# docs_fts_content

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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
)"
Subject: RE: Epstein Sharing Order Part II
Date: Wed, 29 Jan 2020 16:20:27 +0000
I'll let
do his input first, then look at what he's done
From:
(USANYS)
Sent: Wednesday, January 29, 2020 10:40 AM
To:
(USANYS)
is
Subject: Epstein Sharing Order Part Il
- I've updated the sharing order application to be one to share the additional trust and will documents we have now
received. Would you take a look when you can?
- I've tried to describe the various materials we have gotten from the estate attorneys over the last two weeks.
Would you mind taking a look (or asking a paralegal to take a look) to make sure I've accurately described/characterized
the new stuff we're looking to share?
Thanks,
EFTA00011146


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=== Page 1 ===
Case 7:16-cr-00832-KMK Document 119 Filed 04/16/19 Page 1 of 2
Case 7:16-cr-00832-KMK Document 117-1 Filed 04/11/19 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
UNITED STATES,
V.
16 Cr. 832 (KMK)
NICHOLAS TARTAGLIONE,
Defendant.
x
Kenneth M. Karas, District Judge:
WHEREAS, the Bureau of Prisons ("BOP") has certain procedures
in place to protect the workings of its institutions;
WHEREAS, the defendant, by and through counsel, has raised the
concern that certain of the BOP's procedures have the potential to result in defense
strategy and attorney work product being revealed to the Government in
circumvention of the Federal Rules of Criminal Procedure and the Criminal
Justice Act;
IT IS HEREBY ORDERED:
1.
The BOP shall be prohibited from providing to Federal
prosecutors the originals and/or copies of any written communication designated
"attorney work-product" sent by members of the defense team to BOP staff at the
MCC, MDC, or any other facility in which Nicholas Tartaglione (#78514-054)
might be held prior to trial in this case. To facilitate the secure implementation
of this prohibition, the BOP shall not place such materials in Mr. Tartaglione's
EFTA00013272

=== Page 2 ===
Case 7:16-cr-00832-KMK Document 119 Filed 04/16/19 Page 2 of 2
Case 7:16-cr-00832-KMK Document 117-1 Filed 04/11/19 Page 2 of 2
"central inmate file."
2. The BOP shall be prohibited from providing to Federal
prosecutors the originals and/or copies of visitation logs related to "attorney
visits" and/or "legal visits" of Nicholas Tartaglione (#78514-054); this includes
visits to Mr. Tartaglione by defense counsel or other members of the defense team
such as investigators, mitigation specialists, experts, consultants, and mitigation
witnesses. (This proscription does not include "social visits," which are
memorialized in a separate visitation log.)
3. To the extent the United States Attorney's Office is already
in the possession of the type of communications and visitation logs addressed
above, then the Government should immediately disclose all such material to Mr.
Tartaglione so that the defense may then ascertain whether to seek relief under
Rule 12 of the Federal Rules of Criminal Procedure.
4.
Should Mr. Tartaglione be transferred to a non-BOP facility such
as the Westchester County Correctional Facility in Valhalla, New York, this Order
should be interpreted to maintain the same effect.
Granted consent. on governments
Dated: White Plains, New York
April 16 , 2019
So Ordered:
The Honorable Kenneth M. Karas
United States District Court Judge
EFTA00013273


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=== Page 1 ===
From:
To:
Subject: RE: Ghislaine Maxwell custody
Date: Fri, 03 Jul 2020 15:32:25 +0000
Appreciate it, thank you.
From:
Sent: Friday, July 3, 2020 11:21 AM
To:
Subject: Re: Ghislaine Maxwell custody
I will call
and advise - he can be a little touchy.
Sent from my iPhone
On Jul 3, 2020, at 11:13 AM,
wrote:
Thanks. I think it's fine to speak with
bout it, but my sense is that we would also need USMS approval, based on
the email from
If you think it would be ok, I'm happy to reach out to
directly to discuss.
From:
Sent: Friday, July 3, 2020 11:05 AM
To:
Subject: Re: Ghislaine Maxwell custody
I will try. Can I start with
he may be in the best position to get it done?
Sent from my iPhone
On Jul 3, 2020, at 10:23 AM,
Thanks very much for passing this along. The permitted attorney contact on the list below only includes Vogelman
without reference to her New York counsel. Would it be possible to add her two New York attorneys-Chris Everdell
and Mark Cohen-to the list of people Maxwell can speak with on the phone, please?
Ideally, we would like to get them added today so that they can speak with their client over the weekend to facilitate
our discussions with them about next steps in the case.
Thanks,
EFTA00010367

=== Page 2 ===
From:
Sent: Thursday, July 2, 2020 3:47 PM
To:
Subject: Fwd: Ghislaine Maxwell custody
FYI
Sent from my iPhone
Begin forwarded message:
From:
Date: July 2, 2020 at 3:43:43 PM EDT
To: "NHD-SUPERVISORS (USMS)" <USMS-NHD-SUPERVISORS@usms.doj.gov>
Cc:
Subject: Ghislaine Maxwell custody
To all:
Below are the restrictions we have put in place regarding Ms. Maxwell during her stay at Merrimack DOC. I. If you
have any questions please feel free to call or email me.
Due to the high profile status of this case Inmate Maxwell will be closely monitored. The following
directives apply and shall not be deviated from without express permission from
myself or
1.
Inmate Maxwell will be housed in M1
2.
SRT personnel will be posted in medical and will only be relieved only by SRT personnel
3.
Staff will not converse with the inmate outside of the standard communication required related to the
inmate's health and safety
4.
Inmate Maxwell will remain on a 15 minute observation watch
5.
All rounds, and touch probe rounds will be conducted and documented in XJail
6.
Third Shift Supervisors will download the touch probe rounds and camera footage from the previous
day at 0000 hours each day. The video from the medical cell DVR will be downloaded onto a USB drive
and will be tracked via the designated tracking form provided. Supervisors are directed to deliver this
documentation and video to
Monday July 6th
7.
Inmate Maxwell will be authorized to communicate with her legal counsel, Lawrence Vogelman. This
contact is only authorized after Atty Vogelman provides the appropriate PIN
8.
Any and all requests from Inmate Maxwell are to be directed to
only
At no time are staff authorized to make statements to the press regarding this matter or our SOP regarding
this inmate.
EFTA00010368

=== Page 3 ===
Supervisory Deputy United States Marshal
District of New Hampshire
Concord, New Hampshire
office
This e-mail is property of U.S. Marshals Service. It is intended only for the person or entity to which it is addressed
and may contain information that is privileged, confidential, or otherwise protected from disclosure. Distribution or
copying of this e-mail or the information contained herein by anyone other than the intended recipient is prohibited.
If you have received this e-mail in error, please notify me immediately and destroy all electronic and paper copies of
this e-mail.
EFTA00010369


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=== Page 1 ===
To:
From:
Jeffrey Epstein|
Sent:
Sun 1/24/2010 3:37:45 PM (UTC)
Subject:
Re:
what is exagerated. or inaccurate. you and i see things differently. ok. enough
On Sun, Jan 24, 2010 at 10:36 AM,
wrote:
For the record, this email is again your skewed recollection of events, many of which are exaggerated or inaccurate, not reality.
You had told me repeatedly you didn't need me until 5. I asked endlessly if I could help in the morning and when I returned. I came many times and offered you
and your guest refreshments', food, I made
dinner..
From: Jeffrey Epstein
To:
Sent: Sun, January 24, 2010 5:45:29 AM
Subject:
yesterday was emblematic of what appears to be an impossible situation. I told you i had a guest coming that i had
looked forward to meeting for years. I told you the time he was to come.. You refused to tell me if you had confirmed
your flying, and if so the time you were to fly and or return,, though i have asked repeatedely not to be served
restaurant food , you asked me only about menus for lunch. You left without asking or even saying goodbye, You had a
great classic, a great flying day with my great pilot that i arranged for. you, I introduced you to him, in a way that you
asked you refused to tell me when you were to return, you didnot ask if you could help serve lunch, , could you cook
anything( soup for lunch, could you help with my guest, you focused on
,
,
,
you came home
and made a fuss calling her a funcking cunt, stamoing aorund the house, all you did was give me a hard time ,I
suggested you ask her or me any questions that was on your mind, your refused, sayign we both would lie,
then you tell me
could see it right away, I
did not attack you for something
could see. but when
makes the same comment about your behavior,
you view it soley as my doing. you have only been here only three days you have broken your promise every day
exvcept my birthday, which i did have a great day. thank you. I did not lose my temper, I did not sleep/ this is very,
very unfair. You focus on not wanting a record without proposing an alternative solution. it is sad/ i will send
home , i had intended her staying until wed. as i told you last night, soley in response to your actions i already canceled
I am very unhappy with this situation. I tried. i really tried.
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to
, and
destroy this communication and all copies thereof,
including all attachments.
The information contained in this communication is
confidential, may be attorney-client privileged, may
EFTA00011527

=== Page 2 ===
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to
, and
destroy this communication and all copies thereof,
including all attachments.
EFTA00011528


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=== Page 1 ===
From: "
To:
=
Subject: RE: Meeting on Friday
Date: Thu, 06 Sep 2007 13:29:08 +0000
Importance: Normal
Hi
The ASAIC will be there for the meeting. I think she also will be at the OLEOs.
From:
Sent
11:44 AM
To:
Subject: RE: Meeting on Friday
Let's get together at 1:30. FBI is welcome but let's try to limit it to one representative. Is that o.k.?
From:
Sent: Tuesday, September 04, 2007 11:29 AM
To:
Subject: Meeting on Friday
I just left you a voicemail, so you can disregard that. We had a very good meeting with
on Friday. No one
was sure whether you want an FBI presence at the meeting on Friday and
thought I should ask you. Could you let
me know? And does the meeting with Epstein's team start at 2:00? Is there a plan for a pre-meeting meeting with our
folks?
Thanks.
EFTA00013737


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=== Page 1 ===
From:
To:
Cc:
Subject: Ghislaine Maxwell (02879-509)
Date: Mon, 07 Dec 2020 22:03:44 +0000
Attachments: GM_RESPONSE_TO_MDC_LEGALpdf;ATT00001.htm
Good afternoon-
Attached is a courtesy copy of today's ECF filing
in response to the MDC's letter.
EFTA00010185


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=== Page 1 ===
From:
"
(USAFLS)"
To:
(USAFLS)"
Cc:
(USAFLS)"
(USAFLS)"
Subject: please review
Date: Tue, 03 Jun 2008 14:40:17 +0000
Importance: Normal
Attachments: 2DAG060208.wpd
EFTA00013883


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=== Page 1 ===
Court Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
The Mar-a-Lago Club
1100 South Ocean Boulevard
Palm Beach, Florida 33480
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the United States District Court for the Southern District of New York, 40 Foley Square, in the
Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the
following date, time and place:
Appearance Date:
November 29, 2021
Appearance Time: 9:00 a.m.
Appearance Place:
40 Foley Square, Courtroom 906
to testify and give evidence in the following matter:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
Any and all employment records relating to
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
October 5, 2021
/s
AUDREY STRAUSS
United States Attorney for the
UNITED STATES DISTRICT COURT
Southern District of New York
STATES
THE
Assistant United States Attorney
RICT
YORK
One St. Andrew's Plaza
New York, New York 10007
Email:
Telephone:
Rev. 02.01.12
EFTA00010243


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 20-3061 United States of America V. Maxwell "Motion FILED to seal document"
Date: Thu, 08 Oct 2020 20:55:23 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 10/08/2020
Case Name:
United States of America V. Maxwell
Case Number: 20-3061
Document(s): Document(s)
Docket Text:
MOTION, to seal document, on behalf of Appellant Ghislaine Maxwell, FILED. Service date 10/08/2020 by
CM/ECF. [2948488] [20-3061]
Notice will be electronically mailed to:
Assistant U.S. Attorney:
@usdoj.gov
Assistant U.S. Attorney
@usdoj.gov
Assistant U.S. Attorney:
Assistant U.S. Attorney:
Ty Gee, -:
Adam Mueller, -:
Laura Menninger, -:
Gerard Whidbee, Deputy Clerk:
@ca2.uscourts.gov
Notice will be stored in the notice cart for:
Gerard Whidbee, Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Motion FILED
Original Filename: 2020.10.08 Motion for Leave to File RB Under Seal.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=10/08/2020] [FileNumber=2948488-0]
EFTA00010292

=== Page 2 ===
[c39bf875450d32005359a11d8e9823069dd4629182b1fd5a1f2e0fd0f90bc688e1b9fdcc3039ddbe8a3c22af230c8d
EFTA00010293


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=== Page 1 ===
From:
To:
Cc:
Subject: co-conspirator statements/ GX 52
Date: Mon, 15 Nov 2021 22:59:54 +0000
Attachments: 2021.11.15_JSP_Ltr_re_EX_52.pdf;2021.11.15_JSP_Ltr_re_Rule_801(d)(2)(e).pdf
Here are the defense's very brief letter oppositions on these topics.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00010154


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=== Page 1 ===
From
To:
Subject: Epstein update
Date: Fri, 25 Apr 2008 18:51:24 +0000
Importance: Normal
Just received a call from
One of Epstein's private investigators, Robert Myers, has been trying to track
down one of our victims for several days and finally caught up with her today. She told him that she did not
want to talk to him and he then told her that, if she wouldn't talk to him, her name would somehow appear in the
press and she should think about how that will affect her.
put the victim in touch with one of our pro
bono lawyers, and also informed her of her right to contact the police if she feels she is being threatened or
harassed.
In the meantime, this is the latest New York press coverage of Mr. Epstein:
Just Visiting
JEFFREY Epstein - who's facing jail time for soliciting prostitutes, some of whom were under the age of 18 - isn't feeling the love
stateside, so he's skipped the country (temporarily, we're assured) to feel the love in Israel. A rep said Epstein, who was spotted at the
Tel Aviv Hilton over the weekend, "is in Israel for Passover. He's meeting with Israeli scientists about medical research he's funding and
taking a tour of military bases with [Friends of Israel chairman] Benny Shabtai." As for his ongoing legal troubles, the rep added, "It
should be noted that the alleged victims have all acknowledged they lied about their age."
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
EFTA00013730


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: 20cr330, US V. Maxwell
Date: Thu, 11 Nov 2021 21:32:39 +0000
Attachments: 20cr330_SEALED_Mem_Op_&_Order_11.11.21.pdf
412 order from Judge Nathan about a new case the defense mentioned at argument. I think the main point of interest is
the Court's understanding of our various concessions.
From: Nathan NYSD Chambers
Sent: Thursday, November 11, 2021 4:26 PM
To: Jeff Pagliuca
>; Laura Menninger
is
is
is
is
Subject: 20cr330, US V. Maxwell
Counsel:
Attached please find a sealed memorandum opinion and order issued by Judge Nathan. It will be docketed
tomorrow morning after today's holiday.
Sincerely,
Chambers of the Hon. Alison J. Nathan
EFTA00010182


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=== Page 1 ===
Event: Accepted: Meet re Epstein
Start Date: 2019-04-25 14:00:00 +0000
End Date: 2019-04-25 14:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-04-25 13:53:23 +0000
Date Modified: 2019-04-25 13:53:23 +0000
Priority: 5
DTSTAMP: 2019-04-25 13:24:04 +0000
Attendee:
EFTA00013351


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=== Page 1 ===
From:
(USAFLS)"
To:
(FBI)"
(USAFLS)"
(FBI)"
Bcc:
(USAFLS)"
Subject: Re: Epstein
Date: Wed, 28 May 2008 03:45:06 +0000
Importance: Normal
Aaaargh.
The statute of limitations issue is the state statute of limitations. I think
says it is two years. The issue is implicated in two ways. First,
because of the state's leniency for the first set of girls, the second set have been presented only to us for prosecution. If we cannot go
forward, then there will be no prosecution of those crimes. (In response to the argument that
should just present them now, we believe
that some of the victims are unknown to the defense and disclosing them further weakens our case by allowing them to depose and harass
those victims.)
Second, our "state resolution" of the case requires epstein to plead to something that hasn't been charged yet so further delay will allow him
to escape one of the terms of the deal he signed several months ago. (There also is a sol on the private cause of action under 2255 pursuant
to which he must pay damages to the girls. The delay will allow him to escape responsibility for that term, too.)
Other reasons:
The victims are getting older. Clearly one of epstein's arguments will be that he did not know they were minors. The older they are when
they testify the more plausible epstein's argument becomes.
The grand jury we are using will expire soon. We have already presented more than a dozen hours of testimony and the grand jury is
invested and wants to indict.
We promised the girls swift justice so they could move on with their lives.
is a perfect example of why this is needed. The delay so
far has led many to reach out to private lawyers which, in turn, let's e argue that they are only in it for money.
Why give him more time? He has had more than a year's delay already for no reason other than the names of the attorneys he can afford to
hire. This is not a white collar or other non-violent crime. This is a child exploitation crime with more than 20 known child victims. We are
mandated by statute and doj policy to prosecute those cases vigorously and in a timely fashion - whether the children were prostitutes or
unwilling victims. Why is this case being treated so differently?
Original Message
From:
(FBI)
To:
(USAFLS)
Cc:
(FBI)
Sent: Tue May 27 18:45:37 2008
Subject: RE: Epstein
Hey
Sorry to bother you on your vacation. Apparently the DAG is inclined to allow Epstein's counsel to present further arguments.
has requested
and I to prepare, in email format, arguments to present to the DAG supporting why the case should not be
stalled any further.
mentioned statute of limitation issues. I don't know what the specific statute of limitations are (if there are
any) for the various counts. Seems like the statute of limitations was for the life of the victim but I'm not certain. Other points that can be
made include the private investigators continuing to contact the victims and the relocation of our victims to various parts of the country.
Do you have any suggestions as to what would be our best course of persuasion? Thanks and happy travels.
EFTA00013884

=== Page 2 ===
From:
(USAFLS)
Sent: Tuesday, May 27, 2008 2:54 PM
To:
(USAFLS); Senior, Robert (USAFLS)
Cc:
(USAFLS)
Subject: Epstein
Hi
sent me an email about epstein wanting to do less time. I hope that his request will be denied. The original deal was
supposed to be 2 years so he has already gotten a big break. Plus we have identified more victims since we agreed to the 18 months. Please
keep me posted. Thanks.
EFTA00013885


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=== Page 1 ===
From: Trials Law360 <news@law360.com>
To:
Subject: Texas Patent Judges Diverge On Pandemic Trial Protocols
Date: Tue, 13 Oct 2020 08:00:16 +0000
Law360 Trials
TRIALS
How does your salary stack up to your peers?
Take our survey.
Tuesday, October 13, 2020
Follow Law360
TOP NEWS
Law360 Rising Stars
Feature
Texas Patent Judges Diverge On Pandemic Trial Protocols
Two of the busiest patent judges in the country have taken different
approaches to COVID-19 safety precautions as they've resumed in-person
jury trials in Texas, with face-covering preferences and scheduling flexibility
among the biggest points of contrast.
Read full article
J&J Opens Appeal By Assailing 'Radical' $465M Opioid Verdict
Johnson & Johnson unleashed a sweeping assault on a historic judgment
ordering it to pay $465 million for sowing the seeds of narcotic painkiller
addiction in Oklahoma, warning the state's high court that the ruling invites
limitless litigation against major corporations for public health problems.
2 documents attached Read full article
LAW FIRMS
Bangs McCullen
Opioid MDL Bellwether Trial Delayed Amid COVID-19 Fears
Beck Redden
Amid coronavirus concerns, a West Virginia federal judge on Friday
Blank Rome
postponed an eagerly awaited bellwether trial in multidistrict opioid litigation
shortly before its scheduled start, adding to a series of recent setbacks for
Cleary Gottlieb
local governments that blame drug companies for rampant addiction.
Cooley
Order attached Read full article »
Costello Porter
Cozen O'Connor
INTELLECTUAL PROPERTY
Cranfill Sumner
Cravath Swaine
COVID-19 IP Catch-Up: Moderna Promises & Ed Sheeran
DLA Piper
In this round of intellectual property updates tied to the COVID-19 pandemic,
Davis Polk
Moderna said it would hold off on enforcing certain patents and Ed Sheeran
said getting to the U.S. for a copyright trial may be impossible, among many
Edinger Leonard
other litigation updates.
Elliott & Smith
Read full article »
Epstein Becker Green
Faegre Drinker
EMPLOYMENT & BENEFITS
Fleming Nolen
Florio Perrucci
US, Ex-IBM Worker Ask DC Circ. To Revive Tipster Suit
Fogler Brar
Foliart Huff
EFTA00011404

=== Page 2 ===
The U.S. government and a former IBM employee urged the D.C. Circuit
Freshfields
during Friday oral arguments to revive a whistleblower suit claiming the
Gass Weber
company coerced the Internal Revenue Service into a $265 million software
Gibson Dunn
deal.
Read full article
Goldstein & Russell
Jury Rejects EEOC Race Bias Suit Against BBQ Joint
Gomez Trial Attorneys
A federal jury in North Carolina has said Joe's Old Fashioned Bar-B-Que Inc.
Goodwin
was not responsible for a worker's "explosive outburst" and "racial
Greenberg Traurig
comments" against a Black female co-worker, handing a loss to the U.S.
Grubman Shire
Equal Employment Opportunity Commission.
Hogan Lovells
Verdict attached Read full article
Hueston Hennigan
PRODUCT LIABILITY
Irell & Manella
Jenner & Block
Texas Justices Bounce Back Fen-Phen Atty Malpractice Fight
Kaufman Dolowich
The Texas Supreme Court on Friday said a lower court wrongly revived
Kirkland & Ellis
claims that an attorney improperly withheld a cut of a Fen-Phen settlement
Latham & Watkins
he secured for 4,000 former clients, saying the appellate judges' decision
Levy Firestone
was based on an incorrect finding he had submitted unauthenticated copies
of court records.
Littler Mendelson
Opinion attached Read full article
Lynn Jackson
Milbank LLP
COMPETITION
Mintz Levin
Morgan Lewis
Apple Can Keep Fortnite Banned From App Store For Now
Morrison & Foerster
Apple Inc. can keep Epic Games Inc.'s Fortnite video game out of its App
Motley Rice
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Niddrie Addams
applications ahead of a trial scheduled for next year, a California federal
judge ruled in a mixed decision Friday.
Nix Patterson
Order attached Read full article
Norton Rose
O'Melveny & Myers
ENERGY & ENVIRONMENTAL
Odom Sparks
Orrick
Class Says Sunoco Rewriting History To Shake $155M Ruling
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Oklahoma royalty owners accused Sunoco of twisting facts in its attempt to
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of thousands of class members for not automatically paying interest on late
Porzio Bromberg
payments, in a blistering response to the company's motion for a new trial.
Quinn Emanuel
Response attached Read full article
Rumberger Kirk
Ryan Whaley
PERSONAL INJURY & MEDICAL MALPRACTICE
Seyfarth Shaw
Siebman Forrest
Analysis
5 Barrett Med Mal And Injury Rulings Attys Should Know
Skadden
During her three-year tenure as a Seventh Circuit judge, U.S. Supreme Court
Spencer Fane
nominee Amy Coney Barrett has shown a rigorously by-the-books approach
Stoel Rives
to medical malpractice and personal injury cases, including on liability issues
Van Kampen Law
involving the use of excessive force by police that may one day come before
the high court.
Wheeler Trigg
5 documents attached Read full article
Whitten Burrage
Willkie Farr
Colo. Court Affirms $54M Verdict In Bicyclist Crash Suit
WilmerHale
A Colorado appeals court has upheld a $54 million verdict for a cyclist who
Winston & Strawn
was hit by two cars, saying the defendant, a temp agency, forfeited a chance
Yetter Coleman
to cap the award under a state statute.
Yurko Salvesen
Opinion attached Read full article
COMPANIES
Calif. Court Affirms $2.7M Auto Collision Verdict
American Bar Association
EFTA00011405

=== Page 3 ===
A California appeals court has upheld a jury's $2.7 million verdict in a suit
American Civil Liberties Union
accusing a motorist of causing a collision and a man's severe back injury,
AmerisourceBergen Corp.
saying awards for pain and suffering and lost earnings were backed by
substantial evidence.
Apple Inc.
Opinion attached | Read full article
Association of Corporate Counsel
Baretz+Brunelle LLC
Firm Says Malpractice Suit Too Late Over Severed Leg Case
Florio Perrucci urged a New Jersey federal court Friday to toss an insurer's
Bridgestone Corp.
malpractice suit over firm attorneys' failure to assert certain immunity
Cardinal Health Inc.
defenses on behalf of state agencies in litigation over a multivehicle collision
Chambers and Partners
that cost a woman her leg, saying the claims were filed too late.
Cigna Corp.
Motion attached Read full article
Cisco Systems Inc.
Deloitte Touche
EXPERT ANALYSIS
Epic Games Inc.
The Constitutional Risks In Pandemic-Era Criminal Jury Trials
Finjan Holdings Inc.
Virtual voir dire and other pandemic-prompted modifications to jury selection
Fordham University
risk curtailing the Sixth Amendment's guarantee that juries represent a fair
Fox Corp.
cross-section of the community, making criminal convictions vulnerable to
Georgetown University
constitutional attack, say Karin Portlock and Vinay Limbachia at Gibson
Dunn.
Google Inc.
II-VI Inc.
Read full article
International Business Machines
Clients Have The Power To Promote Wellness At Law Firms
Corp.
Law firm clients can play a role in lowering mental distress in the legal
Jaguar Land Rover Ltd.
profession by seeking lawyer wellness data from firms and factoring those
Johnson & Johnson
responses into outside counsel hiring decisions, says Jonathan Prokup
Knights of Columbus USA Inc.
at Cigna.
Los Angeles Angels of Anaheim
Read full article
Los Angeles Rams
LEGAL INDUSTRY
Major Lindsey & Africa LLC
McDonald's Corp.
Barrett Hearings Begin With Focus On ACA, Faith
McKesson Corp.
U.S. Supreme Court nominee Amy Coney Barrett spent the first day of her
Microsoft Corp.
confirmation hearings Monday listening as Democrats cast her as a threat to
Moderna Inc.
the Affordable Care Act and Republicans accused liberals of attacking her
Morgan Stanley
Catholic faith.
National Collegiate Athletic
Read full article
Association
Seyfarth Shaw Hit By Ransomware Attack
National Employment Law Project
Seyfarth Shaw LLP confirmed Monday it had been hit by a cyberattack over
National Hockey League
the weekend, causing the firm to temporarily shut down some of its systems.
New York University
Read full article
New York Yankees
Noramco Inc.
Analysis
Norfolk Southern Corp.
Beyond The Big Offer: Lateral Partner Pay Pitfalls To Avoid
Too many prospective lateral partners look only at a firm's offer figure, without
Pac-12 Enterprises LLC
considering numerous other factors needed to properly vet a compensation
Paypal Holdings Inc.
package before accepting a job, recruiters say.
Pfizer Inc.
Read full article
Purdue Pharma LP
Regeneron Pharmaceuticals Inc.
Stoel Rives, Mintz Levin Reverse Pandemic Pay Cuts
Roku Inc.
Stoel Rives LLP and Mintz Levin Cohn Ferris Glovsky and Popeo PC on
San Francisco 49ers
Friday became the latest firms to confirm that they will restore salaries to pre-
pandemic levels after several months of cuts.
San Jose Sharks
Read full article
SoFi Stadium
Social Finance Inc.
Willkie Hops On Fall Bonus Bandwagon As Other Firms Pass
Sony Corp.
Southern Illinois Healthcare
EFTA00011406

=== Page 4 ===
Willkie Farr & Gallagher LLP confirmed Friday that it will be giving U.S.
State Bar of California
associates bonuses at the end of October, becoming the latest firm to match
Sunoco LP
the pandemic-related bonuses set forth by Davis Polk & Wardwell LLP as
Teva Pharmaceutical Industries
others have announced their decisions not to follow suit.
Ltd.
Read full article
Women GCs On When And How To Speak Out
The Aerospace Corp.
Mary Smith, vice chair and general counsel of the VENG Group, remembers
The Sports Lawyers Association
several years ago when an outside counsel planned a dinner meeting with
Thomson Reuters Corp.
senior members of her then-legal department at a private club that did not
VirnetX Holding Corporation
allow women members.
Read full article
GOVERNMENT AGENCIES
COPRAC
In The Trenches Of Sports Law, It's All About The Pandemic
Centers for Disease Control and
Todd Davis, vice president for legal affairs for the NFL's Los Angeles Rams,
Prevention
said that in his 29 years with the team, he spent maybe 29 minutes on force
Central Intelligence Agency
majeure clauses - until this year's COVID-19 crisis.
Equal Employment Opportunity
Read full article
Commission
600 Law Students Boycott Paul Weiss For Repping Exxon
Federal Bureau of Investigation
Law students on Friday afternoon delivered a letter to the Manhattan
Internal Revenue Service
headquarters of Paul Weiss Rifkind Wharton & Garrison that was signed by
New Jersey Supreme Court
over 600 law students pledging to boycott the firm over its continued
Occupational Safety and Health
representation of ExxonMobil.
Administration
Read full article
Office of Federal Contract
Compliance Programs
Legal Recruiter Drops Fee Suit Against Freshfields
Office of the Comptroller of the
A Massachusetts executive recruiting firm on Friday dropped its case that
Currency
accused Freshfields Bruckhaus Deringer US LLP of refusing to pay millions
Oklahoma Supreme Court
of dollars in fees owed for its work recruiting a successful corporate law
partner from Cleary Gottlieb Steen & Hamilton LLP.
Small Business Administration
Read full article
Texas Supreme Court
U.S. Attorney's Office
Analysis
U.S. Court of Appeals for the
Up Next At High Court: When A Shooting Becomes A 'Seizure'
District of Columbia Circuit
All eyes will be on Capitol Hill next week for Judge Amy Coney Barrett's
U.S. Court of Appeals for the
confirmation hearings, but her would-be colleagues at the U.S. Supreme
Seventh Circuit
Court will be diving into a key civil liberties case involving the meaning of the
word "seizure" under the Fourth Amendment and another involving debtors'
U.S. Department of Justice
rights.
U.S. Department of Labor
Read full article
U.S. Department of Veterans
Affairs
Supreme Court Extends Phone Hearings Through December
U.S. District Court for the District of
The U.S. Supreme Court said Friday it would continue holding oral
Massachusetts
arguments via phone through the end of the year because of the coronavirus
U.S. District Court for the District of
pandemic, a period that includes blockbuster cases on the Affordable Care
New Jersey
Act, the First Amendment and the special counsel's investigation.
U.S. District Court for the Eastern
Read full article
District of New York
U.S. District Court for the Middle
GC Cheat Sheet: The Hottest Corporate News Of The Week
District of Alabama
Shoplet's former top attorney was sentenced to three to nine years in prison
U.S. District Court for the Middle
for stealing millions from the online retailer's PayPal account, and a survey
found that the pandemic will likely force some law departments to eliminate
District of Georgia
or freeze merit increases in 2021. These are some of the stories in corporate
U.S. District Court for the Northern
legal news you may have missed in the past week.
District of California
Read full article
U.S. District Court for the Southern
District of West Virginia
In Case You Missed It: Hottest Firms And Stories On Law360
U.S. Senate
For those who missed out, here's a look back at the law firms, stories and
U.S. Supreme Court
expert analyses that generated the most buzz on Law360 last week.
EFTA00011407

=== Page 5 ===
Read full article
United States District Court for the
Podcast
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Law360's Pro Say: The Road Ahead For Amy Coney Barrett
United States District Court for the
Supreme Court nominee Amy Coney Barrett heads to Capitol Hill next week
Eastern District of Oklahoma
for confirmation hearings that are likely to produce fireworks over health care,
United States District Court for the
abortion and the Republican effort to seat a new justice on an expedited
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=== Page 1 ===
From:
To:
Cc:
Subject: Juror questionnaires to review for tomorrow
Date: Wed, 17 Nov 2021 00:41:52 +0000
Attachments: US_v_Maxwell_Jurors_Proceeding_to_Voir_Dire_(printable_version).xlsx
Hey team,
Since
won't be in court tomorrow, I have reassigned the juror questionnaires for you guys to take on. The new
ones start at row 71 (juror 199), with the one exception that I also reassigned
rows 39 and 40 (the last two from
first batch we didn't get to today).
'Il print yours out so we have the same hard copy notes method.
since I didn't get this
done before you headed out, if you want to take notes in the spreadsheet attached and send to me by 7:45am tomorrow,
I can print it out in the morning (but obviously do what's best for you note taking wise, I'm happy to accommodate
however I can).
Thanks.
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
KIRKLAND & ELLIS LLP
AND AFFILIATED PARTNERSHIPS
Jay P. Lefkowitz, P.C.
To Call Writer Directly:
Facsimile:
www.kirkland.com
June 19, 2009
VIA FEDERAL EXPRESS
United States Attorney's Office
Southern District of Florida
Re: Jeffrey Epstein
Dear
,
I appreciate your letter of June 17, 2009. I sincerely hope that any and all issues that
could generate an adversarial relationship between Mr. Epstein and the United States Attorney's
Office are in our past. Like you, we hope that the ongoing, complex, and at times vigorous
litigation will not again require your involvement, nor result in any belief on your part that any
legal position taken by Mr. Epstein's counsel conflicts with the Non-Prosecution Agreement
("NPA").
In order to avoid future misunderstandings, however, I would like to have a discussion
with you specifically about our ongoing obligations as you understand them under the NPA. As
you know from past experience, and as Mr. Acosta previously acknowledged in letters to my
partner Ken Starr (on December 4, 2007) and Lilly Ann Sanchez (on December 19, 2007), the
language of 8 is "far from simple," and, in certain respects, subject to significant ambiguity.
I believe it is both necessary and appropriate to seek immediate clarification from the
government about its understanding of a few provisions in the NPA. It is likely by no fault of our
own that these issues will come before a judge or an independent third party, whose job it will be
to interpret the intent of the parties. In those circumstances, I think the court would most likely
turn to both of us and directly seek our views, as the drafters of the agreement, before rendering
its own opinion. Therefore, I believe it would bring about the finality that we both seek in a
much reduced time frame if we could discuss several of the more ambiguous provisions
contained in the NPA.
Chicago
Hong Kong
London
Los Angeles
Munich
San Francisco
Washington, D.C.
EFTA00013855

=== Page 2 ===
June 19, 2009
Page 2
One specific example comes to mind. First, we clearly understood during the course of
negotiating the NPA, and believe that both the language of the NPA and our prior
correspondence with your Office confirm, that the waiver of liability set forth in Paragraph 8 at
most was designed to allow an identified individual the right to assert a single violation of a
section 2255 predicate. The waiver of liability does not embrace situations where a particular
plaintiff asserts multiple violations. Thus, compliance with paragraph 8's waiver of liability
would require at most that Mr. Epstein stipulate to the existence of a single enumerated predicate
that would entitle an otherwise eligible plaintiff to actual damages (or the applicable statutory
minimum damages where actual damages fall short of that floor), leaving aside the issue of
whether the waiver is applicable to contested litigation or only the cases where there would be
agreed damage resolutions. In addition, if we believe that a predicate act is time-barred, as
indeed we understand was the case with respect to all such acts in relation to one plaintiff, a
proper construction of the waiver of liability would not preclude the reliance on a statute of
limitations defense.
Given your Office's prior acknowledgements that the language of the NPA is far from
clear, we very much would appreciate an opportunity to discuss Paragraph 8 with you in the very
near future in order to clarify a few pivotal questions raised by the NPA. I assure you that
Mr. Epstein intends to abide fully by the terms of the NPA. And it is my sincere hope that our
discussion can avert future risks that anything we do will cause you to believe that there has been
a breach of the NPA.
Finally, I enclose a letter in response to your June 15 letter in order to provide you with
our perspective on the issues you raised. I hope our differing views on certain events over the
past several years as reflected in my letter will not in anyway divert us from a common goal of
having Mr. Epstein complete his NPA obligations without further tension with your Office.
Jay Sincerely, help
Jay P. Lefkowitz, P.C.
Enclosures
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=== Page 1 ===
From:
nce
Date:
Friday, October 9, 2020 5:03:27 PM
Will do. Safe travels.
NY CART Coordinator
Senior Forensic Examiner
On Oct 9, 2020 4:50 PM,
wrote:
Hey
I know you mentioned you'd be at the evidence garage on Wednesday. While you are there, can
you check on some of the below items?
Can you find out what the NY Cart numbers are for 1B 53 and 1B 57? I have one number 024329.
I'm not sure which one this is associated to and what the other one is.
Also, can you check on 1B 29, 1B 30, and 1B 32 to see if they were processed or are they duplicates?
If they are duplicates, which 1B are each of them a duplicate of?
Can you also pull 1B 35, 1B 36, 1B 37, 1B 38, 1B 39, and 1B 40 and see what each of their Cart
numbers are?
I will be out next week. I'll be six hours ahead of you timewise, so feel free to call me if there are
questions or you'd like to talk through. I cc'd Kelly here as someone who will be in the office if you
have questions. I filled her in as well so she should be able to help you if questions arise.
Special Agen
FBI New York Field Office
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=== Page 1 ===
From: Mail Delivery Subsystem <MAILER-DAEMON@DJMDCJC01-PPOINT08.jcots.jutnet.net>
To:
Subject: [EXTERNAL] Returned mail: see transcript for details
Date: Mon, 15 Nov 2021 03:34:03 +0000
Embedded: unnamed
The original message was received at Mon, 15 Nov 2021 03:33:57 GMT
from [10.187.9.62]
The following addresses had permanent fatal errors
=====
<bcssternheim@mac.com>
(reason: 550 5.1.1 <bcssternheim@mac.com>: user does not exist)
-----
Transcript of session follows
while talking to mx02.mail.icloud.com.:
DATA
550 5.1.1 <bcssternheim@mac.com>: user does not exist
550 5.1.1 <bcssternheim@mac.com>. User unknown
554 5.5.1 Error: no valid recipients
EFTA00010153


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=== Page 1 ===
From:
)"
To:
Cc:
(USANYS)"
)"
]"
Subject: United States V. Ghislaine Maxwell --
opens
Date: Sun, 28 Nov 2021 14:59:08 +0000
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors will
do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine Maxwell
sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
(USANYS)"
Subject: Outstanding requests - update
Date: Mon, 09 Sep 2019 14:56:03 +0000
Attachments: 2019.07.27_Daily_Assignment_Roster.pdf
I'm working though the outstanding requests, specifically those that we sent
last week.
The
Commissary Reports are in the shared here:
\usa.doj.gov\cloud\nys\StAndrews\Shared\InReEpsteinDeath-2019R01059\Evidence\Epstein General BOP Records
Additionally, the records for
and
(no
or
)
are here as well (in the same document).
However, all they entail is a single truview page and nothing else. The actual receipts are only for Epstein,
and
What I'm not sure on is the signed SHU post order review sheets. I have looked through the files and can't seem to find
them anywhere. Albeit I don't know what they look like but I do think I would have recognized them. I will keep looking.
Lastly, are the post orders for SHU the same as the daily assignment roster? I've attached one of them as an example. If
so, we are missing several from the time period that we requested (7/1 - 8/10).
I'm going to continue to work through the spreadsheet as well.
Paralegal Specialist
U.S. Attorney's Office
I
SDNY
1 St. Andrew's Plaza
New York, NY 10007
Office:
Cell:
EFTA00009964


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=== Page 1 ===
DAG Meeting Case Overview
Acting U.S. Attorney
November 5, 2020
I.
Anticipated Charges and Investigative Steps
EFTA00013209

=== Page 2 ===
DAG Meeting Case Overview
Acting U.S. Attorney
November 5, 2020
II.
Charged Cases
U.S. V. Maxwell, 20 Cr. 330 (AJN): This summer, we charged Ghislaine Maxwell with
conspiring to entice minors to travel for the purpose of sexual abuse in connection with helping
Jeffrey Epstein to abuse his many victims. The case focused on three specific victims that
traveled to be abused by Epstein, including instances in which Maxwell herself participated in
the acts of abuse. Trial is set for this coming July. We are finishing discovery, and motions are
scheduled for December. Motion practice could generate further press; for example, the
defendant continues to press for the identity of the specific victims, and if she is successful, that
would surely lead to a round of press about the victims and the details of our case. Relatedly, we
are in plea negotiations with counsel for
,
another Epstein co-conspirator.
,
who scheduled hundreds of sexual massages with minors for Epstein but was also a victim of his
sexual abuse, may plead to an obstruction of justice-related count.
EFTA00013210


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=== Page 1 ===
From:
To:
Subject: Re: Epstein
Date: Thu, 11 Dec 2008 01:10:49 +0000
Importance: Normal
What ois your schedule tomorrow, lets talk am if possible.
Original Message
Fro
To:
Sent: Wed Dec 10 19:05:30 2008
Subject: Fw: Epstein
I was hoping to preempt this.
Original
From:
To:
Sent: Wed Dec 10 18:41:55 2008
Subject: Epstein
Article coming out tomorrow about Epstein's work release. It will be in a small Palm Beach paper. U can c article tonight online. Call me if
u have a problem finding it and I will get more info. Both Herman and Goldberger are quoted.
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=== Page 1 ===
From: "
(USAFLS)"
To:
(USAFLS)"
Subject: RE: Follow up
Date: Thu, 18 Oct 2007 22:02:01 +0000
Importance: Normal
Thank you!
Assistant U.S. Attorney
Fax 561 820-8777
Original Message
From:
(USAFLS)
Sent: Thursday, October 18, 2007 5:55 PM
To:
(USAFLS)
Subject: FW: Follow up
fyi
Original Message
From: Jay Lefkowitz [mailto:
Sent: Thursday, October 18, 2007 5:48 PM
To:
(USAFLS)
Cc: Acosta, Alex (USAFLS)
Subject: Re: Follow up
That is correct.
Jay
Original Message
From:
(USAFLS)"
Sent: 10/18/2007 05:43 PM AST
To: Jay Lefkowitz
Cc: "Acosta, Alex (USAFLS)"
Subject: RE: Follow up
Jay,
Please confirm that this will not affect when Epstein begins serving his sentence. If it does, I have to reconsider
postponement of the guilty plea date. Thanks,
Original Message
From: Jay Lefkowitz [mailto:
Sent: Thursday, October 18, 2007 4:44 PM
To:
(USAFLS)
Cc: Acosta, Alex (USAFLS)
Subject: Re: Follow up
Thanks very much.
EFTA00013503

=== Page 2 ===
Original Message
From:
(USAFLS)"
Sent: 10/18/2007 04:39 PM AST
To: Jay Lefkowitz
Cc: "Acosta, Alex (USAFLS)"
Subject: RE: Follow up
The change of plea will take place on November 20. Agreed.
Original Message
From: Jay Lefkowitz [mailto:
Sent: Thursday, October 18, 2007 4:35 PM
To: Acosta, Alex (USAFLS)
Cc:
(USAFLS)
Subject: Re: Follow up
Alex - Thanks.
are we all set?
,
Jay
Original Message
From: "Acosta, Alex (USAFLS)"
Sent: 10/18/2007 12:15 PM AST
To: Jay Lefkowitz
Cc:
(USAFLS)"
Subject: RE: Follow up
-- Can you see any issues with this? If not, please confirm with
Jay.
Original Message
From: Jay Lefkowitz [mailto:
Sent: Thursday, October 18, 2007 10:12 AM
To: Acosta, Alex (USAFLS)
Subject: Follow up
Alex - I wanted to thank you for making the time for
breakfast Friday. It was great to catch up.
Following up on our conversation about the date for Mr.
Epstein's plea, where you said that you didn't want to
dictate a schedule to the state, as we discussed I have
a case where I represent an individual who is now the
lead witness for the government, and openings are set
for next week. Accordingly, I have now confirmed with
Mr. Epstein's Florida counsel that the state's
attorney's office and the court will be available to
have him enter his plea on November 20. So we will
plan to proceed on one that date. Please confirm that
this is ok.
Thanks, Jay
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
EFTA00013504

=== Page 3 ===
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
EFTA00013505


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=== Page 1 ===
Event:
Start Date: 2008-06-13 14:00:00 +0000
End Date: 2008-06-13 14:30:00 +0000
Organizer:
Location
's ofc.
Class: X-PERSONAL
Date Created: 2006-05-09 15:59:01 +0000
Date Modified: 2006-05-09 15:59:01 +0000
Priority: 5
DTSTAMP: 2008-06-11 15:27:38 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
When: Friday, June 13, 2008 10:00 AM-10:30 AM (GMT-05:00) Eastern Time (US & Canada).
Where:
's ofc.
you can participate by phone. Let me know best number, Thanks,
Original Message
From:
(USAFLS)
To:
Cc:
Sent: Wed Jun 11 10:29:23 2008
Subject: RE: Epstein
Spoke with
Everyone is good for 10:00 this Friday morning.
will be calling
office
EFTA00013971

=== Page 2 ===
From:
(USAFLS)
Sent: Wednesday, June 11, 2008 10:21 AM
To:
Cc:
Subject: RE: Epstein
I'm available anytime
From
(USAFLS)
Sent: Wednesday, June 11, 2008 10:09 AM
To:
Cc:
Subject: RE: Epstein
Absolutely, I'm available from 10 to 11 and after 11 have a conflict.
From:
(ODAG) (SMO)
Sent: Wednesday, June 11, 2008 10:02 AM
To:
Cc:
Subject: Epstein
EFTA00013972

=== Page 3 ===
Would you guys be available Friday morning by telephone to discuss?
EFTA00013973


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=== Page 1 ===
From:
To:
Cc:
Bec: "USAHUB-USAJournal111"
Subject: RE: FW: Ghislaine Maxwell 02879-509
Date: Mon, 16 Nov 2020 17:35:53 +0000
Embedded: RE:_FW:_Ghislaine_Maxwell_02879-509.msg
Sender
Subject: RE: FW: Ghislaine Maxwell 02879-509
Message-Id:
<SN5P110MB05421963E68BCE6BABAACCEF92E30@SN5P110MB0542.NAMP110.PROD.OUTLOOK.CO
M>
To:
Cc:
Cc:
EFTA00009918


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: Citecheck
Date: Wed, 27 Oct 2021 19:51:23 +0000
Attachments: Govt_Reply_v2.docx
Hey
Thanks for hopping on this! Here's a portion of a brief we need citechecked. If there are cites you can't check because
you don't have the documents, just highlight them and I'll check them.
Thanks, and let me know if you have any questions!
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00010701


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=== Page 1 ===
From:
Bcc: "USAHUB-USAJournal111"
Subject: Notes from 2020.11.19 Call with
Date: Thu, 19 Nov 2020 19:34:00 +0000
Embedded: Notes_from_2020.11.19
Sender:
Subject: Notes from 2020.11.19 Call with
Message-Id:
<CY1P110MB01841D6382B59F289A07B9708AE00@CY1P110MB0184.NAMP110.PROD.OUTLOOK.COM
>
To:
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=== Page 1 ===
From:
To:
Subject: FYI -- in case you hadn't seen already
Date: Wed, 17 Apr 2019 13:57:57 +0000
Importance: Normal
https://www.nbcnews.com/news/us-news/alan-dershowitz-sued-defamation-connected-epstein-sex-abuse-claims-
n995271
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
February 28, 2019
TO BE FILED UNDER SEAL
VIA EMAIL
The Honorable Sarah Netburn
United States District Court
Southern District of New York
United States Courthouse
New York, New York 10007
Re:
In re Application to Unseal Civil Discovery Materials, USAO No. 2018R01618
Dear Judge Netburn:
The Government writes respectfully in connection with its sealed application and proposed
order pursuant to the All Writs Act, Title 28, United States Code, Section 1651, for a limited order
to unseal discovery materials in the possession of Boies Schiller & Flexner LLP
(the "Application"), in connection with the matter Jane Doe 43 V. Epstein, et al. ("Jane Doe"),
17 Civ. 616 (JGK) (SN) (the "Litigation"), a copy of which is attached hereto as Exhibit A.
Background
As described in the Application, the Government has served a grand jury subpoena
(the "Subpoena") upon Boies Schiller & Flexner ("Boies Schiller") requiring the production of
copies of discovery and related materials related to the Litigation. The Subpoena was validly
issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations
of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and
Section 2422(b) (unlawfully enticing minors) (the "Investigation"). The production of materials
pursuant to the Subpoena is solely for the purposes of the Investigation, and is subject to the
protections and restrictions of Fed. R. Crim. P. 6(e).
The Government has been advised that Boies Schiller, which is counsel for plaintiffs in the
Litigation, does not intend to contest the Subpoena. However, the Government is advised that
although Boies Schiller would not otherwise contest compliance with the Subpoena, it believes
that a protective order entered in the Litigation (the "Protective Order") may preclude compliance.
Accordingly, the Government respectfully requested that the Court issue an order
permitting Boies Schiller to comply with the validly-issued Subpoena.
SDNY_GM_00000919
CONFIDENTIAL
EFTA00011520

=== Page 2 ===
Page 2
Discussion
Where, as here, a grand jury subpoena has validly issued, and the recipient of the subpoena
is not contesting compliance-but rather seeking authorization to comply with the subpoena-a
court should grant such permission through limited modification of an applicable protective order,
absent countervailing interests not present in this case. As described below, a court can and should
modify a protective order, or permit limited relief from it, to allow the recipient of a grand jury
subpoena to comply with such a subpoena under the circumstances presented here.
The Court is best guided by the decision in Chemical Bank V. Affiliated FM Ins. Co., 154
F.R.D. 91 (S.D.N.Y. 1994), which rejected an application for a party in civil litigation to be held
in contempt for complying with a grand jury subpoena despite the existence of a protective order,
without first obtaining authorization from the court, because the court would have granted such
authorization had it been sought. Chemical Bank, 154 F.R.D. at 93. As that court explained:
The role of the federal courts in law enforcement, exemplified by
the Federal Criminal Code (Title 18, USC) and in enforcing Grand
Jury subpoenas argues in favor of making significant information
available to enforcement authorities absent a countervailing
showing that the need for the information for such purposes is
outweighed by the need for protecting expectations of
confidentiality under Fed. R. Civ. P. 26(c).
Id. at 94 (citing United States V. Davis, 702 F.2d 418, 421-22 (2d Cir. 1983) (finding that the
"conflict between protection of private material used in a civil proceeding and public need in a
criminal prosecution" posed in that case was "easily resolved" and explaining that "[a]bsent
applicable grounds for exception, such as a previously asserted Fifth Amendment privilege, no
shiled protects the civil evidence" in that case "from compellable production before the grand jury
which subpoenaed it"). The court in Chemical Bank chastised the relevant party for responding to
the grand jury subpoena without authorization specifically because such disregard was "entirely
unnecessary and inappropriate" due to the readily available remedy of a modification of the
applicable protective order. Chemical Bank, 154 F.R.D. at 93. The court also explicitly noted that
such formal judicial approval could be obtained ex parte if sufficient reason for doing so was
shown. Id.
Chemical Bank further described the types of interests that otherwise might be implicated
in connection with a Rule 26(c) protective order, none of which are implicated here. Id. at 94
("There is no indication that any difficult balancing under Fed.R.Civ.P. 26(c) would have been
necessary of interests of law enforcement against protection of technological trade secrets,
currently sensitive customer lists, or contemporarily sensitive competitive information which
could benefit rivals, since no such information has been claimed to have been contained in any of
the discovery materials in this case.") (citations omitted).¹
I Notably, here, and in contrast to other cases further described below, the Government's specific
knowledge of the subject matter of discovery materials is relatively limited, due to the confidential
nature of the Litigation; however, the Protective Order itself indicates that discovery materials
SDNY_GM_00000920
CONFIDENTIAL
EFTA00011521

=== Page 3 ===
Page 3
Indeed, the Chemical Bank opinion specifically rejected judicial protection for the type of
information the Protective Order appears to cover in the Litigation:
Avoiding embarrassment may be a reason for a party to seek
confidentiality. It is not by itself a valid reason for courts to uphold
confidentiality as against a legitimate law enforcement need for the
information. Courts must honor restrictions laid down by the Fourt
or Fifth Amendment or applicable statutes. But aside from those
restrictions, hiding possible criminal violations from law
enforcement authorities is hardly a ground for judicial protection of
confidentiality.
Chemical Bank, 154 F.R.D. at 94 (emphasis added). Although parties may rely on confidentiality
agreements and protective orders generally, such classification "is not binding on the court" and
the "risk of disclosure is well known to the Bar, in part because disclosure may be required where
such information is needed for judicial decisions, to the basis for which the public should have
access. Id. (collecting cases).
Under some circumstances, courts in this Circuit have applied a balancing test to evaluate
the government's ability to obtain access to materials covered by a protective order. Specifically,
in Martindell V. International Tel. and Tel. Corp., 594 F.2d 291 (2d Cir. 1979), the government
informally-and without use of a grand jury subpoena-sought access to discovery materials from
a civil litigation. The Court held that the Government was not entitled to the materials unless it
could show either that the protective order was improvidently granted or some extraordinary
circumstance or compelling need for the material; see also In re Grand Jury Subpoena Duces
Tecum Dated Apr. 19, 1991 ("Subpoena Duces Tecum"), 945 F.2d 1221, 1224 (2d Cir. 1991) (in
connection with bankruptcy proceeding, and citing Martindell, vacating denial of a motion to
quash a grand jury subpoena seeking production of documents subject to protective order and
remanding for determination of showing that the order was improvidently granted or of
extraordinary circumstance or compelling need).
As an initial matter, the Court need not employ the Martindell balancing test here. This is
so for two reasons. First, Martindell and cases employing its balancing test generally relate to
motions to quash or other challenges to a grand jury subpoena, or else instances where the
Government sought protected information without such grand jury process. See Martindell, 594
F.2d 291 (in which the government informally, and without use of a grand jury subpoena, sought
access to discovery materials); Subpoena Duces Tecum, 945 F.2d at 1224 (vacating denial of a
motion to quash a grand jury subpoena). Here, there is no such deficiency in the form of request
nor a challenge by the recipient of the subpoena. Indeed, in Chemical Bank, which cited
Martindell, the district court opined that had the Government obtained judicial relief to issue an
such as documents and depositions are not likely to include the kind of confidential business
information that Chemical Bank describes as having the potential to give rise to "difficult
balancing." See id.; see also Jane Doe, Protective Order ("Prot. Order") (Dkt. 177) (defining
"confidential" information as, in sum and substance, medical and psychological information,
personal identifying information, and information relating to sexual activity or sexual contact).
SDNY_GM_00000921
CONFIDENTIAL
EFTA00011522

=== Page 4 ===
Page 4
uncontested subpoena for documents-precisely the scenario here-such relief would be
appropriate. Chemical Bank, 154 F.R.D. at 94.
Second, any presumption against modification of a protective order is unreasonable where,
as here, the protective order is on its face temporary or limited. Such protective orders "that are
on their face temporary or limited may not justify reliance by the parties [and] in such
circumstances reliance may be unreasonable." S.E.C. V. TheStreet.com, 273 F.3d 222, 230-31 (2d
Cir. 2001). "Where a litigant or deponent could not reasonably have relied on the continuation of
a protective order"-for example, where such an order was limited to the pretrial stages of
litigation-"a court may properly permit modification of the order." Id. (citing In re "Agent
Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987)); see also Allen V. City of New York,
420 F.Supp.2d 295, 301 (S.D.N.Y. 2006) (Mag. J. Gorenstein) (analyzing the differently-situated
interests of civil litigants but where, as here, the relevant protective order specified that a party
could object to the designation of a document as confidential, and was also temporary or limited
on its face). In such a case, "[w]hether to lift or modify a protective order is a decision committed
to the sound discretion of the trial court." TheStreet.com, 273 F.3d at 231 (modification in
original) (citing In re Agent Orange, 821 F.3d at 147) (additional citations omitted). Here, the
parties in the Litigation explicitly contemplated the public disclosure of such information at trial
by the very terms of the Protective Order, thereby establishing precisely the kind of temporal limit
described above. See Prot. Order at 6 ("This Protective Order shall have no force and effect on
the use of any CONFIDENTIAL INFORMATION at trial in this matter."). The parties could not
have-as, for example, they might in a bankruptcy proceeding such as in Subpoena Duces
Tecum-relied upon the Protective Order to indefinitely keep the relevant materials hidden.
In this case, where the Protective Order is limited by its terms to only the pretrial stages
of the civil litigation, no confidential business information appears to be at issue, and counsel for
the victims of the suspected crimes being investigated have indicated a willingness to voluntarily
comply with the Subpoena, the "sound discretion of [this] court," TheStreet.com, 273 F.3d at 231,
militates overwhelmingly toward limited, narrow modification of the Protective Order to permit
compliance with the Subpoena.² This is consistent with the grand jury's "wide ranging authority
to inquire into suspected violations of the criminal law; and to effectuate such investigations it may
compel the production of documentary evidence or the testimony of witnesses, as it deems
necessary." Id. at 421-22; see Branzburg V. Hayes, 408 U.S. 665, 688 (1972) ("Although the
powers of the grand jury are not unlimited and are subject to the supervision of a judge, the
longstanding principle that 'the public
has a right to every man's evidence,' except for those
2 The Government notes that any materials produced pursuant to a grand jury subpoena fall under
the protections and restrictions set forth in Fed. R. Crim. P. 6(e), and further notes and emphasizes
that the proposed order accompanying the Application provides no additional exception or
modification to the Protective Order as to the recipient of the subpoena other than the narrow,
limited ability to comply with grand jury process. The Protective Order will remain otherwise
intact and fully enforceable.
SDNY_GM_00000922
CONFIDENTIAL
EFTA00011523

=== Page 5 ===
Page 5
persons protected by a constitutional, common-law, or statutory privilege is particularly applicable
to grand jury proceedings.") (citations omitted).³
Finally, even were the Court to apply the Martindell test here,⁴ despite the significant
distinguishing factors described above, this Investigation is a paradigmatic example of
extraordinary circumstances. In the first instance, unlike in Subpoena Duces Tecum, the posture
of the Application does not involve a motion to quash. Of course, should this Court permit Boies
Schiller to respond, Boies Schiller would have the right to move to quash-including, for example,
if a grand jury subpoena made any improper requests, such as for materials subject to privilege.
But it is not anticipated that Boies Schiller will do so.
Additionally, as set forth in the Application, the existence and scope of the Investigation
in this district is not publicly known. While counsel for certain victims are aware of the
Investigation, neither Epstein nor other subjects of the investigation are believed to be similarly
aware. Accordingly, the ordinary exercise of grand jury power to "subpoena witnesses to testify,
regardless of whether they have already testified or furnished documentary evidence in civil
litigation," Martindell, 594 at 296, would implicate and invite the very risk of disclosure-and the
possibility of alerting potential criminal targets that they are under investigation, causing them to
destroy evidence, flee from prosecution, or otherwise seriously jeopardize the Investigation-that
caused the Government to proceed via subpoena and its related Application. Cf. Subpoena Duces
Tecum, 945 F.2d at 1224 (in which the party that moved to quash the relevant subpoena argued
that the government could not meet its burden of showing need for deposition testimony until it
had at least called the witness before the grand jury).
The subject matter of the Litigation also demonstrates the extraordinary circumstances of
the Government's Investigation and Application, insofar as the materials at issue here appear not
to be of the sort that ordinarily would provide protection against Government investigation. See
3 To read Martindell more broadly would not only be contrary to the opinion itself, as described
above, but would risk rendering that opinion in even further conflict with the well-reasoned
decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have
each adopted a per se rule favoring enforcement of a grand jury subpoena even where a protective
order exists. See In re Grand Jury Subpoena, 836 F.2d 1468, 1477 (4th Cir.), cert. denied, 487
U.S. 1240 (1988); In re Grand Jury Subpoena Served on Meserve, Mumper & Hughes, 62 F.3d
1222, 1226-1227 (9th Cir. 1995); In re Grand Jury Proceedings (Williams), 995 F.2d 1013, 1020
(11th Cir. 1993) (expressly criticizing the Martindell test and stating that it "is administratively
unworkable," "defies construction," and "places prosecutors in untenable positions"). In the First
and Third Circuits, a grand jury subpoena overrides a protective order unless the party seeking to
quash the subpoena shows "exceptional circumstances that clearly favor subordinating the
subpoena to the protective order." In re Grand Jury Subpoena (Roach), 138 F.3d 442, 445 (1st
Cir.), cert. denied, 524 U.S. 939 (1998); In re: Grand Jury, 286 F.3d 153, 157-158 (3d Cir.
2002). The Government is aware of no case in those circuits where the presumption was rebutted
and the grand jury subpoena was not enforced.
4 An application of the Martindell test would not in any event preclude the provision of a list of
witnesses deposed, see 594 F.2d at 293, and of pre-existing documents collected or produced in
the course of discovery, see id. at 297 n.8.
SDNY_GM_00000923
CONFIDENTIAL
EFTA00011524

=== Page 6 ===
Page 6
Chemical Bank, 154 F.R.D. at 94 (describing such materials a "technological trade secrets,
currently sensitive customer lists, or contemporarily sensitive competitive information which
could benefit rivals"). Rather, the Government seeks materials that relate to among the gravest
criminal offenses it investigates-the sexual exploitation of minors-which materials, if revealed,
would tend to inculpate and/or embarrass some parties to the Protective Order. Indeed, by the very
terms of the Protective Order, the confidential materials appear to be of the category for which
"[a]voiding embarrassment
is not by itself a valid reason for courts to uphold confidentiality
as against a legitimate law enforcement need for the information." Id.; see also Prot. Order at 2
(designating as "confidential" information "whose public release would violate common law and
statutory privacy interests"). "Aside from those restrictions [laid down by the Fourth or Fifth
Amendment or applicable statutes], hiding possible criminal violations from law enforcement
authorities is hardly a ground for judicial protection of confidentiality." Chemical Bank, 15 F.R.D.
at 94.
Finally, this is unlike a case in which the contours of the civil litigation are publicly
apparent. Cf. Subpoena Duces Tecum, 945 F.2d at 1223 (noting that a "lengthy report" of the
bankruptcy examination in that case "was made available to the public"). In Subpoena Duces
Tecum, for example, not only was the government apparently unconcerned with the confidentiality
of the grand jury investigation, but the government knew from a lengthy public report precisely
what it might replicate through a grand jury investigation. Id. Not so with respect to the Litigation,
which resulted in no such report, no trial, and limited public filings.
For all of these reasons, and for the reasons set forth in the Application, the Government
respectfully requests that the Court grant the Application.
Respectfully submitted,
GEOFFREY S. BERMAN
United States Attorney
By:
Assistant United States Attorney
Tel.:
Enclosure
SDNY_GM_00000924
CONFIDENTIAL
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=== Page 1 ===
From:
To:
Subject: Fwd: Ghislaine Maxwell custody
Date: Thu, 02 Jul 2020 19:46:44 +0000
FYI
Sent from my iPhone
Begin forwarded message:
From:
Date: July 2, 2020 at 3:43:43 PM EDT
To: "NHD-SUPERVISORS (USMS)" <USMS-NHD-SUPERVISORS@usms.doj.gov>
Cc:
Subject: Ghislaine Maxwell custody
To all:
Below are the restrictions we have put in place regarding Ms. Maxwell during her stay at Merrimack DOC. I. If you have
any questions please feel free to call or email me.
Due to the high profile status of this case Inmate Maxwell will be closely monitored. The following directives
apply and shall not be deviated from without express permission from
myself or
1.
Inmate Maxwell will be housed in M1
2.
SRT personnel will be posted in medical and will only be relieved only by SRT personnel
3.
Staff will not converse with the inmate outside of the standard communication required related to the
inmate's health and safety
4.
Inmate Maxwell will remain on a 15 minute observation watch
5.
All rounds, and touch probe rounds will be conducted and documented in XJail
6.
Third Shift Supervisors will download the touch probe rounds and camera footage from the previous day
at 0000 hours each day. The video from the medical cell DVR will be downloaded onto a USB drive and will
be tracked via the designated tracking form provided. Supervisors are directed to deliver this documentation
and video to
Monday July 6th
7.
Inmate Maxwell will be authorized to communicate with her legal counsel, Lawrence Vogelman. This
contact is only authorized after Atty Vogelman provides the appropriate PIN
8.
Any and all requests from Inmate Maxwell are to be directed to
only
EFTA00010360

=== Page 2 ===
At no time are staff authorized to make statements to the press regarding this matter or our SOP regarding this
inmate.
Supervisory Deputy United States Marshal
District of New Hampshire
Concord, New Hampshire
office
This e-mail is property of U.S. Marshals Service. It is intended only for the person or entity to which it is addressed and
may contain information that is privileged, confidential, or otherwise protected from disclosure. Distribution or copying
of this e-mail or the information contained herein by anyone other than the intended recipient is prohibited. If you have
received this e-mail in error, please notify me immediately and destroy all electronic and paper copies of this e-mail.
EFTA00010361


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CONFIDENTIAL PLEA NEGOTIATIONS
TERMS OF EPSTEIN NON-PROSECUTION AGREEMENT
Epstein pleads guilty (not nolo contendere) to an Information filed by the Palm Beach County
State Attorney's Office charging him with:
(a) lewd and lascivious battery on a child, in violation of Fl. Stat. 800.04(4);
(b) solicitation of minors to engage in prostitution, in violation of Fl. Stat. 796.03; and
(c) engaging in sexual activity with minors at least sixteen years of age, in violation of Fl.
Stat. 794.05.
Epstein and the State Attorney's Office make a joint, binding recommendation that Epstein
serve at least two years in prison, without any opportunity for withholding adjudication or
sentencing; and without probation or community control in lieu of imprisonment.
Epstein agrees to waive all challenges to the information filed by the State and the right to
appeal.
Epstein agrees that, if any of the victims identified in the federal investigation file suit pursuant
to 18 U.S.C. $ 2255, Epstein will not contest the jurisdiction of the U.S. District Court for the
Southern District of Florida over his person and the subject matter. Epstein will not contest that
the identified victims are persons who, while minors, were victims of violations of Title 18,
United States Code, Sections(s) 2422 and/or 2423.
After Epstein enters his state court plea and is sentenced, the FBI and the U.S. Attorney's Office
will close their investigations.
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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-58 United States of America V. Maxwell "Certificate of Service FILED"
Date: Thu, 15 Apr 2021 22:20:15 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 04/15/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Document(s): Document(s)
Docket Text:
CERTIFICATE OF SERVICE, for Notice of Motion to Withdraw As Appellate Counsel and Affirmation of
Christian R. Everdell In Support Of Motion To Be Relieved As Counsel, on behalf of Appellant Ghislaine
Maxwell in 21-58, 21-770, FILED. Service date 04/15/2021 by CM/ECF.[3079010] [21-58, 21-770]
Notice will be electronically mailed to:
Assistant U.S. Attorney:
managingclerksoffice@cohengresser.com, autodocket@cohengresser.com
Assistant U.S. Attorney:
@usdoj.gov
Assistant U.S. Attorney:
Tammy Torres, Deputy Clerk: Tammy_Torres@ca2.uscourts.gov
Notice will be stored in the notice cart for:
Tammy Torres, Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Certificate of Service FILED
Original Filename: Certificate of Service_Affirmation in Support of Motion to Be Relieved As Appellate
Counsel.pdf
Electronic Document Stamp:
EFTA00009832

=== Page 2 ===
[STAMP acecfStamp ID=1161632333 [Date=04/15/2021] [FileNumber=3079010-0]
315af86c26651c73e495afdfdd1141511b]]
EFTA00009833


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=== Page 1 ===
Case 1:19-cr-00830-AT Document 56 Filed
5
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 5/25/2021
SOUTHERN DISTRICT OF NEW YORK
United States of America
Deferred Prosecution Agreement
V.
19 Cr. 830 (AT)
Michael Thomas,
Defendant.
TO:
MICHAEL THOMAS
On November 19, 2019, a grand jury sitting in this District returned a six-count indictment
(the "Indictment"), which charged Michael Thomas ("you") with committing offenses against the
United States, to wit, conspiring to knowingly defraud the United States and to knowingly make
and use a false writing or document, in violation of 18 U.S.C. § 371, and three counts of knowingly
making and using a false writing or document, in violation of 18 U.S.C. § 1001. However, after a
thorough investigation, and based on the facts of this case and your personal circumstances, the
U.S. Attorney's Office for the Southern District of New York ("USAO-SDNY") has determined
that the interests of justice will best be served by deferring prosecution in this District. Upon your
acceptance of responsibility for your behavior and by your signature on this deferred prosecution
agreement (the "Agreement"), prosecution will be deferred during the term of your behavior and
satisfactory compliance with the terms of this Agreement for the period of six months from the
date of this Agreement.
The terms and conditions constituting your good behavior and satisfactory compliance are
as follows:
(1)
You shall refrain from violating any federal, state, or local law. You shall immediately
contact your U.S. Pretrial Services Officer if arrested or questioned by a law-
enforcement officer.
(2)
You shall associate only with law-abiding persons.
(3)
You shall work regularly at a lawful occupation, regularly attend school, and/or support
or care for your legal dependents, if any, to the best of your ability, as approved by your
U.S. Pretrial Services Officer. You shall notify your supervising U.S. Pretrial Services
Officer prior to any work or school changes.
(4)
You shall not leave the contiguous United States without permission of your
supervising U.S. Pretrial Services Officer. In accordance with this condition, the U.S.
Pretrial Services Office shall return your passport upon the Court's entering this
Agreement, and shall do so indefinitely unless this Agreement is violated.
- 1
EFTA00009786

=== Page 2 ===
Case 1:19-cr-00830-AT Document 56 Filed 05/25/21 Page 2 of 5
(5)
You shall notify your supervising U.S. Pretrial Services Officer immediately of any
change in your place of residence.
(6)
You shall follow your supervising U.S. Pretrial Services Officer's instructions and
advice.
(7)
You shall report to your supervising U.S. Pretrial Services Officer as directed.
As a further condition you hereby consent to disclosure, by any federal, state, or local
government agency, or by any medical or substance abuse treatment provider, to the U.S. Pretrial
Services Officer supervising your case, of such medical and treatment records as may be requested
by the Pretrial Services Officer to evaluate deferral of prosecution in this case. You further agree
that you will execute any additional consent forms that any such agency or provider may require
to release such information.
Special conditions are as follows:
You shall truthfully and completely disclose all information with respect to the activities
of yourself and others related to your employment by the Bureau of Prisons ("BOP"), which
information can be used for any purpose. You shall agree to meet with and be interviewed by the
USAO-SDNY, the Federal Bureau of Investigation, the Department of Justice, Office of the
Inspector General ("DOJ-OIG"), and any other law enforcement agency designated by this Office.
You shall complete 100 documented hours of community service, preferably related to the
criminal justice system, including working with recently released inmates. The specific type of
community service to be performed must be approved by your Pretrial Services Officer.
The USAO-SDNY may at any time revoke or modify any condition of this provisional
release or change the period of such supervision, which shall in no case exceed six months. The
USAO-SDNY may discharge you from supervision at any time. The USAO-SDNY may at any
time proceed with the prosecution for this offense should the USAO-SDNY, in its sole discretion,
deem such action advisable.
If upon completion of your supervision a written report from your supervising U.S. Pretrial
Services Officer is received to the effect that you have complied with all the rules, regulations and
conditions and special conditions applicable to your deferred prosecution, no further prosecution
will be instituted in this District for the above offenses.
Nothing in this Agreement shall be interpreted to preclude the BOP or the DOJ-OIG from
taking any administrative action against you, including suspension or termination of employment,
based on the facts alleged in the Indictment, the facts identified in the course of the investigation
that led to the Indictment, or your own statements to the DOJ-OIG or any other law enforcement
entity. Nothing in this Agreement shall be interpreted to require the BOP or the DOJ-OIG to delay
- 2
EFTA00009787

=== Page 3 ===
Case 1:19-cr-00830-AT Document 56 Filed 05/25/21 Page 3 of 5
any administrative action until after the expiration of the period of deferment contemplated by this
Agreement. You agree that a copy of this Agreement, including your admission and acceptance
of responsibility, shall be provided to the BOP.
*
*
*
If you successfully complete the term of supervision and fulfills all the terms and
conditions of this Agreement, the Government will move the Court to dismiss the Indictment as to
the defendant.
It is further understood that this Agreement and the terms and conditions set forth herein
are limited to the facts and circumstances of this case and lack precedential value.
Dated: New York, New York
May 20, 2021
AUDREY STRUASS
United States Attorney for the
Southern District of New York
By: Jusica Lonergan
Nicolas Roos
Jessica Lonergan
Assistant United States Attorneys
Tel.: 212-637-2421 / 1038
- 3 - -
EFTA00009788

=== Page 4 ===
Case 1:19-cr-00830-AT Document 56 Filed 05/25/21 Page 4 of 5
The undersigned hereby consents to the foregoing. The undersigned hereby further admits
that he willfully and knowingly completed materially false count and round slips regarding
required counts and rounds in the Special Housing Unit of the Metropolitan Correctional Center
("MCC") on August 9, 2019 and August 10, 2019. The undersigned expressly waives any and all
rights to a speedy trial pursuant to the Sixth Amendment to the United States Constitution, the
Speedy Trial Act, §§ 3161 et seq., and any other pertinent provisions, and consents to the
adjournment of all pending proceedings in this case. The undersigned further waives the
applicable statute of limitations with respect to any prosecution that is not time-barred on the date
that this agreement is signed. It is the intent of this provision to toll the applicable statute of
limitations during the pendency of the deferred prosecution.
The undersigned understands that pursuant to Title 18, United States Code, Section
3161(h)(2), this Agreement is subject to approval by the Court. Should the Court refuse to
approve, and thereby reject, this Agreement, neither party shall be bound to any term of this
Agreement, and no admissions in this Agreement may be used against the undersigned.
Finally, the undersigned acknowledges that he has read this Agreement and has carefully
reviewed each provision with his attorney. The undersigned and his attorney acknowledge that no
threats, promises, or representations have been made, nor agreements reached, other than those set
forth in this Agreement. The undersigned further acknowledges that he understands and
voluntarily accepts each and every term and condition of this Agreement.
Dated: New York, New York
May 20 , 2021
Montell Figgins
Montell Figgins (May 20, 2021 15:49 EDT)
Michael MithaP Hhene Thomas (May 20, 2021 16:04 EDT)
Montell Figgins, Esq.
Michael Thomas
Attorney for Defendant
Defendant
- 4
EFTA00009789

=== Page 5 ===
Case 1:19-cr-00830-AT Document 56 Filed 05/25/21 Page 5 of 5
Pursuant to 18 U.S.C. §3161(h)(2), exclusion under the Speedy Trial Act of the period of
time during which the prosecution of the defendant is deferred pursuant to this Agreement is
hereby approved.
Dated: New York, New York
May 25, 2021
Honorable Analisa Torres
United States District Judge
The undersigned hereby consents to the foregoing and will accept supervision of the
above-named defendant on the conditions set forth herein.
Dated: New York, New York
May , 2021
Francesca
Digitally signed by
Francesca Piperato
Piperato
Date: 2021.05.24 10:32:36
-04'00'
United States Pretrial Services Officer
- 5 -
EFTA00009790


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=== Page 1 ===
DRAFT
On Friday 10/8/2021 Det
was present with Sgt
at the Town of Palm Beach
Police Department. Sgt
is currently assigned to and supervises the Palm Beach Police
Department's Organized Crime, Vice & Narcotics Unit (Special Investigations).
Sgt
brings Det
to the Town of Palm Beach's storage warehouse. Inside of this warehouse
was a locked storage room specifically designated for the use of members of Special Investigations at
Palm Beach Police Department. Sgt
advises that he, other members of Special Investigations
and the records clerk would have access to this locked room.
Inside of this storage room is where Special Investigations stores old or closed case files. These case files
are held inside of bankers boxes which marked on the outside with either the case name or number.
Sgt
then shows and turns over to Det
two bankers boxes specifically marked "Epstein".
Each box contained various EPSTEIN related case materials (paperwork and physical media). Sgt
shows Det
the remainder of this storage room and no other boxes were observed to be
associated with this investigation.
Det
is brought back to Palm Beach Police Department's Special Investigations office. Sgt
shows Det
another location inside of this office where physical case files are maintained and
stored. No materials related to this investigation were observed in this location. Sgt
advises
that these would be the only locations that Palm Beach Police Department would maintain old physical
case files.
Sgt
then shows Det
their digital case management system. Sgt
searches for
materials related to this investigation. Sgt
prints out multiple reports and digital notes he finds
in their case management system and turns them over to Det
Det
provides Sgt
a subpoena for all the materials provided. Sgt
proved Det
a property receipt for the materials.
DRAFT
EFTA00013429


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=== Page 1 ===
From:
(FBI)"
To:
(USAFLS)"
Subject: Re: Looks like I have permission to send a letter to Epstein's people
Date: Fri, 21 Nov 2008 16:54:44 +0000
Importance: Normal
I'll be there in about a half hour.
From:
(USAFLS)
To:
.
Sent: Fri Nov 21 11:29:22 2008
Subject: Looks like I have permission to send a letter to Epstein's people
Can you drop that file by asap? If the judge did, in fact, change the language of the judgment, I need to know
that.
Thanks.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fa
EFTA00014043


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Voucher for Trip 10643456-2 is late
Date: Tue, 01 Oct 2019 13:57:55 +0000
I believe you have all the relevant materials from me for this but please let me know if not. Thanks!
Sent from my iPhone
>
On Oct 1, 2019, at 00:03, "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com> wrote:
>
> Dear
>
>
Your travel voucher for the trip below is now late based on your customer settings. Please submit your voucher
for this trip and mark it as Final if you have no additional expenses to claim.
>
> Trip ID: 10643456-2
> Traveler name
> Destination: Santa Monica
> Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews
> Trip Dates: 2019-09-17 - 2019-09-20
> Current status: Authorization Approved
>
> E2 Single Sign On Login (within DOJ Network Only):
>
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
V
> E2 Manual Login (User ID and Password):
> https://e2.gov.cwtsatotravel.com
>
>
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
>
V
Please note: Replies to this mailbox are not monitored.
V
> Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change
your email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
>
> Reference ID# V0013
> This e-mail and any attachments may contain confidential and/or proprietary information. If you received this
e-mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00010816


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=== Page 1 ===
From:
(USANYS)
To:
(USANYS)"
(USANYS)"
Subject: RE: Unit Updates
Date: Tue, 02 Jul 2019 13:57:52 +0000
Importance: Normal
Attachments:PC_Unit__Short_Form_Update.7.2.19.docx
With apologies for the delay, please see attached. Thanks,
From
(USANYS)
Sent: Tuesday, July 2, 2019 8:36 AM
To:
(USANYS)
USANYS)
Subject: Unit Updates
Importance: High
Good Morning
Just a reminder that unit updates are due. If you plan on
submitting updates, I need them this morning.
Thanks,
EFTA00010464


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=== Page 1 ===
U.S. Department of Justice
ENT
United States Attorney
Southern District of Florida
500 South Australian Ave., Suite 400
West Palm Beach, FL 33401
(561) 820-8711
Facsimile: (561) 820-8777
July 17, 2008
VIA FACSIMILE
Michael R. Tein, Esq.
Lewis Tein, P.L.
3059 Grand Avenue, Suite 340
Coconut Grove, FL 33133
Re:
Jeffrey Epstein
Dear Mr. Tein:
The Office has reviewed your "Notice of Continued Pendency of Federal Criminal
Action," and we feel that it misrepresents the posture of the federal investigation. For
example, you cite to In re Grand Jury, No. FGJ 07-103 (WPB), as evidence that the federal
criminal action remains pending. That is a citation to Mr. Epstein's Motion to Quash a
subpoena for computer equipment removed from Mr. Epstein's home after he and his
attorneys were aware of the existence of the state investigation. Pursuant to the Non-
Prosecution Agreement, that motion was supposed to have been withdrawn several months
ago, and, therefore, is not "pending" in our estimation.
The Non-Prosecution Agreement calls for deferment of federal prosecution "in favor
of prosecution by the State of Florida, provided that Epstein abides by the [enumerated]
conditions and the requirements of th[e] Agreement (Non-Prosecution Agreement, p.
2 (emphasis added).) One of those conditions is Epstein's agreement that the subject Jane
Does, while minors, were victims of a violation of an offense enumerated in Title 18, United
States Code Section 2255, and that they "will have the same rights to proceed under Section
2255 as [they] would have had if Mr. Epstein had been tried and convicted of an enumerated
offense." (United States Attorney's December 19, 2007 letter to Lilly Ann Sanchez.)
If, in fact, your position is that the federal criminal action is still pending such that the
Court must stay the civil proceedings, then the Office proposes that we seek the prompt
resolution of the Motion to Quash, so that the computer equipment can be analyzed and the
EFTA00013666

=== Page 2 ===
MICHAEL TEIN, EsQ.
JULY 17, 2008
PAGE 2
federal investigation can continue. If, instead, Mr. Epstein intends to fully abide by the Non-
Prosecution Agreement, then the "federal Grand Jury investigation will remain suspended,
and all pending federal Grand Jury subpoenas will be held in abeyance unless and until
[Epstein] violates any term of [the Non-Prosecution Agreement]." (Non-Prosecution
Agreement, page 5.)
Please advise whether you intend to correct the representations to the Court regarding
the status of the federal investigation.
Sincerely,
R. Alexander Acosta
United States Attorney
By:
Assistant United States Attorney
cc:
Jack Goldberger, Esq.
, Esq.
EFTA00013667

=== Page 3 ===
U.S. Department of Justice
ENT
United States Attorney
Southern District of Florida
500 S. Australian Ave, 4th Floor
West Palm Beach, Florida 33401
(561) 820-8711
Facsimile (561) 820-8777
FACSIMILE COVER SHEET
TO:
Michael R. Tein
FAX NO.
305-442-6744
PHONE NO.
TO:
Jack Alan Goldberger
FAX NO.
561-835-8691
PHONE NO.
DATE:
July 17, 2008
# OF PAGES:
3
RE:
Jeffrey Epstein
FROM:
Assistant U.S. Attorney
PHONE NO.
COMMENTS:
EFTA00013668

=== Page 4 ===
07/17/08 18:17 FAX 15616594526
USAO WEST PALM
4
001
*** TX REPORT ***
TRANSMISSION OK
TX/RX NO
3957
CONNECTION TEL
8358691
SUBADDRESS
CONNECTION ID
ST. TIME
07/17 18:16
USAGE T
00'42
PGS. SENT
3
RESULT
OK
U.S. Department of Justice
BHT OF WITH
United States Attorney
Southern District of Florida
500 S. Australian Ave, 4th Floor
West Palm Beach, Florida 33401
(561) 820-8711
Facsimile (561) 820-8777
FACSIMILE COVER SHEET
TO:
Michael R. Tein
FAX NO.
305-442-6744
PHONE NO.
TO:
Jack Alan Goldberger
FAX NO. 561-835-8691
PHONE NO.
DATE:
July 17, 2008
# OF PAGES: 3
RE:
Jeffrey Epstein
FROM:
1 Assistant U.S. Attorney
PHONE NO.
EFTA00013669

=== Page 5 ===
07/17/08 18:18 FAX 15616594526
USAO WEST PALM
0
001
*** TX REPORT ***
TRANSMISSION OK
TX/RX NO
3958
CONNECTION TEL
13054426744
SUBADDRESS
CONNECTION ID
ST. TIME
07/17 18:17
USAGE T
01'04
PGS. SENT
3
RESULT
OK
U.S. Department of Justice
ENT OF
United States Attorney
Southern District of Florida
500 S. Australian Ave, 4th Floor
West Palm Beach, Florida 33401
(561) 820-8711
Facsimile (561) 820-8777
FACSIMILE COVER SHEET
TO:
Michael R. Tein
FAX NO.
305-442-6744
PHONE NO.
TO:
Jack Alan Goldberger
FAX NO. 561-835-8691
PHONE NO.
DATE:
July 17,2008
# OF PAGES: 3
RE:
Jeffrey Epstein
FROM:
Assistant U.S. Attorney
PHONE NO.
EFTA00013670


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 13, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
The Government writes to notify you that it will take the position that the defendant has
waived any defense pursuant to Rule 12.2.
Rule 12.2 provides that, before a defendant asserts an insanity defense or introduces expert
evidence "relating to a mental disease or defect or any other mental condition of the defendant
bearing on
the issue of guilt," the defendant must provide the Government written notice
"within the time provided for filing a pretrial motion, or at any later time the court sets." Fed. R.
Crim. P. 12.2(a)-(b).
The defendant's pretrial motions were due on January 25, 2021 (Dkt. No. 108), and her
supplemental pretrial motions were due on May 7, 2021 (Dkt. No. 250 at 1). Accordingly, the
notice period required by Rule 12.2 expired at least five months ago. The Government has not
received any such notice. Although the Court has set a deadline of four weeks before trial for
defense expert witness disclosures (id. at 2), that is not a deadline for Rule 12.2 notice, and in any
event, that deadline would likely provide insufficient time for the Government to assess the
defendant's notice, move for an examination of the defendant pursuant to Rule 12.2(c)(1)(B),
retain an expert, and conduct the examination.
EFTA00011133

=== Page 2 ===
Page 2
If the defendant intends to offer evidence covered by Rule 12.2 at trial notwithstanding the
above, the Government demands notice no later than October 20, 2021, so that the Government
may raise the matter with the Court in a timely fashion before trial.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
By: s/
Assistant United States Attorneys
Southern District of New York
EFTA00011134


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=== Page 1 ===
From:
To:
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: RE: Maxwell Letter
Date: Fri, 30 Oct 2020 21:18:23 +0000
Embedded: RE:_Maxwell_Letter.msg
Sender:
Subject: RE: Maxwell Letter
Message-Id:
<SN5P110MB05425256B41B15EF30DA470992150@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM>
EFTA00013207


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=== Page 1 ===
Event: Deadline to file response in Doe V. Epstein
Start Date: 2009-05-29 13:00:00 +0000
End Date: 2009-05-29 14:00:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2015-04-04 00:21:54 +0000
Date Modified: 2015-07-22 20:34:54 +0000
Priority: 5
EFTA00013484


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=== Page 1 ===
From:
"
(USANYS) [Contractor]"
To:
"
USANYS)"
(USANYS)"
USANYS)"
,
(USANYS)"
Subject: Yesterday's Epstein hearing
Date: Tue, 25 Jun 2019 13:50:28 +0000
Importance: Normal
https://www.miamiherald.com/news/state/florida/article231916968.html
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
EFTA00010540


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=== Page 1 ===
From:
(USANYS)"
To:
(CID) (FBI)"
Cc:
(USANYS)"
Subject: Re:
Date: Fri, 08 May 2020 19:21:04 +0000
Great, thanks. And likewise. Have a good weekend.
Sent from my iPhone
On May 8, 2020, at 1:41 PM,
(CID) (FBI)
wrote:
Guys,
My desk number is
look forward to speaking with you.
From:
(USANYS) [mailto:
Sent: Thursday, May 07, 2020 6:21 PM
To:
(CID) (FBI)
Cc:
(USANYS)
Subject: RE:
That works for us. Let us know were/how best to reach you. Thanks
From:
(CID) (FBI)
Sent: Thursday, May 7, 2020 5:12 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE:
How about Monday 11am?
-
On May 7, 2020 17:10,
(USANYS)"
wrote:
Great. We're still working remotely, but perhaps we could set up a call for early next week? Would Monday or Tuesday
work for you?
From:
(CID) (FBI)
Sent: Thursday, May 7, 2020 5:09 PM
To: Ponder,
J. (NY) (FBI)
is
(USANYS)
Cc:
(USANYS)
Subject: RE:
Let me know what works for you and
,
I am back from DC and am available to meet anytime.
EFTA00013455

=== Page 2 ===
On May 7, 2020 17:06,
(USANYS)"
wrote:
Thanks very much,
And thanks for the virtual introduction.
welcome and very much look forward to
working with you. Once you're settled,
and I would love to set up a time to talk through this and some of the
other cases we have going with your squads.
And thanks very much for everything over the past few months,
Really appreciate it. I have no doubt we will
continue to talk regularly about MCC and our other cases together.
Best,
From: Ponder,
J. (NY) (FBI)
Sent: Thursday, May 7, 2020 10:53 AM
To:
(USANYS)
Cc:
(CID) (FBI)
is
(USANYS)
Subject:
Thank you for the call and the update on the Epstein investigation with regard to charging Ghislaine Maxwell.
As I mentioned,
(copied) has been chosen as the permanent ASAC for the NYO's Violent Crime/Gang Branch
of the Criminal Division.
will be coordinating with you,
and the rest of the team as we move forward.
To rehash some of the points regarding Maxwell to get
up to speed with the latest:
SDNY is close to a final decision on charging Maxwell regarding her complicity in Epstein's sex trafficking
FBI believes (as of January) that Maxwell is still living with a friend in the Boston suburb of Manchester by the Sea
Confirmed by historical pen register with cell site location and subpoenas to Amazon for delivery location
Since traditional surveillance, including a pole camera, are not suitable due to the secluded location, and in order to get
more recent information, you propose getting a renewed pen register and Amazon subpoena. Additionally, you and the
team may seek to get a mail cover.
It was a pleasure working with you,
,
and the team for the last several months.
Good luck moving forward with the case.
Best regards,
Supervisory Special Agent
FBI New York
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
to
Southern District of Florida
October 9, 2007
VIA ELECTRONIC MAIL
Lilly Ann Sanchez, Esq.
Fowler White Burnett
1395 Brickell Ave Fl 14
Miami Florida 33131-3300
Re:
Jeffrey Epstein
Dear Lilly:
Thank you for your letter to First Assistant
regarding the selection of an attorney to
represent the victims identified in the investigation of Mr. Epstein. While I appreciate your client's
interest in a resolution of the victim's claims without the filing of lawsuits, I do not believe that your
proposal falls within the terms of the Non-Prosecution Agreement signed by your client and the
United States.
I would recommend the following. The U.S. Attorney's Office would ask Judge Davis to
assist in the selection of one or more attorneys to represent the identified victims. If Judge Davis
is willing to perform that limited service pro bono, Mr. Epstein will not need to pay for that service.
The United States would provide Judge Davis with a list of criteria for the selection of the
attorney(s).
The selected attorney(s) would represent the victim(s) on a contingency fee basis, pursuant
to a fee agreement reached between the victim(s) and the attorney(s). If he deems it appropriate,
Judge Davis can propose the terms of that agreement, subject to acceptance by the victim. The
lawyer(s) can interview each potential client to determine how they want to proceed - including
whether she wants to use the attorney selected by Judge Davis or if she wants to choose her own
attorney. Judge Davis can advise the selected attorney(s) of Mr. Epstein's desire to settle the cases
out of court using Judge Davis as the mediator/special master, which the attorneys can report to their
clients. If any one or more of the victims, in consultation with their independent counsel, wants to
mediate the case, and agrees that Judge Davis should serve as the mediator/special master, they can
proceed accordingly. At that point, Mr. Epstein's payment of Judge Davis's fees would be more
appropriate.
EFTA00013745

=== Page 2 ===
LILLY ANN SANCHEZ, EsQ.
OCTOBER 9, 2007
PAGE 2
I am out of the District, so I am not available to meet with you this week. I am available for
a telephone conference tomorrow at 5:00 p.m. or Thursday at 5:00 p.m., if you would like to discuss
this in more detail. I also have not heard any more from Jay Lefkowitz or Guy Lewis, so please let
me know whether I need to contact them directly or if you will share this information with them.
Thank you for your assistance.
Sincerely,
R. Alexander Acosta
United States Attorney
By:
cc:
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=== Page 1 ===
Event: Telephone Conference re: Epstein
Start Date: 2008-12-03 19:00:00 +0000
End Date: 2008-12-03 19:30:00 +0000
Organizer:
Location: My office
Class: X-PERSONAL
Date Created: 2015-04-04 00:21:53 +0000
Date Modified: 2015-07-22 20:34:54 +0000
Priority: 5
DTSTAMP: 2008-11-26 19:32:25 +0000
Attendee:
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=== Page 1 ===
From:
To:
Bcc:
Subject: FW: Jeffrey Epstein
Date: Wed, 26 Nov 2008 17:17:46 +0000
Importance: Normal
Hi guys Happy Thanksgiving! Let me know how you would like me to proceed.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
Original Message
From: Roy BLACK [mailto:RBLACK@royblack.com]
Sent: Wednesday November 26 2008 11:56 AM
To:
Cc:
Subject: Re: Jeffrey Epstein
since receipt of your letter I have looked into the situation and
the following is what is happening:
Mr. Epstein has not breached the Non-Prosecution Agreement
(the "Agreement") by serving a portion of his 18-month
sentence of imprisonment in the Palm Beach County Work
Release Program.
1. He is currently serving his sentence in the Palm
Beach County Work Release Program, not in the
State-Regulated Community Control Program. Thus he is not on community
control.
0 The County Jail sentence he is presently serving is
being served under the auspices of the Palm Beach
County Sheriff's Office.
0 The Palm Beach County Sheriff's Office has a policy
of allowing work release under certain criteria for
those sentenced to the Palm Beach County Detention
Center or Stockade. It has already been determined
that Mr. Epstein qualifies under the Palm Beach County Sheriff's
Office policy for work release. The Florida statute
authorizing work release for someone imprisoned in
county jail is at 951.24 (2)(a).
o The statute provides that when punishment by
imprisonment in the county jail is prescribed, the
sentencing court, in its discretion, may at any time
during the sentence consider granting the privilege to
the prisoner to leave the confines of the jail or
county facility during necessary and reasonable hours,
EFTA00014038

=== Page 2 ===
subject to the rules and regulations prescribed by the
court, to work at paid employment or to conduct his or
her own business or profession. See Fla. Stat. $
951.24(2)(a).
0 In Palm Beach County, the Sheriff's Office has
discretion over work release. The local rules state
that placement into House Arrest and Work Release "is
at the discretion of the Sheriff and the presiding
Judge" and offer no defined scope of the type of
offenders that are eligible-or that are barred-from
serving their time in Work Release." See Palm Beach
County Department of Corrections Inmate Rule G-16.
2. The Non Prosecution Agreement does not prohibit
work release.
0 The Agreement does not regulate what programs Mr. Epstein can
participate in while he is serving the County Jail
sentence.
3. The Agreement expressly provides that he is to be
afforded the same benefits that any other inmate might
receive. See 1 12 of the Agreement.
5. Under Florida Law, work release is considered part
of the confinement. See Rule 33-601.602, Fla. Admin.
Code. (work release "allows inmates to work at paid
employment in the community while continuing as inmates
of the facility where they are confined.") So he is an inmate.
6.
recognized that Mr. Epstein
might serve a portion of his sentence through the Work
Release Program.
O. On December 6, 2007, after the Agreement had been
executed, counsel received a draft notification
letter in which US Attorney
expresses this
intention. The draft document provides that the
recipient is "entitled to notification when Mr. Epstein
is released from imprisonment at the end of his prison
term and/or if he is allowed to participate in a work
release program." See December 6, 2007 letter to J.
Lefkowitz from
attaching draft notification
letter, p. 8.
7. I am told that on July 3, 2008, you wrote an email
to the Deputy Sherriff stating that the US Attorney's
Office had no objection to work release as long as
Epstein is treated as any similarly situated inmate. If anything
he is being treated more harshly than any other inmate in
the program. He can't leave the office. He has a guard
and is wearing a GPS device. So his terms are not more lenientbut rather
more restrictive than any other
inmate in the program.
Clearly we do not feel this is a violation of the agreement and we have
no intent to violate it. We will meet with you and anyone in the
executive office to resolve this matter. Certainly it would be best for
us to meet and discuss.
EFTA00014039

=== Page 3 ===
11/24/08 12:28 PM
Dear Roy:
Please review
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
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=== Page 1 ===
From:
To: "Stoddart, Allison" <Allison.Stoddart@wilmerhale.com>
Subject: Accepted: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Date: Fri, 19 Nov 2021 17:32:29 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Subject: unsealing order and related materials
Date: Tue, 09 Apr 2019 23:14:57 +0000
Importance: Normal
Attachments: 2019-04-09, JE, unsealing, 17_Civ_7433.pdf; 2019-
04-09,_JE,_unsealing_order_(can_be_shared_with_BSF).pdf;,2019-04-
09,_JE,_unsealing_conference_before_Judge_McMahon,_transcript.pdf; 2019-04-
9,_JE,_letter_providing_additional_authority_17_Civ_0616_(SN)_(with_exhibit)pdf
Long day today with all this, but ultimately very productive. To the extent any of this is of interest, attached are Judge
McMahon's memorandum and order; the separate (shareable) unsealing order; and the very brief transcript of my
conference with her earlier today. Also attached is the letter providing additional authority submitted this evening to
Judge Netburn in connection with our similar application in her case.
thanks,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Update
Date: Thu, 09 Sep 2021 20:48:39 +0000
Attachments: Public_Corruption_Unit_August_2021.docx
Southern District of New York
EFTA00011529


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=== Page 1 ===
IN RE:
INVESTIGATION OF
JEFFREY EPSTEIN
/
NON-PROSECUTION AGREEMENT
IT APPEARING that the City of Palm Beach Police Department and the State Attorney's
Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's
Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein");
IT APPEARING that the State Attorney's Office has charged Epstein with three counts of
solicitation of prostitution, in violation of Florida Statutes Section 796.07;
IT APPEARING that the United States Attorney's Office and the Federal Bureau of
Investigation have conducted their own investigation of the offenses and Epstein's background;
IT APPEARING that Jeffrey Epstein (hereinafter "Epstein") has committed offenses against
the United States from in or around 2001 through in or around October 2005, including:
(1)
knowingly and willfully conspiring with others known and unknown to commit an
offense against the United States, that is, to use a facility or means of interstate or
foreign commerce to knowingly persuade, induce, or entice minor females to engage
in prostitution, in violation of Title 18, United States Code, Section 2422(b); all in
violation of Title 18, United States Code, Section 371;
(2)
knowingly and willfully conspiring with others known and unknown to travel in
interstate commerce for the purpose of engaging in illicit sexual conduct, as defined
in 18 U.S.C. $ 2423(f), with minor females, in violation of Title 18, United States
Code, Section 2423(b); all in violation of Title 18, United States Code, Section
2423(e);
(3)
using a facility or means of interstate or foreign commerce to knowingly persuade,
induce, or entice minor females to engage in prostitution; in violation of Title 18,
United States Code, Sections 2422(b) and 2;
(4)
traveling in interstate commerce for the purpose of engaging in illicit sexual conduct,
as defined in 18 U.S.C. $ 2423(f), with minor females; in violation of Title 18,
United States Code, Section 2423(b); and
(5)
knowingly, in and affecting interstate and foreign commerce, recruiting, enticing,
and obtaining by any means a person, knowing that the person had not attained the
Page 1 of 4
EFTA00013739

=== Page 2 ===
age of 18 years and would be caused to engage in a commercial sex act as defined
in 18 U.S.C. $ 1591(c)(1); in violation of Title 18, United States Code, Sections
1591(a)(1) and 2; and
IT APPEARING that Epstein has accepted responsibility for his behavior by his signature
on this Agreement; and
IT APPEARING, after an investigation of the offenses and Epstein's background, that the
interest of the United States pursuant to the Petite policy will be served by the following procedure;
THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the
Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor
of prosecution by the State of Florida, provided that Epstein abides by the following conditions and
the requirements of this Agreement set forth below.
Should Epstein violate any of the conditions of this Agreement, the United States Attorney
may at any time initiate prosecution against Epstein for any offense. In this case, the United States
Attorney will furnish Epstein with notice specifying the condition(s) of the Agreement that he has
violated.
After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the
offenses set out on pages 1 and 2 of this Agreement will be instituted in this District, and the charges
against Epstein if any, will be dismissed.
Terms of the Agreement:
1.
Epstein shall plead guilty (not nolo contendere) to an Information filed by the
State Attorney's Office charging violations of the following Florida Statutes:
(a)
lewd and lascivious battery on a child, in violation of Fl. Stat.
800.04(4);
(b)
solicitation of minors to engage in prostitution, in violation of Fl.
Stat. 796.03; and
(c)
engaging in sexual activity with minors at least sixteen years of age,
in violation of Fl. Stat. 794.05.
2.
Epstein and the State Attorney's Office shall make a joint, binding
recommendation that the Court impose a thirty (30) month sentence to be
divided as follows:
(a)
Epstein shall begin by serving at least twenty (20) months in prison,
without any opportunity for withholding adjudication or sentencing,
Page 2 of 4
EFTA00013740

=== Page 3 ===
and without probation or community control in lieu of imprisonment;
and
(b)
following the term of imprisonment, Epstein shall serve ten (10)
months of community control.
3.
Epstein shall waive all challenges to the Information filed by the State
Attorney's Office and shall waive the right to appeal his conviction and
sentence.
4.
Epstein shall provide to the U.S. Attorney's Office copies of all proposed
agreements with the State Attorney's Office prior to entering into those
agreements.
5.
Epstein agrees that, if any of the victims identified in the federal
investigation file suit pursuant to 18 U.S.C. $ 2255, Epstein will not contest
the jurisdiction of the U.S. District Court for the Southern District of Florida
over his person and/or the subject matter, and Epstein will not contest that the
identified victims are persons who, while minors, were victims of violations
of Title 18, United States Code, Sections(s) 2422 and/or 2423.
6.
The United States shall provide Epstein's attorneys with a list of the
identified victims, which will not exceed forty, after Epstein has signed this
agreement and has been sentenced. The United States shall make a motion
with the United States District Court for the Southern District of Florida for
the appointment of a guardian ad litem for the identified victims and
Epstein's counsel may contact the identified victims through that counsel.
7.
Epstein shall enter his guilty plea and be sentenced not later than September
28, 2007, and shall begin service of his sentence not later than October 15,
2007.
8.
With credit for gain time, Epstein shall serve at least 17 months in a state
correctional institution.
Epstein understands that the United States Attorney has no authority to require the State
Attorney's Office to abide by any terms of this agreement. Epstein understands that it is his
obligation to undertake discussion with the State Attorney's Office to ensure compliance with these
procedures, which compliance will be necessary to satisfy the United States' interest, pursuant to
the Petite policy.
By signing this agreement, Epstein asserts and certifies that each of these terms is material
to this agreement and is supported by independent consideration and that a breach of any one of
these conditions allows the United States to elect to terminate the agreement and to investigate and
Page 3 of 4
EFTA00013741

=== Page 4 ===
prosecute Epstein for any and all federal offenses.
By signing this agreement, Epstein asserts and certifies that he is aware of the fact that the
Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions
the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule
48(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment,
information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an
information, or in bringing a defendant to trial. Epstein hereby requests that the United States
Attorney for the Southern District of Florida defer such prosecution. Epstein agrees and consents
that any delay from the date of this Agreement to the date of initiation of prosecution, as provided
for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and
he hereby waives any defense to such prosecution on the ground that such delay operated to deny
him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment
to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the
running of the statute of limitations for a period of months equal to the period between the signing
of this agreement and the breach of this agreement. Epstein further asserts and certifies that he
understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure
provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby
agrees and consents that, if a prosecution against him is instituted, it may be by way of an
Information signed and filed by the United States Attorney, and hereby waives his right to be
indicted by a grand jury.
By signing this agreement, Epstein asserts and certifies that the above has been read and
explained to him. Epstein hereby states that he understands the conditions of this Non-Prosecution
Agreement and agrees to comply with them.
Dated:
JEFFREY EPSTEIN
Dated:
GERALD LEFCOURT, ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated:
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: OPR Epstein
Date: Fri, 13 Nov 2020 02:29:53 +0000
Attachments: epstein._executive_summary.pdf
Among other things, this explains how OPR evaluates things.
Southern District of New York
Begin forwarded message:
From:
Date: November 12, 2020 at 8:18:53 PM EST
To:
Subject: OPR Epstein
https://www.justice.gov/opa/press-release/file/1336416/download
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=== Page 1 ===
Case 1:19-cr-00830-AT Document 59 Filed 05/25
Page 5
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 5/25/2021
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
United States of America
Deferred Prosecution Agreement
v.
19 Cr. 830 (AT)
Tova Noel,
Defendant.
TO: TOVA NOEL
On November 19, 2019, a grand jury sitting in this District returned a six-count indictment
(the "Indictment"), which charged Tova Noel ("you") with committing offenses against the United
States, to wit, conspiring to knowingly defraud the United States and to knowingly make and use
a false writing or document, in violation of 18 U.S.C. § 371, and five counts of knowingly making
and using a false writing or document, in violation of 18 U.S.C. § 1001. However, after a thorough
investigation, and based on the facts of this case and your personal circumstances, the U.S.
Attorney's Office for the Southern District of New York ("USAO-SDNY") has determined that
the interests of justice will best be served by deferring prosecution in this District. Upon your
acceptance of responsibility for your behavior and by your signature on this deferred prosecution
agreement (the "Agreement"), prosecution will be deferred during the term of your behavior and
satisfactory compliance with the terms of this Agreement for the period of six months from the
date of this Agreement.
The terms and conditions constituting your good behavior and satisfactory compliance are
as follows:
(1)
You shall refrain from violating any federal, state, or local law. You shall immediately
contact your U.S. Pretrial Services Officer if arrested or questioned by a law-
enforcement officer.
(2)
You shall associate only with law-abiding persons.
(3)
You shall work regularly at a lawful occupation, regularly attend school, and/or support
or care for your legal dependents, if any, to the best of your ability, as approved by your
U.S. Pretrial Services Officer. You shall notify your supervising U.S. Pretrial Services
Officer prior to any work or school changes.
(4)
You shall not leave the contiguous United States without permission of your
supervising U.S. Pretrial Services Officer. In accordance with this condition, the U.S.
Pretrial Services Office shall return your passport upon the Court's entering this
Agreement, and shall do so indefinitely unless this Agreement is violated.
= 1 -
EFTA00009781

=== Page 2 ===
Case 1:19-cr-00830-AT Document 59 Filed 05/25/21 Page 2 of 5
(5)
You shall notify your supervising U.S. Pretrial Services Officer immediately of any
change in your place of residence.
(6)
You shall follow your supervising U.S. Pretrial Services Officer's instructions and
advice.
(7)
You shall report to your supervising U.S. Pretrial Services Officer as directed.
As a further condition you hereby consent to disclosure, by any federal, state, or local
government agency, or by any medical or substance abuse treatment provider, to the U.S. Pretrial
Services Officer supervising your case, of such medical and treatment records as may be requested
by the Pretrial Services Officer to evaluate deferral of prosecution in this case. You further agree
that you will execute any additional consent forms that any such agency or provider may require
to release such information.
Special conditions are as follows:
You shall truthfully and completely disclose all information with respect to the activities
of yourself and others related to your employment by the Bureau of Prisons ("BOP"), which
information can be used for any purpose. You shall agree to meet with and be interviewed by the
USAO-SDNY, the Federal Bureau of Investigation, the Department of Justice, Office of the
Inspector General ("DOJ-OIG"), and any other law enforcement agency designated by this Office.
You shall complete 100 documented hours of community service, preferably related to the
criminal justice system, including working with recently released inmates. The specific type of
community service to be performed must be approved by your Pretrial Services Officer.
The USAO-SDNY may at any time revoke or modify any condition of this provisional
release or change the period of such supervision, which shall in no case exceed six months. The
USAO-SDNY may discharge you from supervision at any time. The USAO-SDNY may at any
time proceed with the prosecution for this offense should the USAO-SDNY, in its sole discretion,
deem such action advisable.
If upon completion of your supervision a written report from your supervising U.S. Pretrial
Services Officer is received to the effect that you have complied with all the rules, regulations and
conditions and special conditions applicable to your deferred prosecution, no further prosecution
will be instituted in this District for the above offenses.
Nothing in this Agreement shall be interpreted to preclude the BOP or the DOJ-OIG from
taking any administrative action against you, including suspension or termination of employment,
based on the facts alleged in the Indictment, the facts identified in the course of the investigation
that led to the Indictment, or your own statements to the DOJ-OIG or any other law enforcement
entity. Nothing in this Agreement shall be interpreted to require the BOP or the DOJ-OIG to delay
2 -
EFTA00009782

=== Page 3 ===
Case 1:19-cr-00830-AT Document 59 Filed 05/25/21 Page 3 of 5
any administrative action until after the expiration of the period of deferment contemplated by this
Agreement. You agree that a copy of this Agreement, including your admission and acceptance
of responsibility, shall be provided to the BOP.
*
*
*
If you successfully complete the term of supervision and fulfills all the terms and
conditions of this Agreement, the Government will move the Court to dismiss the Indictment as to
the defendant.
It is further understood that this Agreement and the terms and conditions set forth herein
are limited to the facts and circumstances of this case and lack precedential value.
Dated: New York, New York
May 20, 2021
AUDREY STRUASS
United States Attorney for the
Southern District of New York
By: Jewica Lonergan
Nicolas Roos
Jessica Lonergan
Assistant United States Attorneys
Tel.: 212-637-2421 / 1038
3 -
EFTA00009783

=== Page 4 ===
Case 1:19-cr-00830-AT Document 59 Filed 05/25/21 Page 4 of 5
The undersigned hereby consents to the foregoing. The undersigned hereby further admits
that she willfully and knowingly completed materially false count and round slips regarding
required counts and rounds in the Special Housing Unit of the Metropolitan Correctional Center
("MCC") on August 9, 2019 and August 10, 2019. The undersigned expressly waives any and all
rights to a speedy trial pursuant to the Sixth Amendment to the United States Constitution, the
Speedy Trial Act, §§ 3161 et seq., and any other pertinent provisions, and consents to the
adjournment of all pending proceedings in this case. The undersigned further waives the
applicable statute of limitations with respect to any prosecution that is not time-barred on the date
that this agreement is signed. It is the intent of this provision to toll the applicable statute of
limitations during the pendency of the deferred prosecution.
The undersigned understands that pursuant to Title 18, United States Code, Section
3161(h)(2), this Agreement is subject to approval by the Court. Should the Court refuse to
approve, and thereby reject, this Agreement, neither party shall be bound to any term of this
Agreement, and no admissions in this Agreement may be used against the undersigned.
Finally, the undersigned acknowledges that she has read this Agreement and has carefully
reviewed each provision with her attorney. The undersigned and her attorney acknowledge that
no threats, promises, or representations have been made, nor agreements reached, other than those
set forth in this Agreement. The undersigned further acknowledges that she understands and
voluntarily accepts each and every term and condition of this Agreement.
Dated: New York, New York
May 2021
Attorney J-17 for Defendant
1
9
Jason Foy, Esq.
Tova Noel
Defendant
4 -
EFTA00009784

=== Page 5 ===
Case 1:19-cr-00830-AT Document 59 Filed 05/25/21 Page 5 of 5
Pursuant to 18 U.S.C. $3161(h)(2), exclusion under the Speedy Trial Act of the period of
time during which the prosecution of the defendant is deferred pursuant to this Agreement is
hereby approved.
Dated: New York, New York
May 25, 2021
as
Honorable Analisa Torres
United States District Judge
The undersigned hereby consents to the foregoing and will accept supervision of the
above-named defendant on the conditions set forth herein.
Dated: New York, New York
May 24, 2021
United States Pretrial Services
Officer
- 5- #
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From:
To:
Cc:
Subject: Submitted Report: Case-Related Urgent: Major Development in a Significant Investigation or
Litigation
Date: Thu, 20 May 2021 17:18:08 +0000
Importance: Normal
Reporting District: SOUTHERN DISTRICT OF NEW YORK
Synopsis: Deferred prosecution agreements to two BOP MCC NY Officers, Tova Noel and Michael Thomas.
Description:
SYNOPSIS:
The USAO-SDNY plans to offer deferred prosecution agreements to two correctional officers, Tova Noel and
Michael Thomas, who were employed at the Manhattan Correctional Center ("MCC") and were previously
charged with making false statements and conspiring to (i) make false statements and (ii) interfere with or
obstruct the lawful function of the MCC. These charges, which were brought in November 2019, stem from the
correctional officers' falsification of institutional count and round forms on the night that Jeffrey Epstein
committed suicide. The deferred prosecution agreements will require, among other things, the defendants to
cooperate with a pending Office of Inspector General investigation by providing truthful information about the
events in question; an admission of guilt from both defendants as to the conduct set forth in the indictment;
and for both defendants to complete 100 hours of community service, preferably in an area related to the
criminal justice system. The USAO-SDNY plans to file a public letter by Friday, May 21 notifying the Court of the
defendants' acceptance of the deferred prosecution agreements and seeking a hearing date; the USAO-SDNY
anticipates that the deferred prosecution agreements will be entered by the Court by the following Friday, May
28.
DESCRIPTION:
On November 14, 2019, USAO-SDNY obtained an indictment against Tova Noel and Michael Thomas which
charged them with multiple counts of making false statements, in violation of 18 U.S.C. $ 1001, and conspiring
to (i) make false statements and (ii) interfere with or obstruct the lawful function of the MCC, in violation of 18
U.S.C. $ 371. As alleged in the Indictment, on August 9 and 10, 2019, the defendants falsely indicated on
Bureau of Prison forms that they had completed required institutional counts and rounds. On August 10, 2019,
inmate Jeffrey Epstein committed suicide while housed in the Special Housing Unit at the MCC. After
discovering Epstein's body, the defendants admitted to their supervisor that they had failed to conduct at least
some of the required counts and rounds. The falsification of records occurred prior to their discovery of
Epstein's body.
EFTA00013389

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The USAO-SDNY plans to offer deferred prosecution agreements to both defendants. The USAO-SDNY has
determined that deferring the defendants' prosecution is an outcome consistent with the interests of justice,
the mitigating personal circumstances of the defendants, and the Department's practice in the overwhelming
majority of other cases in which correctional officers have been investigated or charged with falsifying count or
round forms. As a condition of the defendants' agreement, they will be required to admit their guilt and
cooperate by providing truthful information with the Office of Inspector General, which is preparing a report
on, among other things, their conduct on the night in question, the circumstances in which they discovered
Epstein's body after his suicide, and the institutional failures that led to Epstein's death at the MCC The
agreement does not preclude any administrative action or termination by the Bureau of Prisons. The
defendants will also be subject to pretrial supervision for six months, must refrain from committing any crimes,
and will be required to complete 100 hours of community service. This outcome is supported by the
investigative agencies, the Department of Justice, Office of the Inspector General, as well as the Federal Bureau
of Investigation, and has been approved by Pretrial Services. The USAO-SDNY plans to send a public letter by
May 21, 2021 to notify the Court that the Government has offered, and the defendants have accepted, deferred
prosecution agreements, and in order to request a hearing date, which the Government expects to be
scheduled for the following week, by May 28.
Report ID: 2021-05-66021
For Official Use Only (FOUO): The term used within DHS to identify unclassified information of a sensitive
nature, not otherwise categorized by statute or regulation, the unauthorized disclosure of which could adversely
impact a person's privacy or welfare, the conduct of Federal programs, or other programs or operations essential
to the national interest. Information impacting the National Security of the United States and classified
Confidential, Secret, or Top Secret under Executive Order 12958, "Classified National Security Information," as
amended, or its predecessor or successor orders, is not to be considered FOUO. FOUO is not to be considered
classified information. http://www.fas.org/sgp/othergov/dhs-sbu.html
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=== Page 1 ===
From:
To:
Bcc:
Subject: RE: Epstein is out on work release
Date: Thu, 20 Nov 2008 16:59:03 +0000
Importance: Normal
P.S. - The Saturday before his plea and sentencing Goldberger specifically told me that he would not get work
release. So did Roy.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
From:
(USAFLS)
Sent: Thursday, November 20, 2008 11:58 AM
To:
(USAFLS)
Subject: RE: Epstein is out on work release
He is hanging out at his lawyer's office during the day, eating a lovely lunch, and getting driven back to the
campgrounds at night. He is allegedly working for the "Florida Science Foundation" which exists only to
employ Epstein. Its offices are conveniently located 3 buildings down from me at Goldberger's office.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
From:
(USAFLS)
Sent: Thursday, November 20, 2008 11:56 AM
To:
C. (USAFLS)
Subject: RE: Epstein is out on work release
Work release ? What the hell is that ? Where does he sleep at night and what is he doing ?
From:
(USAFLS)
EFTA00014044

=== Page 2 ===
Sent: Thursday, November 20, 2008 11:50 AM
To:
Cc:
Subject: Epstein is out on work release
The Colonel just stopped by to see
and told her that Epstein has been out on work release for the past few
weeks.
Can I indict him now?
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
EFTA00014045


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=== Page 1 ===
From:
To:
(USAFLS)"
Subject: Re: confidential communication
Date: Mon, 19 May 2008 19:36:32 +0000
Importance: Normal
Hi all. We are at sea today with bad reception. Just got your messages. I could try to call you now or tomorrow we will be in
berlin. Sorry
Original Message
From:
(USAFLS)
To:
Sent: Mon May 19 12:40:32 2008
Subject: FW: confidential communication
For your records.
From: Jay Lefkowitz [mailto
Sent: Monday, May 19, 2008 10:54 AM
To:
(USAFLS)
Subject: confidential communication
Dear Alex:
I am writing to you because I have just received the attached letter from
In light of that letter, and given
the critical new evidence discussed below, I would like to request a meeting with you, mindful of our July 8 deadline, at
your earliest opportunity. Given your personal involvement in this matter to date, and the fact that at this juncture it is clear
that CEOS has referred the matter back to you, I respectfully request that you not shunt me off to one of your staff. You
and I have both spent a great deal of time on this matter, and I know that we both would like to resolve this matter in a way
that bestows integrity both on the Department and the process.
In our prior discussions, you expressed that you were "not unsympathetic" to our various federalism concerns, but stated
that because you serve within the "unitary Executive," you believed your hands were tied by Main Justice. You were also
extremely gracious in stating that you did not want the United States to be "unfair". Although CEOS limited its assessment
to the federal statutes your Office had brought forth and to the application of those laws to the facts as presented, it is
abundantly clear from
letter that Main Justice is not directing this prosecution. In fact, CEOS plainly acknowledged
that a federal prosecution of Mr. Epstein would involve a "novel application" of federal statutes and that our arguments
against federal involvement are "compelling." Moreover, the language used by Drew in his concluding paragraph, that he
cannot conclude that a prosecution by you in this case "would be an abuse of discretion" is hardly an endorsement that you
move forward.
Moreover, as you know, Drew made clear that the scope of his review did not extend to the other significant issues we
have raised with you, such as the undo interest by some members of your staff with the financial and civil aspects of this
matter, or with the inappropriate discussion one member of your Office had with a senior reporter at the New York Times.
(In fact, I have met with that reporter and have reviewed copious notes of his conversation with Mr. Weinstein). At this
stage, we have no alternative but to raise our serious concerns regarding the issues Drew refused to address with the
Deputy or, if necessary, the Attorney General, because we believe those issues have significantly impacted the
investigation and any recommendation by your staff to proceed with an indictment. That being said, it would obviously be
much more constructive and efficient if we could resolve this matter directly with you in the advance of further proceedings
in Washington.
Because it is clear that national policy, as determined by Main Justice, is not driving this case, the resolution of this matter
is squarely, and solely, your responsibility. I know you want to do the right thing, and it is because you have made clear to
EFTA00013661

=== Page 2 ===
me on several occasions that you will always look at all of the relevant and material facts that I call the following to your
attention. New information that has come to light strongly suggests that the facts of this case cannot possibly implicate a
federal prosecutorial priority. Due to established state procedures and following the initiation of multiple civil lawsuits, Mr.
Epstein's counsel was able to take limited discovery of certain women in this matter. The sworn statements provided by
these women all confirm that federal prosecution is not appropriate in this case.
The consistent representations of witnesses such as
and the civil complainants and their attorneys, confirm the following key points: First, there was no telephonic
communication that met the requirements of $ 2422(b). For example, as many other witnesses have stated, Ms.
testified in no unclear terms that there was never any discussion over the phone about her coming over to Mr. Epstein's
home to engage in sexual activity: "The only thing that ever occurred on any of these phone calls [with]
or
another assistant] was, 'Are you willing to come over,' or, 'Would you like to come over and give a massage."
Tr. A
at 15. Second, the underage women who visited Mr. Epstein have testified that they lied about their age in order to gain
admittance into his home and women who brought their underage friends to Mr. Epstein counseled them to lie about their
ages as well. Ms.
stated the following: "I would tell my girlfriends just like
approached me. Make sure you
tell him you're 18. Well, these girls that I brought, I know that they were 18 or 19 or 20. And the girls that I didn't know and
I don't know if they were lying or not, I would say make sure that you tell him you're 18."
Tr. at 22. Third, there was
no routine or habit suggesting an intent to transform a massage into an illegal sexual act. For instance, Ms.
stated
that Mr. Epstein "never touched [her] physically" and that all she did was "massage[ his back, his chest and his thighs and
that was it."
Tr. at 12-13. Finally, as you are well aware, there was no force, coercion, fraud, violence, drugs, or
even alcohol present in connection with Mr. Epstein's encounters with these women.
The civil suits confirm that the plaintiffs did not discuss engaging in sexually-related activities with anyone prior to arriving
at Mr. Epstein's residence. This reinforces the fact that no telephonic or Internet persuasion, inducement, enticement or
coercion of any kind occurred. Furthermore, Mr. Herman, the attorney for most of the civil complainants, was quoted in the
Palm Beach Post as saying that "it doesn't matter" that his clients lied about their ages and told Mr. Epstein that they were
18 or 19. In short, the new evidence establishing that the women deliberately lied about their age because they knew Mr.
Epstein did not want anyone under 18 in his house directly undercuts the claim that Mr. Epstein willfully blinded himself as
to their ages. Willful blindness is not a substitute for evidence of knowledge nor is it a negligence standard. It requires
proof beyond reasonable doubt of deliberate intent and specific action to hide one's knowledge. There is absolutely no
such evidence of that here, so it is not even a jury issue. Furthermore, willful ignorance cannot constitute the required
mens rea for a crime of conspiracy or aiding and abetting.
Through the recent witness statements, we have also discovered another serious issue that implicates the integrity of the
federal investigation. We have learned that FBI Special Agent
attempted to convince these adult women, now
in their twenties, that they were in fact "victims" even though the women themselves strongly disagreed with this
characterization. This conduct, once again, goes to the heart of the integrity of the investigation. In a sworn statement,
Ms.
was highly critical of the overreaching by federal law enforcement officers in this case. She testified-in no
uncertain terms-that she does not, and never did, feel like a "victim," despite the fact that the FBI repeatedly tried to
convince her otherwise.
I am mindful of the fact that we have a state court date of July 8 on which either to enter a plea or to commence trial. As I
review the trial options with Mr. Epstein, I certainly want to make sure I do everything within my power to obviate a need for
trial through a reasonable alternative resolution. Although it is clear that CEOS is not directing a prosecution here, and has
stated only that you have the authority to commence such a prosecution, I am well aware that the decision whether to
proceed, subject to any further process in Washington, is now within your discretion. I think the new facts should greatly
influence your decision and accordingly, I hope you will agree to meet with me, both to discuss the new evidence and to
discuss a resolution to this matter once and for all. I am available to meet with you at your earliest convenience subject to
our mutual availability.
Respectfully,
Jay
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
EFTA00013662

=== Page 3 ===
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
EFTA00013663


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=== Page 1 ===
From:
(USANYS)"
To: Nathan NYSD Chambers
Cc:
)"
)"
)"
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Letter from MDC Legal Counsel
Date: Thu, 29 Apr 2021 22:38:12 +0000
Attachments: Ltr_to_Hon_Nathan_04.29.21_-pdf
Good afternoon,
Attached is a letter from MDC legal counsel in response to the Court's April 29, 2021 Order (Dkt. 255). Because the MDC
is not a party to this case, this letter has not been filed on ECF, but the Government has no objection to the public
docketing of this letter.
Respectfully,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St.
Plaza
New York, New York 10007
Tel:
EFTA00013301


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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From:
Date: November 12, 2021
Re:
United States V. Ghislaine Maxwell
Court Docket No: 20 Cr. 330 (AJN)
USAO No: 2018R01618
Witness Name:
Witness DOB:
(Name/DOB as printed here will be forwarded to travel agency and then to TSA and must exactly
match the witness's driver's license or other travel ID or TSA will not permit the witness to fly.)
Witness Address:
Witness TelNos (mobile):
Witness e-mail:
Witness Needed to Appear in SDNY on
Date: December 7, 2021
Time: 9 AM
Witness Needed to Appear for:
Trial (X)
Date: December 8-9, 2021 all day
Grand Jury ( )
Date:
Trial Prep (X)
Date: December 7, 2021 at 9 AM
Estimated Dates Witness will Arrive:
December 6, 2021 (evening)
Depart:
December 9, 2021 (evening)
Is the person a Fact Witness and not an Expert Witness?
(Yes/No):
Yes
Current Federal Civilian or Military Employee?
(Yes/No):
No
Is the Witness Facing Criminal Charges?
(Yes/No):
No
Does the Witness Reside Outside the Continental United States?
(Yes/No):
No
Is this Witness a Victim-Witness?
(Yes/No):
No
Hotel Required?
(Yes/No):
Yes
Has the Witness advised you of any unusual travel expenses?
(Yes/No):
No
Unusual expenses of fact witnesses can include
special travel arrangements
care for dependent child or incapacitated family member left at home
kennel fees for pets
rev. 2019.11.19
EFTA00010214

=== Page 2 ===
necessary travel companion
extra baggage (more than one bag)
Please describe the unusual expense:
For Victim-Witness Coordinator:
1. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW
is apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should
be used.
For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to
court/GJ testimony.
Witnesses may only be brought in under the FEWS appropriation for grand jury testimony that
has been scheduled and where the witness is expected to testify before the grand jury; court
testimony; or preparation for same. Any other witness travel, e.g., for investigative interviews,
must be covered by the investigating component from litigative funds. See Ed Tyrrell.
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
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=== Page 1 ===
From: "Biase, Nicholas (USANYS)"
To:
(USANYS)"
(USANYS)"
"Margolin, James (USANYS) [Contractor]"
,
"Berman, Geoffrey (USANYS)"
Subject: Jeffrey Epstein friend Ghislaine Maxwell under FBI investigation
Date: Fri, 27 Dec 2019 14:36:26 +0000
https://www.cnbc.com/2019/12/27/jeffrey-epstein-friend-ghislaine-maxwel-under-fbi-investigation.html
Sent from my iPhone
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=== Page 1 ===
Event: CEOS Meeting re Epstein Investigation
Start Date: 2009-12-17 18:00:00 +0000
End Date: 2009-12-17 19:30:00 +0000
Organizer:
Location: By Phone - Call-in #
Class: X-PERSONAL
Date Created: 2015-03-27 13:43:35 +0000
Date Modified: 2015-07-22 20:34:48 +0000
Priority: 5
DTSTAMP: 2009-12-14 21:34:04 +0000
Attendee:
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=== Page 1 ===
From:
(FBI)"
To:
(USAFLS)"
Subject: Re: Epstein Agreement
Date: Thu, 03 Jul 2008 16:49:20 +0000
Importance: Normal
Original Message
From:
(USAFLS)
To:
Cc:
(USAFLS);
;
Sent: Thu Jul 03 11:58:51 2008
Subject: Epstein Agreement
Dear Colonel Gauger:
Thank you for taking the time to meet with us on Tuesday. As we discussed, I have attached the pertinent portion of Mr. Epstein's
agreement with the U.S. Attorney's Office.
Epstein Agrmt Portion.pdf>>
I also wanted to call to your attention a couple of items regarding the issue of Work Release. During the change of plea, Mr. Epstein stated
that he would be working at the Florida Science Foundation, located at 250 Australian Avenue, Suite 1400, that the Foundation had been in
existence for a "couple of years," and that he had been working there "every day" prior to the plea. The Division of Corporations'
documents show that the Florida Science Foundation was incorporated in November 2007, not a "couple of years ago." The address
provided for the "office" of the Florida Science Foundation is Jack Goldberger's office suite, and neither the office building directory nor
the office suite door reflects that such a business is located there, and neither the security guard nor any building tenant that FBI questioned
knows of the existence of such a business. Mr. Epstein also could not have been working there "every day" when he hadn't been in Palm
Beach County in the past six months.
I would appreciate the opportunity to review the work release regulations. If Mr. Epstein truly is eligible for the program, we have no
objection to him being treated like any other similarly situated prisoner, but sitting in his attorney's office suite making telephone calls,
web-surfing, and having food delivered to him is probably not in accordance with the objectives of imprisonment. Obviously, the decision
is left entirely within your discretion, but I wanted to make sure that you had a complete picture before you made that decision.
Thank you again, and have a wonderful 4th of July.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
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=== Page 1 ===
From:
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To: "Acosta, Alex (USAFLS)"
Subject: FW: Epstein
Date: Mon, 15 Oct 2007 13:43:29 +0000
Importance: Normal
Attachments: 071015_Special_Master_Letter.wpd
Alex,
Here's
proposed letter to Judge Davis. Let me know what you think.
Sent from my GoodLink synchronized handheld (www.good.com)
Original Message
From:
(USAFLS)
Sent:
Monday, October 15, 2007 09:38 AM Eastern Standard Time
To:
(USAFLS)
Subject:
Epstein
Hi
- I have prepared this as a letter from you to Judge Davis. I am going to call
to see if we have nailed down
the final number of victims so that you can include the information in the letter. You can get me on my cell phone.
Thank you!
<<071015 Special Master Letter.wpd>>
Assistant U.S. Attorney
Fax 561 820-8777
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=== Page 1 ===
From:
"
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To:
Bcc: "V
(USAFLS)"
"
(USAFLS)"
i
(USAFLS)"
(USAFLS)"
Subject: Jeffrey Epstein
Date: Wed, 28 May 2008 20:51:45 +0000
Importance: Normal
Mr. Lefkowitz,
The United States Attorney's Office for the Southern District of Florida was recently
notified that the Office of the Deputy Attorney General, at your request, intends to review
certain aspects of the investigation involving Mr. Epstein's sexual conduct involving minor
victims. Naturally, until the DAG's Office has completed its review, this Office has postponed the
current June 2, 2008 deadline requiring compliance by your client with the terms and
conditions of the September 24, 2007 global resolution of state and federal liabilities, as
modified by the United States Attorney's December 19, 2007 letter to Lilly Ann Sanchez, Esq.
Sincerely,
First Assistant US Attorney
Southern District of Florida
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=== Page 1 ===
From:
"
(USAFLS)"
To: "
(USAFLS)"
Bcc:
"
(USAFLS)"
Subject: Re: Epstein
Date: Tue, 27 May 2008 17:20:27 +0000
Importance: Normal
Please tell me you that you are joking. Maybe we should throw him a party and tell him we are sorry to have bothered him.
Original Message
From:
(USAFLS)
To:
(USAFLS)
Sent: Tue May 27 10:27:10 2008
Subject: Epstein
Don't know what is up but Barry talked to
and according to
said something about 90 days in jail.
is talking to
-he said.
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=== Page 1 ===
CG
COHEN & GRESSER LLP
Christian R. Everdell
September 21, 2020
BY EMAIL
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear
We write to address three issues. First, we write to express once again our dissatisfaction
with the incomplete and inadequate production of discovery to Ms. Maxwell in the MDC, and to
demand that the government find an immediate solution that will permit Ms. Maxwell to review
all of the discovery materials produced to date. Second, we write to request that the government
set up a time at the earliest convenience when Ms. Maxwell and defense counsel can review the
documents marked as "Highly Confidential" in the discovery materials. Third, we write to
register our objection to the onerous conditions of confinement to which Ms. Maxwell is
subjected, which are entirely unique to Ms. Maxwell. We request that the government intercede
directly with the BOP to improve these conditions, as set forth below.
1. Ms. Maxwell Still Cannot Access All of the Discovery
One full month has now passed since August 21, 2020, the date the government
represented to the Court that it would complete production of the initial group of discovery
materials, and Ms. Maxwell still cannot read a substantial portion of the discovery produced to
date. The government further represented to the Court at the initial appearance on July 14, 2020
that this initial group of discovery materials represents "the core of the case" against Ms. Maxwell.
(Tr. at 12, line 11). Ms. Maxwell has therefore been denied full access to the most critical
evidence in this case for a month. This is unacceptable and inconsistent with the government's
obligations and its representations to Judge Nathan; this must be fixed immediately.
The government represented to the Court at the initial appearance that it was "prepared to
make a substantial production of discovery" as soon as the protective order was entered. (Tr. 12-
13). However, the government was clearly not prepared to produce discovery, as each of the three
EFTA00013225

=== Page 2 ===
September 21, 2020
Page 2
subsequent productions contained numerous unreadable documents and were delivered to Ms.
Maxwell in the MDC well after the dates on the cover letters. Ms. Maxwell did not receive the
government's August 5th production until August 11th and did not receive the August 13th
production until August 17th. As you recall, Ms. Maxwell did not receive the hard drive with the
government's third and final production in this first phase of discovery until August 25, 2020,
several days after the August 21, 2020 deadline imposed by the Court.
On a conference call on August 27, 2020, we advised you of the substantial number of
documents in all three productions that Ms. Maxwell was unable to access, and even proposed
possible technological solutions that we thought might alleviate the problem - namely, shortening
the file paths to the documents and producing the documents on a hard drive with onboard
encryption, as opposed to McAfee encryption. Later that same day, we sent you a follow-up letter
listing the unreadable documents and requesting that the government immediately reproduce to
Ms. Maxwell a new set of all of the discovery materials produced to date in a format that she could
access on her computer at the MDC, and provide the appropriate software tools that will allow her
to review all of the discovery files. That same day we also shipped to you two separate hard
drives - one with onboard encryption and one without - to use to load the replacement production.
The new hard drive was not made available to Ms. Maxwell at the MDC until the late
afternoon of September 9, 2020, almost two weeks later. While some of the previously unreadable
documents are now readable, Ms. Maxwell still cannot access a substantial portion of the
discovery materials, including certain file types and extensions. For example, Ms. Maxwell
cannot read any documents that have .XLS or .EML file extensions. Ms. Maxwell also still cannot
access the following documents:
Production Number
Bates Numbers
Production 1
967
969
971
973-974
976
1014
3699
3700
4511
5417
5431-5433
5487-5491
6007-6101
6130-6132
7087-7089
EFTA00013226

=== Page 3 ===
September 21, 2020
Page 3
7521-7580
7620-7641
7660
7676-7677
9087-9088
11489-11490
12217
12305
12359
12376
12382
12405
Production 2
20147
20169
20171
20182
20184
20199
20205
20223
20231
20242
20254
20262
20269
20277
20284
20306
20333
20335
20337
20355
20397
65958-65960
76863-76876
76877-76884
78667-78668
78670-78671
78710-78747
87383
EFTA00013227

=== Page 4 ===
September 21, 2020
Page 4
87407-87688
89471-89642
90052
90409
90486
91249
91540-92418
92994-93060
93432-94279
98846-101563
101564-101631
102101-102121
105689-105866
107072-107272
110210-110266
118735-118750
164886-164887
164920-165517
Production 3
167914-168477
169184-169504
169505-169749
169760-170396
170398-170613
170624-170635
171442
171447
171449
171455
172140
It is the responsibility of the government, not the defense, to ensure that Ms. Maxwell has a
complete set of the discovery that she can review in the MDC. Defense counsel should not be in
the position of having to suggest technological fixes to help the government satisfy its own Rule
16 obligations, which have not been met. Without access to the full discovery materials, Ms.
Maxwell cannot participate in the preparation of her defense. Accordingly, we demand that the
EFTA00013228

=== Page 5 ===
September 21, 2020
Page 5
government immediately fix all of the issues with Ms. Maxwell's discovery so that she can review
all of the discovery materials produced to date. 1
Ms. Maxwell also does not have access to a table or a writing surface on which to take
notes when she is reviewing the discovery. The desktop computer she uses to review discovery
sits on a table that is only wide enough to accommodate the computer, leaving no room to take
notes. Ms. Maxwell must attempt to write while the paper is on her lap or rest the paper sideways
on the little available space next to the computer. Furthermore, the computer screen uses to view
the discovery faces the prison guard station and the doorway to the rec room, where the phone is
located. As a result, any time a guard answers the phone or enters or exits the rec room, which
occurs as much as 40 times a day or more, Ms. Maxwell has to turn off the computer screen to
prevent the guards from seeing what she is reviewing.
These conditions severely impact Ms. Maxwell's ability to prepare her defense and provide
written instructions to her legal team. We therefore request that you speak to the warden about
providing Ms. Maxwell with a desk and reorienting the computer screen so that it is not visible to
the prison guards.
2. Ms. Maxwell and Defense Counsel Request Access to All Documents Designated
as "Highly Confidential"
According to the Protective Order in this case, Ms. Maxwell may only review the
documents marked by the government as "Highly Confidential" in the presence of defense counsel
and "under the protection of law enforcement officers or employees." (Dkt. 36 14).
Accordingly, we request that the government schedule a time at the earliest possible convenience
for Ms. Maxwell and defense counsel to review all of the "Highly Confidential" documents
produced to date, pursuant to the terms of the Protective Order.
3. Ms. Maxwell's Conditions of Confinement Must Be Improved
Ms. Maxwell's conditions of confinement are extraordinarily onerous and unlike those of
any other inmate at the MDC (or in BOP custody, to our knowledge). In fact, in the time that Ms.
Maxwell has been at the MDC, she has met with four separate wardens and interim wardens, and
each has told her that they have never seen in their collective years of experience anything like her
current regime. We have written to the current warden twice in the last three weeks - on August
28, 2020 and September 9, 2020 - making specific requests to improve the conditions of her
I We exclude from this any discovery materials marked "Highly Confidential" that she is not permitted to review in
the MDC under the terms of the Protective Order in this case. The "Highly Confidential" documents are the subject of
the defense's second request.
EFTA00013229

=== Page 6 ===
September 21, 2020
Page 6
confinement, but have received no response. Accordingly, we now ask the government to
intercede with the BOP to make the following improvements.
a. Living Conditions, Surveillance, and Searches
Despite being housed on an entire floor by herself, Ms. Maxwell is forced to sleep and
spend half of her time in a confined space ominously referred to as the "isolation cell," which is
roughly 7x9 feet. While she is inside the isolation cell, Ms. Maxwell is constantly watched by 2-3
prison guards and has two cameras trained on her every second - one in the ceiling and a
supplemental handheld camera that is usually positioned only about four feet away from her. She
gets very little sleep, as she is woken up by flashing lights, loud discussions among the guards,
and adjustments of the supplemental camera. Ms. Maxwell is effectively being kept in solitary
confinement (she has now been housed alone for over 80 days) and treated as if she were on
suicide watch even though she is not, and has never been suicidal. Moreover, she is being treated
like a laboratory rat, with her every movement is recorded by the prison guards every 15 minutes.
Ms. Maxwell is supposed to be allowed out of the isolation cell from 7am to 8pm each day
and taken to a separate rec room on the same floor, where a desktop computer and a shower are
located, so that she can review the discovery and maintain her personal hygiene. However, she is
frequently picked up late and returned to the isolation cell early. For example, this past Friday,
September 18, 2020, Ms. Maxwell had an in-person counsel visit that was supposed to begin at
11:00 a.m. Ms. Maxwell was not picked up from the isolation cell until after 8am and was not
delivered to the visiting room until approximately 45 minutes after the meeting was supposed to
begin. When Ms. Maxwell finally arrived, she then needed to be strip-searched before the meeting
could begin, which meant that the visit was cut short by almost an hour.2
Ms. Maxwell is also searched more frequently and extensively than any other pretrial
detainee of which we are aware. Each time Ms. Maxwell is moved from the isolation cell, she is
searched and her cell is searched, and she is often searched again when she arrives at the rec room,
all of which takes up time she could be using to review the discovery. Then process is repeated
when Ms. Maxwell is brought back to the isolation cell. This past Friday, Ms. Maxwell was
searched at least five separate times and strip-searched twice. Each time, Ms. Maxwell had her
mouth searched by prison guards who put their hands inside her mouth, which exposes her to
heightened risk of COVID-19 transmission.
Given the disruption caused by moving Ms. Maxwell each day, we do not see why Ms.
Maxwell could not be housed in the rec room where the computer and shower are located, instead
of the isolation cell. In fact, Ms. Maxwell was told on several occasions by previous wardens and
2 Ms. Maxwell was also not given approved legal calls with counsel on August 25, 2020 and August 27, 2020.
EFTA00013230

=== Page 7 ===
September 21, 2020
Page 7
interim wardens that this was the plan. We ask that the government talk to the current warden
about implementing this change.
b. Body Scans
Ms. Maxwell is subjected to a body scan each week, and until recently, she received
approximately three per week. We assume these are to see if Ms. Maxwell has secreted anything
inside her body. We do not understand why it is necessary for the BOP to administer body scans
on such a regular and frequent basis - and thereby repeatedly expose Ms. Maxwell to radiation -
especially when she is already under constant surveillance and the scans have all come up
negative. We ask that these body scans be curtailed significantly or eliminated, if possible.
c. Access to the Commissary
Although the MDC nominally approved Ms. Maxwell's request for permission to purchase
from the full prison commissary list in August 2020, in fact, her access to the commissary is still
extremely limited. To name just one example, she has not been able to purchase sports bras that
fit since she arrived at the MDC. Ms. Maxwell cannot be denied such a basic article of clothing.
Among other things, it means that she cannot engage in aerobic exercise necessary to stay healthy.
We are more than happy to send Ms. Maxwell whatever brand of underwear is approved by the
MDC, but we cannot do so without the permission of the warden. We therefore ask the
government to speak to the warden about granting defense counsel permission to send Ms.
Maxwell approved commissary items, including underwear, and to give her access to the full
commissary list.
d. Food/Care Packages
Ms. Maxwell's meals have been a persistent problem and are entirely inadequate. She has
been given non-vegetarian meals and has been denied food on the prison menu. For example, she
often receives meals with no protein and was recently given only bread and butter for several
meals with no additional food. It was not until Ms. Maxwell was given access to the menu for the
first time on September 1, after she complained that she had been given a non-vegetarian meal,
that she realized that she had not been receiving full meals with all of the nutritional components
since arriving at MDC.
Moreover, she has often has been given inedible food, such as frozen black bananas, and
has not been fed at all for long stretches of time. For example, this past weekend she was not fed
anything for a period of more than 20 hours from Saturday late afternoon until Sunday at midday.
As a result of this inadequate nutrition, she has lost a great deal of weight since arriving at MDC.
The MDC's response to this problem was to remove the scale from the rec room so that she can no
longer weigh herself and keep track of how much weight she is losing. This is unconscionable
EFTA00013231

=== Page 8 ===
September 21, 2020
Page 8
and unacceptable. This lack of food also severely affects her ability to concentrate and review
discovery to prepare her defense.
We therefore ask the government to speak to the warden about ensuring that Ms. Maxwell
is given full access to the prison menu, that she be given complete meals on a timely basis, and
that her food is, at the very least, edible and provides her with enough nutrition to stop her weight
loss. We also ask that Ms. Maxwell, like other detainees, be given permission to receive care
packages of approved food items to supplement her diet.
e. Non-Delivery of Mail and Other Items
Delivery of mail to Ms. Maxwell has also been a problem. Ms. Maxwell's friends and
family members have mailed her numerous letters since she arrived at the MDC. However, as of
yesterday, she has only received a handful of these letters, despite being correctly addressed.
Several of these letters appear to have been rejected because they were written on colored paper,
as opposed to white paper, even this prohibition appears nowhere in the prison regulations. It took
six weeks for these letters to be rejected. And even though these letters were all resent on white
paper, only one of the nine letters has been delivered to Ms. Maxwell thus far. At the same time,
Ms. Maxwell has received hundreds of letters from people she does not know. We do not know
why most of the letters that she cares about have not been delivered, while there seems to be no
limit whatsoever on the number of letters she can receive from complete strangers.
Ms. Maxwell has also not received shipments of approved items from Amazon. For
example, on August 13, 2020, her counsel placed an Amazon order for a package of five BOP-
approved flexible pens and eight BOP-approved legal pads. The legal pads were delivered to the
MDC on August 18, 2020, and the pens were delivered on August 19, 2020. Both deliveries were
rejected as undeliverable without reason. Similarly, the delivery of a book was rejected and
returned for no apparent reason. And to our knowledge, none of the copies of The New York
Times, which are approved and have been paid for since August 1, 2020, have been delivered to
Ms. Maxwell. We do not understand why these items were rejected or have not been delivered.
We were also not permitted to deliver a new pair of reading glasses to Ms. Maxwell to
replace the ones that BOP personnel broke in a search of her cell shortly after she arrived at the
MDC. Instead, we had to wait until Ms. Maxwell received approval to receive the glasses and
then had to mail them to her. As result, Ms. Maxwell was without her reading glasses for over
two months from early July 2020 until September 16, 2020, when they finally were provided to
her at the MDC. It therefore has been extremely difficult for Ms. Maxwell to review the discovery
until now.
We therefore ask the government to speak to the warden about ensuring that Ms.
Maxwell's personal mail is delivered in a timely fashion, and that future deliveries of approved
items are not rejected and are delivered to Ms. Maxwell.
EFTA00013232

=== Page 9 ===
September 21, 2020
Page 9
*
*
In her August 25, 2020 Opinion and Order, Judge Nathan stated that if Ms. Maxwell is not
being provided sufficient access to the discovery materials "so that she can meaningfully
participate in the preparation of her defense," defense counsel may seek intervention by the Court.
(Dkt. 49 at 2). Judge Nathan further stated that while she had not been presented any evidence
that Ms. Maxwell's conditions of confinement were punitive or motivated by an improper
purpose, she nevertheless ordered the government "to provide written status updates every 90 days
detailing any material changes to conditions of Ms. Maxwell's confinement, with particular
emphasis on her access to legal materials and ability to communicate with defense counsel." (Id.).
For the reasons set forth above, the government and the BOP are not providing adequate
conditions that allow Ms. Maxwell access to the discovery materials so that she can meaningfully
participate in the preparation of her defense. Ms. Maxwell has been provided hard drives
containing a substantial number of unreadable files and therefore still cannot review the entire
discovery production, even though it is now one month after the discovery deadline has passed.
Furthermore, the conditions of Ms. Maxwell's confinement have deteriorated since our last
application to the Court for relief. She is not being fed a sufficient amount of food and is losing a
great deal of weight, which makes it very difficult for her to review the discovery and prepare her
defense. Ms. Maxwell is also subjected to a level of surveillance that is intrusive, aggressive,
constant, unnecessary and unjustifiable on the grounds of safety and security. These measures are
akin to punishment, which is inappropriate for any pretrial detainee, especially one who, like Ms.
Maxwell, has never once received a disciplinary infraction.
We seek your urgent intervention on these issues now, well before the November 25, 2020
deadline for the government's first written status update to the Court, because these matters simply
cannot wait until then to be remedied. We further reserve all of our rights with regard to these
issues, including the right to seek intervention from the Court, if these matters are not addressed
expeditiously.
EFTA00013233

=== Page 10 ===
September 21, 2020
Page 10
Thank you in advance for your attention to these matters.
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
cc:
EFTA00013234


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 10892303-1(1) approved by
now awaiting further
approval
Date: Tue, 31 Dec 2019 14:30:28 +0000
Importance: Normal
Dear
Final voucher 10892303-1(1) has been approved by
now awaiting further approval.
Trip ID: 10892303-1
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13197 - U.S. V. Epstein - Witness Interview (California)
Destination: Santa Monica, CA, United States
Dates: 2019-12-15 - 2019-12-18
Current status: Pending Voucher Approval
Voucher total expenses: 2227.40
Estimated trip cost: 2440.58
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0010
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00010330


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c3: VOL00008
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c7: images
c0:
=== Page 1 ===
From:
(USANYS) [Contractor]"
To: Montell Figgins
Cc:
(USANYS)"
(USANYS)"
Subject: U.S. V Thomas, No. 19 Cr 830 - Discovery Production 6
Date: Wed, 14 Oct 2020 21:17:38 +0000
Attachments: SDNY_00017772_(AEO).pdf; 2020.10.14_Thomas_Discovery_Letter_-_Production_6.pdf
Counsel,
Please find attached a letter regarding the Government's production in this case. We are uploading a zip file containing
the discovery materials to USAfx. Additionally, please find attached one additional page of discovery, which has been
marked attorney's eyes only. Please contact us with any questions or if you have any difficulty accessing the production.
Regards,
Paralegal Specialist
U.S. Attorney's Office I SDNY
New York, NY 10007
Office:
Cell:
EFTA00011428


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=== Page 1 ===
From:
To:
Subject: RE: travel approval request
Date: Mon, 28 Oct 2019 16:49:06 +0000
Hi
Yes, thanks - could you please make these bookings:
-
Monday, Nov. 4, 7:30 a.m., JetBlue, LGA to PBI (arriving 10:22 a.m.)
-
Nov. 4 to Nov. 5, reservation at Hilton West Palm Beach
-
Nov. 4, conference room reservation at Hilton West Palm Beach (if you could please have me be listed as the contact
person, and put it on my travel card, that seems to be easiest for them in terms of logistics when we're there)
-
Tuesday, Nov. 5, 7:53 a.m., JetBlue, PBI to JFK (arriving 10:27 a.m.)
I think that's everything, but please let me know if I'm forgetting anything or if any other info would be useful, and thanks
as always.
From:
Sent: Monday, October 28, 2019 09:27
To:
Subject: RE: travel approval request
Good morning
Have you finalized the dates and location for your trip to West Palm Beach, FL scheduled between Nov 3- 5th? I'd like to
start the reservation process for the airfare, hotel and amount of days you'll need a conference room. Let me know ASAP
so your preferred options don't sell out. Thanks as always.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Tuesday, October 22, 2019 2:03 PM
To:
Cc:
is
>;
is
Subject: RE: travel approval request
Thanks very much.
From:
Sent: Tuesday, October 22, 2019 14:00
To:
Cc:
is
is
EFTA00010268

=== Page 2 ===
is
Subject: RE: travel approval request
Approved for both and the conference room.
From:
Sent: Tuesday, October 22, 2019 1:55 PM
To:
Cc:
is
>;
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and
we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel on that Monday for the interview, please.
thanks very much,
From:
Sent: Wednesday, June 12, 2019 14:51
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference room at
the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
EFTA00010269

=== Page 3 ===
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
)
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week for
meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and
return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
EFTA00010270

=== Page 4 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00010271


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c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
mcc new YORK
MCC new TORN
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
SPECIAL HOUSING WAIT
ZA
TIER-G
DATE: 08/10/2019
TIME
TIME
TIME
SIGNATURE
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TIME
TIME
SIGNATURE
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1209
1210
3:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1241
1242
30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
1"
12
00-9:30 AM
5:00-5:30 PM
1:30-2:00 AM
137
138
:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
207
208
0:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
241
242
0:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
300
308
1:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
343
34
1:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
4"
47
2:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
440
4
12:30- 1:00 PM
8:30-9:00 PM
5:00-5:30 AM
508
500
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
In
542
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
410
u"
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
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10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
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=== Page 2 ===
mcc NEW TORK
mcc new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
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ZA
TIER-H
DATE: 08/10/2019
TIME
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START
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12"
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4:00-4:30 PM
12
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1245
124
30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
113
114
00-9:30 AM
5:00 -5:30 PM
1:30-2:00 AM
1:37
139
30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
2"
2'
0:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
245
24
0:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
3"
3
1:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
343
340
1:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
414
4
2:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
+140
44
2:30- 1:00 PM
8:30-9:00 PM
5:00-5:30 AM
510
5"
00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
543
5KK
30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
412
103
00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates L onfined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at le: st once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another roun 1 in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than .0 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
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MCC new YORK
MCC NEW YORK
mcc new YORK
SPECIAL HOUSING UNIT
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SPECIAL HOUSING WAIT
ZA
SPECIAL HOUSING WAIT
TIER-J
DATE: 08/10/2019
TIME
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1005
1206
8:00-8:30 AM
4:00-4:30 PM
12:30-1:00 AM
1239
1238
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
107
Psol
9:00-9:30 AM
5:00-5:30 PM
1:30-2:00 AM
135
136
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
2.05
200
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
2399
240
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
305
36
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
339
3400
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
City
413
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
436
839
12:30- 1:00 PM
8:30-9:00 PM
5:00-5:30 AM
504
505
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
534
538
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
Cive
$ 4
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00009777

=== Page 4 ===
mcc new YORK
MCC new TORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
ZA
SPECIAL HOUSING WAIT
TIER-K
DATE: 08/10/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1207
1208
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1259
1040
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
109
110
9:00-9:30 AM
5:00-5:30 PM
1:30-2:00 AM
137
138
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
267
208
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
2"
242
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
307
308
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
341
342
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
4th
4°
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
438
439
12:30- 1:00 PM
8:30-9:00 PM
5:00-5:30 AM
506
507
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
539
54
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
608
600
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00009778

=== Page 5 ===
mcc new TORK
MCC new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
SPECIME HOUSING UNIT
ZA
TIER- L
DATE: 08/10/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1201
1202
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1233
1234
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
103
104
9:00-9:30 AM
5:00 -5:30 PM
1:30-2:00 AM
131
32
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
201
202
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
235
236
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
301
302
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
333
39,
234
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
406
407
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
430
431
12:30- 1:00 PM
8:30-9:00 PM
5:00-5:30 AM
500
you
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
533
534
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
602
603
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00009779

=== Page 6 ===
mcc new YORK
MCC new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
SPECIAL HOUSING VAIT
ZA
TIER-M
DATE: 08/10/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1203
12
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1235
123
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
105
104
9:00-9:30 AM
5:00-5:30 PM
1:30-2:00 AM
133
13
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
203
204
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
2t
230
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
303
3°
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
333
33
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
408
400
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
434
7
12:30-1:00 PM
8:30-9:00 PM
5:00-5:30 AM
502
50
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
535
530
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
604
605
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00009780


c1: EFTA00010020
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00010020.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: [EXTERNAL] US V Maxwell, 20-cr-330 (AJN), public portion of transcript attached
Date: Wed, 10 Nov 2021 23:20:54 +0000
Attachments: LBAAMAXH.pdf
Good evening.
The public portion of the transcript of today's hearing in US V Maxwell, 20-cr-330 (AJ), is attached.
The judge has granted permission for us to handle the sealed portion by email, and it will be sent separately, later this
evening.
Regards,
EFTA00010020


c1: EFTA00013926
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00013926.pdf
c6: pdf
c7: images
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=== Page 1 ===
Case 9:08-cv-80736-KAM
Document 19
Entered on FLSD Docket 08/01/2008
Page 1 of 16
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-80736-CIV-MARRA/JOHNSON
JANE DOE #1 AND JANE DOE #2,
Petitioners,
V.
UNITED STATES OF AMERICA,
Respondent.
VICTIMS' RESPONSE TO GOVERNMENT'S "NOTICE TO COURT REGARDING
ABSENCE OF NEED FOR EVIDENTIARY HEARING" AND MOTION FOR
PRODUCTION OF NON-PROSECUTION AGREEMENT AND OF REPORT OF
INTERVIEW
COME NOW the Petitioners, Jane Doe #1 and Jane Doe #2 (the "victims"), by and
through their undersigned attorneys to file this Response to the Government's document styled as
"Notice to Court Regarding Absence of Need for Evidentiary Hearing" as follows:
INTRODUCTION
At the conclusion of the oral argument on the victims' petition, victims Jane Doe #1 and
Jane Doe #2 joined the Government in expressing to the Court a desire to work out a set of
stipulated facts regarding this case. Towards that end, the Government sent a proposed set of
stipulated facts to the victims' counsel (Exhibit 1 to this pleading) and, in turn, the victims' sent
a responsive letter raising concerns about some of the Government's proposed stipulated facts
and suggesting some additions and modifications (Exhibit 2 to this pleading). The victims also
requested copies of two relevant documents from the Government: (1) the Non-Prosecution
1
EFTA00013926

=== Page 2 ===
Case 9:08-cv-80736-KAM
Document 19
Entered on FLSD Docket 08/01/2008
Page 2 of 16
Agreement with defendant Epstein that is at the center of this litigation and (2) the FBI's report
of interview concerning a meeting with Jane Doe #1. These requests were also made in several
telephone conversations with the attorney for the Government. Remarkably, rather than respond
to the victims' suggestions, the Government has now suddenly reversed course and filed a terse
document claiming an "absence of a need" for an evidentiary hearing. If anything, however, the
victims' discussions with the Government have made clear that the Court should not enter
judgment for the Government but rather should enter immediate judgment for the victims that the
Government violated their rights under the CVRA. The Court should then schedule a hearing to
determine the proper remedy for the violation of the victims' rights.
In particular, the Government now apparently admits that the Non-Prosecution
Agreement it struck with Epstein in September 2007 contained an "express confidentiality
provision." See Exhibit 1 to this pleading, Government's Proposed Stipulated Facts, at page 3,
paragraph 6. Assuming that the Government honored its agreement with the defendant (a fact
that the victims have proposed to stipulate to), the Government could not have "conferred" with
the victims about the proposed arrangement over the next nine months because doing so would
have violated its confidentiality obligations with the defendant. As a result, the Government
plainly has not afforded the victims' their right to "confer" about the proposed arrangement under
the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771(a)(5). In addition, the Government
effectively misled the victims that it had reached a Non-Prosecution Agreement with Epstein,
plainly violating the victims' rights to be treated with "fairness" under the CVRA, 18 U.S.C.
371(a)(8)(8). The Court should therefore find that the victims' rights have been violated.
The Court should also order the Government to produce the Non-Prosecution Agreement
2
EFTA00013927

=== Page 3 ===
Case 9:08-cv-80736-KAM
Document 19
Entered on FLSD Docket 08/01/2008
Page 3 of 16
to the victims. The victims are entitled to know what disposition has been made in their case.
Moreover, that Agreement purportedly contains provisions pertaining to the civil liability of
Epstein for crimes he has committed against Jane Doe #1 and Jane Doe #2. Epstein obviously
knows what those provisions are. The victims are entitled to see those provisions and the
surrounding document as well.
The Court should also order the Government to produce a report of interview with Jane
Doe #1 from about October 26, 2007, during which the Government apparently claims that it
discussed the plea arrangement with the victims.
Finally, after these documents are produced to the victims and the Court enters judgment
that the victims' rights have been violated, the Court should schedule a hearing to determine the
appropriate remedy for the violations of the victims' rights.
THE VICTIMS' PROFFERED FACTS
The Government's latest submission takes the position that "after consideration" it is now
unnecessary to hold an evidentiary hearing. The Government apparently believes that the Court
could rule in its favor based on just two submitted undisputed facts. In taking this position, the
Government apparently believes that there are no set of facts that could sustain judgment for the
victims. To the contrary, however, the available facts require judgment for the victims that their
rights under the CVRA have been violated.
Having attempted to confer with the Government about the facts in this case, counsel for
the victims respectfully submit the following - and more complete -- set of facts that, on
information and belief, they could establish if given the opportunity to do so:
In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of
3
EFTA00013928

=== Page 4 ===
Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 4 of 16
Investigation opened an investigation into allegations that Jeffrey Epstein had used facilities of
interstate commerce to induce young girls between the ages of thirteen and seventeen to engage
in prostitution (among other offenses). The case was presented to the United States Attorney's
Office for the Southern District of Florida, which accepted the case for investigation. Jane Doe
#1 and Jane Doe #2 were victims of sex crimes committed by Epstein while they were minors.
The U.S. Attorney's Office's investigation soon revealed that Epstein had committed
federal sex crimes against Jane Doe #1 and Jane Doe #2. This made Jane Doe #1 and Jane Doe
#2 "victims" protected by the Crime Victim's Rights Act, 18 U.S.C. $ 3771. Accordingly, the
U.S. Attorney's Office arranged to have victim notification letters sent to Jane Doe #1 and Jane
Doe #2. For example, on about June 7, 2007, Assistant U.S. Attorney A. Marie Villafaña sent a
letter to Jane Doe #1 that began: "Pursuant to the [CVRA], as a victim and/or witness of a federal
offense, you have a number of rights." The letter then listed the various rights of victims under
the CVRA. The U.S. Attorney's Office would not have sent such a letter to Jane Doe #1 if it did
not believe that she was a victim and was protected by the CVRA.
By mid-2007, the U.S. Attorney's Office had ample information to file an indictment
against Epstein charging multiple federal sex offenses. It elected not to file an indictment but
instead to engage in pre-indictment plea discussions with Epstein.
In September 2007, Epstein and the U.S. Attorney's Office reached an agreement
blocking any federal prosecution of the federal offenses he had committed. This Non-
Prosecution Agreement barred federal charges for Epstein's sex offenses in favor of prosecution
by Florida, so long as several preconditions were met. Those included a conviction on a state
sex offense that reflected that the victims were minors at the time the crimes occurred and that
4
EFTA00013929

=== Page 5 ===
Case 9:08-cv-80736-KAM
Document 19
Entered on FLSD Docket 08/01/2008
Page 5 of 16
would require sex offender registration. While the Agreement barred federal criminal
prosecution, it envisioned that the victims would pursue a civil rights action against Epstein for
his sexual offenses against them. Most important for present purposes, the Agreement contained
an express confidentiality provision, which prevented the Government from disclosing the terms
of the Agreement to the victims or others before it was consummated. The Agreement was
subsequently modified in October and December 2007. The Agreement has several addenda that
are relevant to the Agreement. (To date, although requested to do so, the Government has
refused to provide to the victims the final Non-Prosecution Agreement or any of its earlier
versions.) Through his attorneys, Epstein was aware of the confidentiality provision and of the
fact that it would block the Government from conferring with the victims about the plea
arrangement.
On about October 26, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason
Richards met in person with Jane Doe #1 at a restaurant. The Special Agents explained that there
had been discussions with Epstein about a possible resolution of the charges against him.
Consistent with the express confidentiality provision in the Non-Prosecution Agreement, the
Special Agents did not disclose that the arrangement would bar any federal prosecution of
Epstein. Nor did the Agents disclose that the Non-Prosecution Agreement had been finalized.
Jane Doe #1's reasonable perception of the meeting was that only the State part of the Epstein
investigation had been resolved, and that the federal investigation would continue, possibly
leading to a federal prosecution. (While the Government has a report of interview regarding this
meeting with the victim that could confirm the victims' understanding of the facts, the
Government has refused Jane Doe #1's request to see the report.)
5
EFTA00013930

=== Page 6 ===
Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 6 of 16
Following the signing of the Non-Prosecution Agreement and the modifications thereto
by the U.S. Attorney's Office for the Southern District of Florida, Epstein received an unusual
benefit that the Government does not ordinarily provide to other criminal defendants: his
performance was delayed while he was given an opportunity to seek higher level review within
the Department of Justice in Washington, D.C.
On around January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI
advising them that "[t]his case is currently under investigation. This can be a lengthy process
and we request you continued patience while we conduct a thorough investigation." The FBI
sent these letters, under the direction of the U.S. Attorney's Office, because it believed that the
CVRA applied to Jane Doe #1 and Jane Doe #2. The FBI did not notify Jane Doe #1 or Jane
Doe #2 that the Non-Prosecution Agreement had been concluded four months earlier. Jane Doe
#1 and Jane Doe #2 reasonably understood that a federal criminal investigation of Epstein was
on-going and that federal criminal charges were possibility. At the time, Jane Doe #1 and Jane
Doe #2 believed that criminal prosecution of Epstein was extremely important. They also
desired to be consulted by the FBI and/or other representatives of the federal government about
the prosecution of Epstein. In light of the letters that they had received around January 10
(among other things), they reasonably believed that they would be contacted before the federal
government reached any final resolution of that investigation.
In the spring 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was
attempting to take her deposition and private investigators were harassing her. Assistant U.S.
Attorney A. Marie Villafaña secured pro bono counsel to represent Jane Doe #1 and several other
identified victims in connection with the criminal investigation. Pro bono counsel was able to
6
EFTA00013931

=== Page 7 ===
Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 7 of 16
assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafaña secured pro bono
counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in
Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms.
Garvin was not advised about the Non-Prosecution Agreement.
In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafaña to inform her
that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide
information about the federal crimes committed by Epstein, hoping to secure a significant federal
indictment against Epstein. AUSA Villafaña and Mr. Edwards discussed the possibility of federal
charges being filed. At the end of the call, AUSA Villafaña asked Mr. Edwards to send any
information that he wanted considered by the U.S. Attorney's Office in determining whether to
file federal charges. Because of the confidentiality provision in the Non-Prosecution Agreement,
Mr. Edwards was not informed of the Agreement's existence. Mr. Edwards was also not
informed that any resolution of the criminal matter was imminent.
On July 3, 2008, Mr. Edwards sent to AUSA Villafaña a letter, a true and correct copy of
which is attached as Exhibit 3. In the letter, Mr. Edwards indicated his desire that federal
charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients: "We
urge the Attorney General and our United States Attorney to consider the fundamental import of
the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional
indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed,
and we further urge you to take the steps necessary to protect our children from this very
dangerous sexual predator." When Mr. Edwards wrote this letter, he still had not been made
aware that a Non-Prosecution Agreement had been reached with Epstein.
7
EFTA00013932

=== Page 8 ===
Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 8 of 16
On about July 3, 2008, Jane Doe #1 and Jane Doe #2 learned, through telephones
conversations had between Mr. Edwards and AUSA Villafaña, that the U.S. Attorney's Office
and Epstein might be in the process of finalizing some sort of plea arrangement. Accordingly,
they filed an emergency motion seeking to protect their rights under the CVRA, including in
particular their right to confer about the proposed plea arrangement.
Mr. Edwards - and thus his clients -- first learned of the Non-Prosecution Agreement on
or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe's
emergency petition. That pleading was the first public mention of the non-prosecution agreement
and the first disclosure to Mr. Edwards and his clients. Epstein, through his attorneys, knew that
the victims had not been informed about the plea arrangement.
On July 9, 2008, AUSA Villafaña sent a victim notification to Jane Doe #1 via her
attorney, Mr. Edwards, which is attached as Exhibit 6 to the Villafaña Declaration. That
notification contains a written explanation of some of the terms of the Non-Prosecution
Agreement between Epstein and the U.S. Attorney's Office. A full copy of the terms was not
provided. This was the first time that Jane Doe #1 was told that the arrangement blocked any
possibility of federal criminal charges being filed against Epstein. A notification was not
provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the
United States was prepared to name in an indictment.
On July 11, 2008, the Court held a hearing on the victims' emergency motion. During the
hearing, the Government discussed in open court various provisions of the Non-Prosecution
Agreement. At the conclusion of the hearing, victims' counsel and the Government agreed to
8
EFTA00013933

=== Page 9 ===
Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 9 of 16
confer in an effort to determine the undisputed facts of the fact. The Court took the motion under
advisement.
On July 16, 2008, the Government sent to Mr. Edwards a proposed set of undisputed
facts, which is attached to this pleading as Exhibit 1.
On July 17, 2008, Mr. Edwards sent a response to the Government, which is attached to
this pleading as Exhibit 2. The response made various suggestions to the proposed undisputed
facts. The response also requested a copy of the Non-Prosecution Agreement and the Report of
Interview with Jane Doe #1.
On July 29, 2008, rather than attempt to work with victims' counsel to draft a set of
undisputed facts, the Government filed its "Notice to Court Regarding Absence of Need for
Evidentiary Hearing."
At all times material to this statement of facts, it would have been easily practical and
feasible for the Federal Government to inform Jane Doe #1 and Jane Doe #2 of the details of any
proposed plea agreement with Epstein, including in particular the details of the Non-Prosecution
Agreement. The reason that AUSA Villafaña and the FBI agents acting with her did not provide
this information to Jane Doe #1 and Jane Doe #2 was because of the express confidentiality
provision that had been entered into by the Federal Government and Epstein. This provision
was requested by Epstein. The Government was under no obligation to enter into such an
arrangement and would have been statutorily forbidden from entering into such an arrangement
by the CVRA's requirement that it "confer" with the victims about any disposition of their cases.
9
EFTA00013934

=== Page 10 ===
Case 9:08-cv-80736-KAM
Document 19
Entered on FLSD Docket 08/01/2008
Page 10 of 16
THE GOVERNMENT SHOULD BE DIRECTED TO CONFER WITH THE VICTIMS
REGARDING THE UNDISPUTED FACTS OF THE CASE
The Government should be directed to confer with the victims about the facts in this case,
rather than allowed to obscure the facts with its proposed "notice" that an evidentiary hearing is
unnecessary. The reason that the Government abruptly terminated discussions about the facts
with the victims seem obvious: The facts, if revealed, would plainly demonstrate that the victims
did not receive their right under the CVRA to confer with the Government and to be treated
fairly. The victims will not repeat all of their arguments from their earlier pleadings but would
simply highlight for the Court the point that this case already reeks of favored treatment for a
billionaire sex offender who has substantial influence. Regardless of how the Court proceeds, it
should at least do so on the basis of fully developed factual record so that the victims and the
public can be assured that justice has been done.
If anything, the facts in this case now call for immediate judgment in favor of the victims.
Based on the Government's proposed stipulated facts (Exhibit 1 to this pleading), it is now
obvious that the Government could not have fulfilled its statutory obligations to confer with the
victims. As now admitted by the Government, in September 2007, it had entered into a Non-
Prosecution Agreement with Epstein containing what it describes as "an express confidentiality
provision." While the Government has refused to disclose the text of this provision (or, indeed,
the Non-Prosecution Agreement itself), it is apparent that the Government could not have
conferred with the victims about the Agreement while abiding by the confidentiality provision.
Likewise it is now apparent that the Government has not fulfilled its statutory obligation
to treat the victims with fairness. The Government reached the Non-Prosecution Agreement with
10
EFTA00013935

=== Page 11 ===
Case 9:08-cv-80736-KAM
Document 19
Entered on FLSD Docket 08/01/2008
Page 11 of 16
Epstein in September 2007, yet affirmatively concealed that Agreement from the victims through
a series of misleading statements and representations over the next nine months. For example,
on around January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising
them that "[t]his case is currently under investigation. This can be a lengthy process and we
request your continued patience while we conduct a thorough investigation." As the Government
well knew, however, a Non-Prosecution Agreement had already been reached with Epstein at that
time - a fact not disclosed in the letter.
The victims therefore request judgment in their favor that their rights under the CVRA
have been violated. In the alternative, the victims request that the Court direct that the
Government confer in good faith with the victims to attempt to reach a set of stipulated facts that
might form the basis for a final ruling in this case. As part of this conference, the victims request
that the Government indicate which (if any) of the proposed facts set forth above it disputes.
THE GOVERNMENT SHOULD BE REQUIRED TO PRODUCE
THE NON-PROSECUTION AGREEMENT
Remarkably, the Government has yet to disclose to the victims the very Non-Prosecution
Agreement that lies at the heart of this case. This failure becomes even more curious when
assessed against the Government's proposed stipulation of facts, which included the proposed
fact that the victims had been told about the "full terms" of the Agreement. The proposed
stipulated facts that the Government sent to the victims included this proposed stipulation:
On July 9, 2008, AUSA Villafaña sent a victim notification to Jane Doe #1 via her
attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafaña
Declaration. That notification contains a written explanation of the full terms of
the agreement between Epstein and the U.S. Attorney's Office.
Contrary to its own proposed stipulation, the Government has never disclosed to the victims the
11
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=== Page 12 ===
Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 12 of 16
"full terms" of its Non-Prosecution Agreement with Epstein. To protect the victims' right to be
treated with fairness, 18 U.S.C. $ 3771(a)(8), it should be required to do so now.
Congress' main concern in passing the CVRA was that crime victims were "treated as
non-participants in a critical event in their lives. They were kept in the dark by prosecutors too
busy to care enough and by a court system that simply did not have a place for them." 150
CONG. REC. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein). To remedy this problem,
Congress gave victims "the simple right to know what is going on, to participate in the process
where the information that victims and their families can provide may be material and relevant
Id. To date, Jane Doe #1 and Jane Doe #2 do not know what has happened to their case,
because they have not been told how it has been resolved. Of course, no possible harm to the
Government can come from the release of the Agreement, as this criminal matter is now
concluded - at least from the Government's perspective.
Production of the Non-Prosecution Agreement is also warranted because it has provisions
in it that are designed to benefit Jane Doe #1 and Jane Doe #2. As described by the Government,
the Agreement contains provisions in it that preclude Epstein from contesting civil liability for
the sex offenses committed against a number of the victims, including Jane Doe #1. Obviously,
Jane Doe #1 cannot take advantage of this provision if her attorneys are not able to review it.
Jane Doe #1 and Jane Doe #2 intend to file civil suits against Epstein within the next few days.
Epstein knows what is in the Non-Prosecution Agreement that may be helpful to him. Jane Doe
#1 and Jane Doe #2 are entitled to see the Agreement for items that may be helpful to them.
Finally, Epstein is apparently taking advantage of provisions in the Non-Prosecution
Agreement to stall civil suits against him. For example, in Jane Doe V. Epstein et al., No. 08-
12
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=== Page 13 ===
Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 13 of 16
80804-MARRA/JOHNSON (S.D. Fla. 2008), on July 25, 2008, Epstein filed a motion for a stay.
That motion claims that the civil action is "a counterpart to a pending federal criminal action."
The basis for that claim, so far as Jane Doe #1 and Jane Doe #2 can tell, is the federal Non-
Prosecution Agreement. Epstein should not be permitted to use provisions in the Agreement to
his advantage in private litigation without disclosing those provisions to the parties he is
opposing. Indeed, as a simple matter of fairness to the victims, see 18 U.S.C. $ 3771(a)(5)
(victims right to "fairness"), the provisions should be disclosed.
In sum, the Court should direct the Government to reveal to the victims what it has done
to resolve the case by ordering production of the full Non-Prosecution Agreement and any
accompanying addenda to the agreement.
THE GOVERNMENT SHOULD BE REQUIRED TO PRODUCE THE REPORT OF
INTERVIEW WITH JANE DOE #1
The Government apparently has a report of interview indicating that two named FBI
agents met with Jane Doe #1 on about October 26, 2007. The Government, however, has
declined to produce it.
The Government should be directed to produce this information to Jane Doe #1. Of
course, a criminal defendant would be entitled to such a report. See Fed. R. Crim. P. 16(a)(1)(A)
& (B). As an innocent victim in this matter, Jane Doe #1 should be treated with at least the same
consideration. See 18 U.S.C. $ 3771(a)(8) (victim's right to "be treated with fairness"). Jane
Doe #1 requested this report in her letter regarding the proposed stipulated facts (see Exhibit 2 to
this filing), a request that the Government has simply ignored.
13
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=== Page 14 ===
Case 9:08-cv-80736-KAM
Document 19
Entered on FLSD Docket 08/01/2008
Page 14 of 16
AFTER ENTERING JUDGMENT FOR THE VICTIMS' ON THE VIOLATION OF THEIR
RIGHTS, THE COURT SHOULD SCHEDULE A HEARING ON THE APPROPRIATE
REMEDY
For the reasons just explained, the Court should enter judgment for Jane Doe #1 and Jane
Doe #2 on the violations of their rights under the CVRA and order the Government to produce
the Non-Prosecution Agreement and the report of interview with Jane Doe #1. After doing that,
the question then arises as to what is the proper remedy for the violations of victims' rights.
To be clear, at this time, the victims seek two things: (1) a judicial declaration that the
Government violated their rights under the CVRA and an apology from the Government; and (2)
a hearing to discuss the appropriate remedy under the circumstances. At the same time, the
victims are not asking to have any provision in the Non-Prosecution Agreement establishing
liability in a civil suit to be vacated or declared invalid. Because the possible connection
between these two things raises complex legal issues, the victims respectfully request that the
Court order a hearing at which the appropriate remedy can be discussed. The victims also need
to review the full text of the Non-Prosecution Agreement and any accompanying addenda to
make an appropriate determination about the remedy that they wish to pursue.
CONCLUSION
The Court should find that the Government violated Jane Doe #1 and Jane Doe #2's
rights under the CVRA to confer and to be treated with fairness during the negotiation and
consummation of the Non-Prosecution Agreement. In the alternative, the Court should direct the
Government to confer with the victims regarding what facts are undisputed in this matter and,
should material facts actually be disputed, hold an evidentiary hearing regarding those facts. So
that the victims can discuss these matters with the Government, the Court should order the
14
EFTA00013939

=== Page 15 ===
Case 9:08-cv-80736-KAM
Document 19
Entered on FLSD Docket 08/01/2008
Page 15 of 16
Government to provide to the victims the full Non-Prosecution Agreement (and accompanying
addenda) that is central to this litigation as well as a report of interview with Jane Doe #1 from
about October 26, 2007. The Court should then hold a hearing on the proper remedy for the
violations of the victims' rights.
DATED this 1st day of August, 2008.
Respectfully Submitted,
THE LAW OFFICE OF BRAD EDWARDS &
ASSOCIATES, LLC
By:
s/ Brad Edwards
Brad Edwards, Esquire
Attorney for Petitioners
Florida Bar No. 542075
2028 Harrison Street
Suite 202
Hollywood, Florida 33020
Telephone: 954-414-8033
Facsimile:
954-924-1530
E-Mail:
be@bradedwardslaw.com
Paul G. Cassell
Attorney for Petitioners
Pro Hac Vice
332 S. 1400 E.
Salt Lake City, UT 84112
Telephone: 801-585-5202
Facsimile:
801-585-6833
E-Mail:
cassellp@law.utah.edu
15
EFTA00013940

=== Page 16 ===
Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 16 of 16
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on August 1, 2008, I electronically filed the foregoing
document with the Clerk of the Court using CM/ECF.
s/ Brad Edwards
Brad Edwards, Esquire
Attorney for Petitioner
Florida Bar No. 542075
SERVICE LIST
Jane Doe 1 and Jane Doe 2
Case No.: 08-80736-CIV-MARRA/JOHNSON
United States District Court, Southern District of Florida
Dexter A. Lee,
Assistant U.S. Attorney
99 N.E. 4th Street
Miami, Florida 33132
Telephone: 305-961-9320
Facsimile:
305-530-7139
16
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=== Page 1 ===
From: "
(ODAG)"
To:
(USAFLS)"
>, "
(USAFLS)"
Subject: FW: Epstein
Date: Mon, 23 Jun 2008 21:25:28 +0000
Importance: Normal
Attachments: scan0001.pdf
FYI
Original Message
From:
(ODAG)
Sent: Monday, June 23, 2008 5:25 PM
To: 'Starr, Ken'; Jay Lefkowitz; Kenneth Starr
Cc: Acosta, Alex (USAFLS)
Subject: Epstein
Gentlemen:
Attached please find a letter regarding the Epstein matter.
EFTA00013554


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=== Page 1 ===
COHEN & GRESSER LLP
October 1, 2020
BY EMAIL
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear
We write once again to express our dissatisfaction that the government still has not
provided a complete set of readable discovery materials to Ms. Maxwell in the MDC. We have
now had several phone calls and emails to discuss the problems with the discovery, but the
problems still are not fixed. It is now over five weeks since the August 21 discovery deadline set
by the court and the government still has not met its discovery obligations. That is simply not
acceptable.
In our previous letter, dated September 21, 2020, we outlined for you the numerous
problems that Ms. Maxwell had been having with unreadable discovery files since she first began
receiving the government's productions in the MDC in August 2020. This was a continuation of
the same problem we identified for you in our letter, dated August 27, 2020, when we requested a
new set of the discovery materials that were fully readable.
On September 22, 2020, we had a conference call to discuss these issues. On that call, you
stated that you were trying to address the readability problems, but that in the meantime, defense
counsel could, among other things, create a laptop computer with a full copy of the discovery
saved locally that defense counsel could bring to the MDC so that Ms. Maxwell could use it to
review the unreadable discovery. You also notified us that there were approximately 40,000 non-
nude photographs and images, and thousands of nude or partially nude images, which had been
seized from Jeffrey Epstein's residences in New York and the Virgin Islands pursuant to search
warrants, and which you had referenced in your August 21, 2020 production cover letter. You
further advised that you were in the process of scanning those images so that you could produce
any documents not marked Highly Confidential in electronic format. Finally, in response to our
request that Ms. Maxwell be given access to the Highly Confidential documents "at the earliest
EFTA00013222

=== Page 2 ===
October 1, 2020
Page 2
possible convenience," you explained that due to COVID-19 restrictions, the U.S. Marshals are
not producing pretrial detainees to proffer rooms to review discovery and therefore an FBI agent
would have to bring the materials to the MDC for Ms. Maxwell and defense counsel to review, but
did not propose a date when that could happen. 1
On September 29, 2020, we had another conference call to further discuss the discovery.
We advised you that while we planned to create a laptop that we could use to review discovery
with Ms. Maxwell, it was the government's burden, not the defense's burden, to ensure that Ms.
Maxwell had a complete, readable copy of the discovery. Moreover, this did not solve the
problem, as the laptop could only be used during counsel visits and Ms. Maxwell needed a
complete set of the discovery in the MDC that she could review on her own when defense counsel
was not visiting.
We further notified you that we did not believe that making the thousands of images seized
from Epstein's residences available for inspection at the FBI's offices satisfied the government's
discovery obligations because Ms. Maxwell could not be produced to the FBI's offices to review
them. You responded that defense counsel could make a request to have the FBI deliver those
images to Ms. Maxwell in the MDC. In fact, we had made such a request in our September 22,
2020 letter, when we asked to schedule a time for Ms. Maxwell to review the Highly Confidential
documents. That still has not happened. We made an additional request yesterday for Ms.
Maxwell to be able to review the approximately 40,000 non-nude images seized from Epstein's
residences as soon as possible, since these do not require defense counsel to be present for her to
review them in the MDC. Your response was that these images are still being processed for
production. The government has not produced these materials to Ms. Maxwell if she has no way
to inspect them at the FBI's offices and they are still not ready for her to review in the MDC.
Earlier today, you notified us that you have prepared a replacement set of files for the
documents that Ms. Maxwell has been unable to open at the MDC and requested a hard drive from
us, which we provided this afternoon. This will now be the third attempt by the government to
produce a full, readable set of the discovery to Ms. Maxwell (not counting the thousands of
images that are still being processed for production). Given the past attempts, we can expect that
the replacement production will take several days to be made available to Ms. Maxwell in the
MDC and we have little confidence that it will fix the errors when it finally arrives. Ms. Maxwell
has already lost over a month of time to review these documents, and defense counsel have spent
hours cataloguing the defects in the prior productions to correct the government's errors. That is
not acceptable.
I You also stated that you would send us a formal letter memorializing your responses to the issues raised in our
September 21, 2020 letter. We have not received any letter from the government.
EFTA00013223

=== Page 3 ===
October 1, 2020
Page 3
In sum, the government has not complied with its discovery obligations. We reiterate the
request we made on the September 29, 2020 conference call that the government create a laptop
computer, similar to the one that defense counsel is creating, which contains a complete set of the
discovery and which the government has verified is fully readable, and then provide that laptop
immediately to Ms. Maxwell in the MDC. We also renew our request that Ms. Maxwell be given
prompt access to the non-nude images seized from Epstein's residences, and that the government
propose times next week when Ms. Maxwell and defense counsel can review the Highly
Confidential documents at the MDC.
Thank you in advance for your attention to these matters.
Sincerely,
/s/
COHEN & GRESSER LLP
cc:
EFTA00013224


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
USANYS)
[Contractor]
Cc:
(USANYS)"
Subject: RE: Amazon return
Date: Thu, 11 Nov 2021 18:42:58 +0000
Attachments: 2021.11.11_Maxwell_Discovery_Letter.docx
These returns have been stamped here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-
2018R01618\Discovery\GM\37 Twenty-Eighth Production
Draft discovery cover letter is attached and saved here for your review.
From:
Sent: Thursday, November 11, 2021 9:46 AM
To:
(USANYS) [Contractor]
USANYS) [Contractor]
Cc:
USANYS)
)
Subject: RE: Amazon return
Thanks, Sunny! Yes, good to go with this production.
From:
(USANYS) [Contractor]
Sent: Thursday, November 11, 2021 9:29 AM
To:
(USANYS) [Contractor]
Co
(USANYS)
)
Subject: RE: Amazon return
I've added it to the pending Rule 16 production and have saved it to the trial subpoena returns folder here:
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\!Trial\TrialSubpoena Returns\Amazon\2021.11.10
Let me know if you want this pending Rule 16 production prepped to go out today with the 3500 and GX (right now the
pending production just has these Amazon returns).
From:
Sent: Wednesday, November 10, 2021 11:09 PM
To: P
(USANYS) [Contractor]
USANYS) [Contractor]
Cc:
USANYS)
Subject: Amazon return
Hey
and
in
Thanks again for all the help today! When you have a chance, would one of you mind adding this to the next Discovery
folder and to a folder for Amazon subpoena returns?
EFTA00010178

=== Page 2 ===
Thanks!
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00010179


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=== Page 1 ===
From:
To:
Subject: notes from convo w/
counsel
Date: Sat, 07 Mar 2020 22:08:57 +0000
Attachments:
convo_notes.docx
Assistant U.S. Attorney
Southern District of New York
EFTA00011359


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=== Page 1 ===
From: "
(USAFLS)"
To:
(USAFLS)"
(USAFLS)"
Subject: RE:
Date: Mon, 19 Nov 2007 16:46:23 +0000
Importance: Normal
I think it is December 14th, which is a Friday, not the 16th, which is a Sunday.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
Original Message
From:
(USAFLS)
Sent: Monday, November 19, 2007 11:38 AM
To:
(USAFLS);
(USAFLS)
Subject: FW:
Clearly Epstein believes that January 4th not December 16th is when he'll plead guilty and be sentenced. Judging from
email, it seems that January 4th is the date. Hopefully, I'll hear from Judge Davis today or tomorrow. Thanks,
Original Message
From: Jay Lefkowitz [mailto:
Sent: Friday, November 16, 2007 2:00 PM
To:
(USAFLS)
Subject:
- Beyond my letter the other day, and your email
to me from a few weeks ago, is there anything else you
need from me regarding the plea and sentencing dates.
As we discussed, and as we have confirmed, the Court
has told us she will handle both at the same time (plea
before sentencing, obviously), and to the agreed-upon
counts, on Jan 4. I trust I have cleared up any
confusion regarding Jan 7.
Thx. Jay
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
EFTA00013528

=== Page 2 ===
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
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=== Page 1 ===
From:
)"
To:
)"
Bcc:
Subject: FW: Call re Maxwell Staffing
Date: Wed, 28 Oct 2020 17:34:19 +0000
Embedded: FW:_Call_re_Maxwell_Staffing.msg
Sender:
Subject: FW: Call re Maxwell Staffing
Message-Id:
<BN3P110MB0532D56358609FF4DA9B20A38C170@BN3P110MB0532.NAMP110.PROD.OUTLOOK.CO
M>
To:
EFTA00013198


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=== Page 1 ===
From: Isidro Garcia
To:
)"
Cc: Mark Johnson
)"
Subject: RE: SDNY investigation meeting
Date: Sun, 26 May 2019 20:52:27 +0000
OK will copy her on this
Sent from my T-Mobile 4G LTE Device
Isidro M. Garcia
GARCIA LAW FIRM. P.A.
120 S. Olive Avenue
Suite 401
West Palm Beach, Florida 33401
Email
Fax
www.garcialaborlaw.com
Original message
From:
)"
Date: 5/26/19 4:40 PM (GMT-05:00)
To: Isidro Garcia
Cc: Mark Johnson
)"
Subject: RE: SDNY investigation meeting
Sid,
Following up on the below, in addition to asking
to please bring whatever materials she has from that
time, could you please ask her to bring any photos she has of herself from when she knew Epstein - or if she has
many such photos, just five or six from that period of time? It will be very helpful for us to have a record of her
general appearance then, for legal reasons, and we're happy to either make copies and return them to her, or to
have them in safekeeping with us until the investigation is complete, whatever she prefers.
thanks very much,
From:
)
Sent: Thursday, May 23, 2019 13:08
To: 'Isidro Garcia'
EFTA00009933

=== Page 2 ===
Cc: Mark Johnson
Subject: RE: SDNY investigation meeting
Mr. Garcia,
Following up on our phone conversation yesterday, I wanted to send you an email, as promised, as a brief
summary. As discussed, our investigation continues to move forward, and we're interested in meeting with
again to talk with her more specifically about her recollections from the time. Although we have the notes
from her interviews from the prior investigation, it is important for us at this stage to have a sense of what he
current recollection is about his conduct. As I mentioned, we absolutely do not want
to feel re-
victimized or dragged through this unnecessarily; rather, we are hoping to confirm our understanding of what she
described in previous interviews (as to her recollection now). I promise we would not ask her to talk about those
experiences if it weren't important-and useful-to the current investigation.
As we also talked about, when we meet with her we'd like to ask her to please bring the materials she described
having when we first met-I believe she said she had a box of materials from the time, possibly including one or
more phones, possibly photos or gifts, etc. Really anything she has relating to that time or experiences could be
very helpful. We would be happy to provide her with copies of anything that she still wants to retain, and of
course we will treat her possessions with the utmost care and would expect to return them, if she wants, at the
conclusion of the investigation.
Please let us know if you or she has any questions about any of this at all, and we look forward to meeting with
her and you next week. (I understand the timing of that may be changing now-we remain available anytime on
the 29th, or can discuss other days if that doesn't work-unfortunately the agents aren't available on the 31st, but
I'm sure we'll figure it out.)
Thanks very much again, and please express our appreciation to
for meeting with us again, we really
appreciate it.
thank you,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Cc:
Subject: Maxwell trial fact witness travel - -
Date: Fri, 12 Nov 2021 23:14:05 +0000
Attachments:
-_Fact_Witness_Travel_Request_(trial).docx.
Hi
Attached please find a fact witness travel request for another witness in the Maxwell trial-
I expect he'll
testify on 12/8, but he could possible bleed over into 12/9. I need to prep with him on 12/7, and he's not vaccinated, so
we'll need to get him a COVID test before he can testify. Given that plan, I'd like to have him fly in the evening of 12/6 and
out on the evening of 12/9.
It is very important that
not run into
or any of their family.
is
ex, and they do
not know that
is coming up to NY to testify. So would you please make sure that
stays at a hotel that is far
away from anywhere you might put
and their kids?
Thanks so much,
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=== Page 1 ===
From
To: Nathan NYSD Chambers
Cc:
bcsternheim_mac.com <bcsternheim@mac.com>, "ceverdell@cohengresser.com"
<ceverdell@cohengresser.com>, Laura Menninger <Imenninger@hmflaw.com>, "Jeff
Pagliuca" <jpagliuca@hmflaw.com>
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Birth Certificates
Date: Fri, 19 Nov 2021 04:04:27 +0000
Attachments: 2021.11.18_Mot_to_admit_birth_certificates_[unredacted].pdf;
2021.11.18_Mot_to_admit_birth _certificates_proposed_redactions].pdf
Chambers,
Attached please find a letter motion to determine that the Minor Victims' Birth certificates are self-authenticating, in
unredacted form and with proposed redactions.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York. New York 10007
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=== Page 1 ===
Event: Telephone Conference re: Epstein
Start Date: 2008-12-03 19:00:00 +0000
End Date: 2008-12-03 19:30:00 +0000
Organizer:
Location: My office
Class: X-PERSONAL
Date Created: 2015-03-27 13:43:11 +0000
Date Modified: 2015-07-22 20:34:49 +0000
Priority: 5
DTSTAMP: 2008-11-26 19:32:25 +0000
Attendee:
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=== Page 1 ===
From:
To:
(USAFLS)"
Subject: Re: CONFIDENTIAL: Epstein NonProsecution Agrmt W Addendum.pdf
Date: Fri, 05 Dec 2008 03:14:04 +0000
Importance: Normal
Thank you and I will pass on your greeting to
Michael Danchuk
n
In a message dated 12/4/2008 6:15:36 P.M. Eastern Standard Time,
writes:
Dear Mr. Danchuk: I have attached the Non-Prosecution Agreement. Please restrict its disclosure only to those who have reviewed and
signed the Protective Order. If any other staff members or attorneys need to see this document, please have them review and sign the
Protective Order and send it to me. Thank you.
Please give my regards to Ms.
as well.
<<Epstein NonProsecution Agrmt W Addendum.pdf>>
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
Make your life easier with all your friends, email, and favorite sites in one place. Try it now.
EFTA00014130


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c3: VOL00008
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=== Page 1 ===
UMB
June 10, 2020
Attn:
Southern District of New York
1 ST Andrew's Plaza
New York, NY 10007
RE: Ghislaine Maxwell
Dear
On June 10, 2020 we received the attached request(s) as referenced
above.
I was unable to find anything that you are requesting for the
customer(s) listed above and/or on the dates listed on the
subpoena(s).
Please feel free to contact me if you have any further questions on
this matter. I can be reached
Sincerely,
Legal Process Specialist
UMB n.a.
P.O. Box 419226
Kansas City Missouri 64141-6226
816.860.7000
umb.com
Member FDIC
EFTA00010339


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
)"
Subject: RE: call tomorrow re: search warrant documents ?
Date: Tue, 14 Jul 2020 16:17:36 +0000
Yeah it's sometimes challenging to try to precisely relay
info on this, and given the importance I think it'd be
helpful - thanks. I'll propose tomorrow at 1:00.
From:
(USANYS)
Sent: Tuesday, July 14, 2020 12:16
To:
Cc:
in
Subject: RE: call tomorrow re: search warrant documents ?
Sure, if that would be helpful. 1 is better for me than 12, but I can make it work if need be. Morning I can do 10-11.
From:
Sent: Tuesday, July 14, 2020 12:07 PM
To:
(USANYS)
Cc:
is
Subject: call tomorrow re: search warrant documents ?
Could you join a call tomorrow? I could do noon or 1:00 if that works? (Or I also could do the morning if I get coverage
for a couple VOSR check-ins with Berman.)
From:
(NY) (FBI)
Sent: Tuesday, July 14, 2020 12:02
To:
(USANYS) [Contractor]
>;
Cc:
(NY) (FBI)
is
is
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
I'll fill it out and get it back to you ASAP. I am available tomorrow from 7:30 AM till about 3:30 PM, just let me
know when.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jul 14, 2020 11:58 AM,
)"
wrote:
EFTA00009941

=== Page 2 ===
We've received and reviewed the hard drive you provided last week. Unfortunately it's still not possible for us to
determine which devices have been fully 100% included in that drive? We're not able to tell based on looking at the
contents, because the devices do not all appear to have their own folders.
The attached spreadsheet is the one you included on the drive, but it does not reflect which devices have been fully
transferred. Could you please fill in the two columns I've added, L and M, indicating which devices have been fully
transferred to us, and for the ones that are not fully transferred, the estimated time for completion? If you could please
let us know that today it will be extremely helpful in figuring out how to proceed.
And separately, could you please let me know what times you're available for a call tomorrow? It would be helpful to
discuss why a number of the devices were combined together in folders on the drive, rather than being provided
separately. And also helpful to know how long it would take to correct that.
thanks very much,
From:
Sent: Wednesday, May 13, 2020 12:25
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any FBI
tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which both
we and the agents can access. We're required to have the files in a format that we can produce them to defense counsel.
I've done that in many other cases and it hasn't previously been an issue. My understanding from
is that the best
way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will process-by which
I just mean converting into file formats that are loadable onto Relativity. It doesn't really have anything to do with the
taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents earlier
this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9. Again, I
understand from
that the best way forward is to just get copies of the materials in their original formats, which I
understand will be segregated and designated by device. That should work for us! I was just trying to understand the
approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
)
is
(USANYS) [Contractor]
Cc:
is
)
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
EFTA00009942

=== Page 3 ===
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was
already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece
by piece as things are processed, I was unaware that you didn't want to review as things were processed, that
you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a differentiation of
methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
<Christopher.Rozier@usdoj.gov>
Cc:
is
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just basically
sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago, but
regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that
means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
>;
Cc:
is
)
Subject: RE: Epstein search warrant documents
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
EFTA00009943

=== Page 4 ===
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
is
Cc:
is
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it on
our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data and
where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and send
it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
EFTA00009944

=== Page 5 ===
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
>;
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
>;
>;
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review the
returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
i
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
V.
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you.
If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
is
)
>;
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
EFTA00009945

=== Page 6 ===
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems to
do so.
Also,
,
please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're waiting
on that list to be able to do an updated search warrant on all of those devices. Please let us know the current timeline -
and also the current timeline on producing the results from those August and September searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months from our call, which
would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
>;
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
)
>;
>;
>;
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
)
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor] <Christopher.Rozier@usdoj.gov>;
i
>;
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
Rozier can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
EFTA00009946

=== Page 7 ===
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
in
(NY) (FBI)
is
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Are you available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
EFTA00009947

=== Page 8 ===
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
-
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers
and no way to match up anything-that is, even if we were to try to go hunt down every individual large file in the
native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get
a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million
documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
is
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
i
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
EFTA00009948

=== Page 9 ===
(cell)
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor] <Christopher.Rozier@usdoj.gov>;
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
in
)
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
)
>;
is
>;
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
>;
(USANYS)
i
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
>;
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
EFTA00009949

=== Page 10 ===
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think FBI
was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to be
able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
in
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
V.
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
EFTA00009950

=== Page 11 ===
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
in
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
EFTA00009951


c1: EFTA00011386
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00011386.pdf
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c7: images
c0:
=== Page 1 ===
Exhibit A
EFTA00011386

=== Page 2 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 1 of 15
COMPOSITE EXHIBIT A
NON-PROSECUTION AGREEMENT AND
ADDENDUM
EFTA00011387

=== Page 3 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 2 of 15
IN RE:
INVESTIGATION OF
JEFFREY EPSTEIN
/
NON-PROSECUTION AGREEMENT
IT APPEARING that the City of Palm Beach Police Department and the State
Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter,
the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey
Epstein (hereinafter "Epstein");
IT APPEARING that the State Attorney's Office has charged Epstein by indictment
with solicitation of prostitution, in violation of Florida Statutes Section 796.07;
IT APPEARING that the United States Attorney's Office and the Federal Bureau of
Investigation have conducted their own investigation into Epstein's background and any
offenses that may have been committed by Epstein against the United States from in or
around 2001 through in or around September 2007, including:
(1)
knowingly and willfully conspiring with others known and unknown to
commit an offense against the United States, that is, to use a facility or means
of interstate or foreign commerce to knowingly persuade, induce, or entice
minor females to engage in prostitution, in violation of Title 18, United States
Code, Section 2422(b); all in violation of Title 18, United States Code, Section
371;
(2)
knowingly and willfully conspiring with others known and unknown to travel
in interstate commerce for the purpose of engaging in illicit sexual conduct, as
defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18,
United States Code, Section 2423(b); all in violation of Title 18, United States
Code, Section 2423(e);
(3)
using a facility or means of interstate or foreign commerce to knowingly
persuade, induce, or entice minor females to engage in prostitution; in
violation of Title 18, United States Code, Sections 2422(b) and 2;
(4)
traveling in interstate commerce for the purpose of engaging in illicit sexual
conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation
Page 1 of 7
EFTA00011388

=== Page 4 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 3 of 15
of Title 18, United States Code, Section 2423(b); and
(5)
knowingly, in and affecting interstate and foreign commerce, recruiting,
enticing, and obtaining by any means a person, knowing that the person had
not attained the age of 18 years and would be caused to engage in a
commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title
18, United States Code, Sections 1591(a)(1) and 2; and
IT APPEARING that Epstein seeks to resolve globally his state and federal criminal
liability and Epstein understands and acknowledges that, in exchange for the benefits
provided by this agreement, he agrees to comply with its terms, including undertaking certain
actions with the State Attorney's Office:
IT APPEARING, after an investigation of the offenses and Epstein's background by
both State and Federal law enforcement agencies, and after due consultation with the State
Attorney's Office, that the interests of the United States, the State of Florida, and the
Defendant will be served by the following procedure;
THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for
the Southern District of Florida, prosecution in this District for these offenses shall be
deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the
following conditions and the requirements of this Agreement set forth below.
If the United States Attorney should determine, based on reliable evidence, that,
during the period of the Agreement, Epstein willfully violated any of the conditions of this
Agreement, then the United States Attorney may, within ninety (90) days following the
expiration of the term of home confinement discussed below, provide Epstein with timely
notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its
prosecution on any offense within sixty (60) days' of giving notice of the violation. Any
notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the
United States learning of facts which may provide a basis for a determination of a breach of
the Agreement.
After timely fulfilling all the terms and conditions of the Agreement, no prosecution
for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have
been the subject of the joint investigation by the Federal Bureau of Investigation and the
United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury
investigation will be instituted in this District, and the charges against Epstein if any, will be
dismissed.
Page 2 of 7
EFTA00011389

=== Page 5 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 4 of 15
Terms of the Agreement:
1.
Epstein shall plead guilty (not nolo contendere) to the Indictment as
currently pending against him in the 15th Judicial Circuit in and for
Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging
one (1) count of solicitation of prostitution, in violation of FL Stat. §
796.07. In addition, Epstein shall plead guilty to an Information filed
by the State Attorney's Office charging Epstein with an offense that
requires him to register as a sex offender, that is, the solicitation of
minors to engage in prostitution, in violation of Florida Statutes Section
796.03;
2.
Epstein shall make a binding recommendation that the Court impose a
thirty (30) month sentence to be divided as follows:
(a)
Epstein shall be sentenced to consecutive terms of twelve (12)
months and six (6) months in county jail for all charges, without
any opportunity for withholding adjudication or sentencing, and
without probation or community control in lieu of
imprisonment; and
(b)
Epstein shall be sentenced to a term of twelve (12) months of
community control consecutive to his two terms in county jail
as described in Term 2(a), supra.
3.
This agreement is contingent upon a Judge of the 15th Judicial Circuit
accepting and executing the sentence agreed upon between the State
Attorney's Office and Epstein, the details of which are set forth in this
agreement.
4.
The terms contained in paragraphs 1 and 2, supra, do not foreclose
Epstein and the State Attorney's Office from agreeing to recommend
any additional charge(s) or any additional term(s) of probation and/or
incarceration.
5.
Epstein shall waive all challenges to the Information filed by the State
Attorney's Office and shall waive the right to appeal his conviction and
sentence, except a sentence that exceeds what is set forth in paragraph
(2), supra.
6.
Epstein shall provide to the U.S. Attorney's Office copies of all
Page 3 of 7
EFTA00011390

=== Page 6 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 5 of 15
proposed agreements with the State Attorney's Office prior to entering
into those agreements.
7.
The United States shall provide Epstein's attorneys with a list of
individuals whom it has identified as victims, as defined in 18 U.S.C.
§ 2255, after Epstein has signed this agreement and been sentenced.
Upon the execution of this agreement, the United States, in consultation
with and subject to the good faith approval of Epstein's counsel, shall
select an attorney representative for these persons, who shall be paid for
by Epstein. Epstein's counsel may contact the identified individuals
through that representative.
8.
If any of the individuals referred to in paragraph (7), supra, elects to
file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the
jurisdiction of the United States District Court for the Southern District
of Florida over his person and/or the subject matter, and Epstein waives
his right to contest liability and also waives his right to contest damages
up to an amount as agreed to between the identified individual and
Epstein, so long as the identified individual elects to proceed
exclusively under 18 U.S.C. § 2255, and agrees to waive any other
claim for damages, whether pursuant to state, federal, or common law.
Notwithstanding this waiver, as to those individuals whose names
appear on the list provided by the United States, Epstein's signature on
this agreement, his waivers and failures to contest liability and such
damages in any suit are not to be construed as an admission of any
criminal or civil liability.
9.
Epstein's signature on this agreement also is not to be construed as an
admission of civil or criminal liability or a waiver of any jurisdictional
or other defense as to any person whose name does not appear on the
list provided by the United States.
10.
Except as to those individuals who elect to proceed exclusively under
18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's
signature on this agreement, nor its terms, nor any resulting waivers or
settlements by Epstein are to be construed as admissions or evidence of
civil or criminal liability or a waiver of any jurisdictional or other
defense as to any person, whether or not her name appears on the list
provided by the United States.
11.
Epstein shall use his best efforts to enter his guilty plea and be
Page 4 of 7
EFTA00011391

=== Page 7 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 6 of 15
sentenced not later than October 26, 2007. The United States has no
objection to Epstein self-reporting to begin serving his sentence not
later than January 4, 2008.
12.
Epstein agrees that he will not be afforded any benefits with respect to
gain time, other than the rights, opportunities, and benefits as any other
inmate, including but not limited to, eligibility for gain time credit
based on standard rules and regulations that apply in the State of
Florida. At the United States' request, Epstein agrees to provide an
accounting of the gain time he earned during his period of
incarceration.
13.
The parties anticipate that this agreement will not be made part of any
public record. If the United States receives a Freedom of Information
Act request or any compulsory process commanding the disclosure of
the agreement, it will provide notice to Epstein before making that
disclosure.
Epstein understands that the United States Attorney has no authority to require the
State Attorney's Office to abide by any terms of this agreement. Epstein understands that
it is his obligation to undertake discussions with the State Attorney's Office and to use his
best efforts to ensure compliance with these procedures, which compliance will be necessary
to satisfy the United States' interest. Epstein also understands that it is his obligation to use
his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding
recommendation regarding the sentence to be imposed, and understands that the failure to
do so will be a breach of the agreement.
In consideration of Epstein's agreement to plead guilty and to provide compensation
in the manner described above, if Epstein successfully fulfills all of the terms and conditions
of this agreement, the United States also agrees that it will not institute any criminal charges
against any potential co-conspirators of Epstein, including but not limited to
Further, upon execution of this
agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury
investigation will be suspended, and all pending federal Grand Jury subpoenas will be held
in abeyance unless and until the defendant violates any term of this agreement. The
defendant likewise agrees to withdraw his pending motion to intervene and to quash certain
grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence
requested by or directly related to the grand jury subpoenas that have been issued, and
including certain computer equipment, inviolate until all of the terms of this agreement have
been satisfied. Upon the successful completion of the terms of this agreement, all
outstanding grand jury subpoenas shall be deemed withdrawn.
Page 5 of 7
EFTA00011392

=== Page 8 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 7 of 15
By signing this agreement, Epstein asserts and certifies that each of these terms is
material to this agreement and is supported by independent consideration and that a breach
of any one of these conditions allows the United States to elect to terminate the agreement
and to investigate and prosecute Epstein and any other individual or entity for any and all
federal offenses.
By signing this agreement, Epstein asserts and certifies that he is aware of the fact that
the Sixth Amendment to the Constitution of the United States provides that in all criminal
prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further
is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court
may dismiss an indictment, information, or complaint for unnecessary delay in presenting
a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein
hereby requests that the United States Attorney for the Southern District of Florida defer such
prosecution. Epstein agrees and consents that any delay from the date of this Agreement to
the date of initiation of prosecution, as provided for in the terms expressed herein, shall be
deemed to be a necessary delay at his own request, and he hereby waives any defense to such
prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of
the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the
United States to a speedy trial or to bar the prosecution by reason of the running of the statute
of limitations for a period of months equal to the period between the signing of this
agreement and the breach of this agreement as to those offenses that were the subject of the
grand jury's investigation. Epstein further asserts and certifies that he understands that the
Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all
felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees
and consents that, if a prosecution against him is instituted for any offense that was the
subject of the grand jury's investigation, it may be by way of an Information signed and filed
by the United States Attorney, and hereby waives his right to be indicted by a grand jury as
to any such offense.
111
111
111
Page 6 of 7
EFTA00011393

=== Page 9 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 8 of 15
By signing this agreement, Epstein asserts and certifies that the above has been read
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated:
By:
ASSISTANT U.S. ATTORNEY
Dated: 9/24/07
S
Dated:
GERALD LEFCOURT, ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated:
LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
Page 7 of 7
EFTA00011394

=== Page 10 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 9 of 15
By signing this agreement, Epstein asserts and certifies that the above has been read
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated:
By:
ASSISTANT U.S. ATTORNEY
Dated:
JEFFREY EPSTEIN
Dated: 9/24/07
LEFCOURT/ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated:
LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
Page 7 of 7
EFTA00011395

=== Page 11 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 10 of 15
By signing this agreement, Epstein asserts and certifies that the above has been read
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated:
By:
ASSISTANT U.S. ATTORNEY
Dated:
JEFFREY EPSTEIN
Dated:
GERALD LEFCOURT, ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated: 9-24-07
LILLY ANN SANGHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
Page 7 of 7
EFTA00011396

=== Page 12 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 11 of 15
IN RE:
INVESTIGATION OF
JEFFREY EPSTEIN
/
ADDENDUM TO THE NON-PROSECUTION AGREEMENT
IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7
of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as
follows:
7A.
The United States has the right to assign to an independent third-party the responsibility
for consulting with and, subject to the good faith approval of Epstein's counsel, selecting
the attorney representative for the individuals identified under the Agreement. If the
United States elects to assign this responsibility to an independent third-party, both the
United States and Epstein retain the right to make good faith objections to the attorney
representative suggested by the independent third-party prior to the final designation of
the attorney representative.
7B.
The parties will jointly prepare a short written submission to the independent third-party
regarding the role of the attorney representative and regarding Epstein's Agreement to
pay such attorney representative his or her regular customary hourly rate for representing
such victims subject to the provisions of paragraph C, infra.
7C.
Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney
representative selected by the independent third party. This provision, however, shall not
obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus,
If after consideration of potential settlements, an attorney representative elects to file a
contested lawsuit pursuant to 18 U.S.C. $ 2255 or elects to pursue any other contested
remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney
representative, as opposed to any statutory or other obligations to pay reasonable
attorneys fees and costs such as those contained in $ 2255 to bear the costs of the attorney
representative, shall cease.
EFTA00011397

=== Page 13 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 12 of 15
By signing this Addendum, Epstein asserts and certifies that the above has been read and
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated: 10/30/07
ASSISTANT U.S. ATTORNEY
Dated: 10/29/07
D SEFFREY EPSTEIN
Dated:
GERALD LEFCOURT, ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated:
LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
EFTA00011398

=== Page 14 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 13 of 15
By signing this Addendum, Epstein asserts and certifies that the above has been read and
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated: 10/30/07
ASSISTANT U.S. ATTORNEY
Dated:
JEFFREY EPSTEIN
Dated: 10/29/07
GERALD LEFCOURT ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated:
LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
EFTA00011399

=== Page 15 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 14 of 15
By signing this Addendum, Epstein asserts and certifies that the above has been read and
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated: 10/30/07
ASSISTANT U.S. ATTORNEY
Dated:
JEFFREY EPSTEIN
Dated:
GERALD LEFCOURT, ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated: 10-29-07
8666 LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
EFTA00011400

=== Page 16 ===
Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 15 of 15
Dac-07-07 04:55pm From-Fowlar-White Burnett
3057829201
T-266 P.003/004 F-276
Affirmation
I, Jeffrey E. Epstain do hereby re-affirm the Non-Proscoution Agreement and Addendure to
same dated October 30, 2007.
Juliney x E. Epstein
12/7/04
Date
EFTA00011401


c1: EFTA00010261
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00010261.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Gloria Allred
To:
)"
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of
Epstein. She is willing to fly to New York for the victim meeting on Oct. 23. May I call you
at 5:45 P.M. to discuss ?
Date: Wed, 23 Oct 2019 16:00:28 +0000
Inline-Images: image001.jpg; image002.png; image003.png; image004.jpg; image005.png
Good. Thanks. I am in suite 607 at 305 Broadway.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
ALLRED. MAROKO & GOLDBERG
2019
Best Lawyers
Martindale-Hubbell"
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
From:
Sent: Wednesday, October 23, 2019 8:55 AM
To: Gloria Allred
Cc:
is
Subject: Re: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to
New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria we were slightly delayed by questions but are heading over now
Sent from my iPhone
On Oct 23, 2019, at 08:57, Gloria Allred
wrote:
I will not have a means to communicate with you after 9:30 this morning, because I will be at the F.B.I. Victim Services
meeting and they will take my phone. Would you please respond to my message below prior to that time in order that I
may know the plan for meeting with
and me today?
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image005.jpg>
EFTA00010261

=== Page 2 ===
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
From: Gloria Allred
Sent: Tuesday, October 22, 2019 8:26 PM
To:
Cc:
is
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Is there a place at the FBI for you to interview
at the end of the meeting with Victim Services ? I am on a tight
schedule tomorrow. Please advise if you want to interview her there at 11:A.M or 11:30.at the end of their meeting or
do wish to use my office at 305 Broadway? I need to leave the interview with her by 12:30. I must take the 2P.M. train to
D.C.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
AGURED
Best Lawyers
AV\PREEMINENT
From:
Sent: Tuesday, October 22, 2019 1:08 PM
To: Gloria Allred
Cc:
is
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gloria Allred
Sent: Tuesday, October 22, 2019 4:03 PM
To:
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
EFTA00010262

=== Page 3 ===
I have asked her when we can reschedule, but I do not have an answer yet.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image009.jpg>
<image010.png>
From:
Sent: Tuesday, October 22, 2019 11:54 AM
To: Gloria Allred
Cc:
is
Subject: Re: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria,
Is
still available for our 4pm call, or do we need to reschedule?
Thanks,
On Oct 22, 2019, at 12:26 PM,
)
wrote:
Ok thanks, please keep us posted. We are happy to accommodate
schedule.
And yes, we can speak with
at your office from noon to 1pm tomorrow.
will be the AUSA
handling that meeting.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gloria Allred
Sent: Tuesday, October 22, 2019 12:24 PM
To:
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to
fly to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
EFTA00010263

=== Page 4 ===
Just a heads up. I think she is needing to reschedule and is cancelling for today. I will let you know a.s.a.p. or by 2P.M.
at the latest. Sorry. Also, re
for tomorrow.can you speak to her from noon to 1 P.M. at my office at 305
Broadway? I need to leave at 1P.M. to catch the train to D.C.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image003.jpg>
<image004.png>
From:
Sent: Tuesday, October 22, 2019 8:19 AM
To: Gloria Allred
Cc:
is
is
(NY) (FBI)
Subject: Re: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to
fly to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Hi Gloria,
We are find with a conference call this afternoon if that is ok with your client. We can use the below dial-in:
Passcode
And your proposed time for
interview works on our end.
Thanks,
On Oct 21, 2019, at 8:11 PM, Gloria Allred
wrote:
I have 2 questions. First, would it be o.k. with all of you if we did the call with
tomorrow at 4P.M. e.s.t as a
conference call rather than as a Skype call? We will be in at least 4 different locations and I think it will be easier if we
did it that way. If so, please send us the number to dial. Daniel from my CO counsel Marianne Wang's office will also
be joining us on the call. Also ,re
my client who is flying in for victim services will be happy to speak with you,
but I have a very tight schedule on Wednesday, because I need to be on a 1 or at the latest 2 P.M. train to D.C. that
day. Could we have the meeting from noon to 1P.M.? My office is only one block away from the FBI meeting.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.jpg>
<image002.png>
EFTA00010264

=== Page 5 ===
From:
Sent: Monday, October 21, 2019 6:40 AM
To: Gloria Allred
i
Cc:
is
(NY) (FBI)
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to
fly to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria,
We will make ourselves available to meet with your new client on 10/23. Because the victim meeting is being run by
the FBI, their victim services folks are handling travel logistics. I'm cc'ing
who should be able to
hopefully help coordinate travel. Would you please provide
with your new client's name as it appears on her
ID, date of birth, email address, and phone number?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gloria Allred
Sent: Friday, October 18, 2019 5:02 PM
To:
Cc:
Subject: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image003.jpg>
<image004.png>
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED
EFTA00010265

=== Page 6 ===
THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED
THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
EFTA00010266


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=== Page 1 ===
From:
To:
'Acosta, Alex (USAFLS)"
<AAcosta@usa.doj.gov>
Cc:
Subject: Article about Epstein in today's New York magazine
Date: Mon, 10 Dec 2007 16:07:37 +0000
Importance: Normal
http://nymag.com/news/features/41826/
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
EFTA00013715


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-Marra/Johnson
IN RE JANE DOES 1 AND 2
/
ORDER TO PRODUCE AND PROTECTIVE ORDER
THIS CAUSE came before the Court on the Petitioners' Motion seeking the
production of the Non-Prosecution Agreement between the United States Attorney's
Office for the Southern District of Florida (hereinafter "USAO") and Jeffrey Epstein.
After consideration of the Motion, the arguments of the parties, and the record, it is
ORDERED AND ADJUDGED that the Petitioners' Motion is GRANTED.
THE COURT ORDERS that the Non-Prosecution Agreement, including any
modifications and addenda thereto, shall be produced in accordance with the following
procedures:
(a)
The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as "the
Agreement"), to the attorneys for the Petitioners.
(b)
The Petitioners and their attorneys shall not disclose the Agreement
or its terms to any third party absent further court order, following notice to and an
opportunity for Jeffrey Epstein's counsel to be heard.
EFTA00014068

=== Page 2 ===
(c)
Prior to producing the documents to Petitioners' counsel, a copy of
this Order must be provided to counsel and their clients, who must review and
acknowledge their
receipt of and agreement to abide by the terms of this Order, and who must provide a
copy of that acknowledgment to the USAO.
(d)
If any individuals who have been identified by the USAO as victims
of Jeffrey Epstein and/or any attorney(s) for those individuals request the opportunity to
review the Agreement, then the USAO shall produce the Agreement to those individuals,
so long as those individuals also agree that they shall not disclose the Agreement or its
terms to any third party absent further court order, following notice to and an opportunity
for Jeffrey Epstein's counsel to be heard
(e)
Prior to producing the documents to any other individuals who have
been identified by the USAO as victims of Jeffrey Epstein and/or any attorney(s) for
those individuals, a copy of this Order must be provided to said individuals, who must
review and acknowledge their receipt of and agreement to abide by the terms of this
Order, and who must provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Florida, on this
day of August, 2008.
KENNETH A. MARRA
UNITED STATES DISTRICT JUDGE
Copies furnished to:
EFTA00014069

=== Page 3 ===
All counsel of record
By signing below, I certify that I have reviewed and agree to be bound by the terms of this
Order.
Dated:
Signed by:
Printed Name:
EFTA00014070


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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From:
Date: November 11, 2021
Re:
United States V. Ghislaine Maxwell
Court Docket No:
20 Cr. 330 (AJN)
USAO No:
2018R01618
Witness Name:
Witness DOB:
(Name/DOB as printed here will be forwarded to travel agency and then to TSA and must
exactly match the witness's driver's license or other travel ID or TSA will not permit the
witness to fly.)
Witness Address:
Witness TelNos (mobile):
Witness e-mail:
Witness Needed to Appear in SDNY on
Date: December 1, 2021
Time: 2 p.m.
Witness Needed to Appear for:
Trial (X)
Date: December 1, 2021
Grand Jury ( )
Date:
Trial/GJ Prep ()
Date:
Estimated Dates Witness will Arrive: December 1, 2021
Depart: December 3, 2021 (evening)
Is the person a Fact Witness and not an Expert Witness?
(Yes/No): Yes
Current Federal Civilian or Military Employee?
(Yes/No): No
Is the Witness Facing Criminal Charges?
(Yes/No): No
Does the Witness Reside Outside the Continental United States?
(Yes/No): No
Is this Witness a Victim-Witness?
(Yes/No): No
Hotel Required?
(Yes/No): Yes
Has the Witness advised you of any unusual travel expenses?
(Yes/No): No
Unusual expenses of fact witnesses can include
special travel arrangements
care for dependent child or incapacitated family member left at home
rev. 2019.11.19
EFTA00010176

=== Page 2 ===
kennel fees for pets
necessary travel companion
extra baggage (more than one bag)
Please describe the unusual expense:
For Victim-Witness Coordinator:
1. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW
is apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should
be used.
For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to
court/GJ testimony.
Witnesses may only be brought in under the FEWS appropriation for grand jury testimony that
has been scheduled and where the witness is expected to testify before the grand jury; court
testimony; or preparation for same. Any other witness travel, e.g., for investigative interviews,
must be covered by the investigating component from litigative funds. See Ed Tyrrell.
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
EFTA00010177


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=== Page 1 ===
From:
To:
Subject: RE: Grand Jury Return - US V. Maxwell, S1 20 Cr. 330 (AJN)
Date: Fri, 10 Jul 2020 13:20:22 +0000
Attachments: Maxwell_Superseding_Indictment_ - S1_20_Cr_330_(AJN).pdf
Inline-Images: image001.png
Good morning,
This superseding indictment does not appear to have been docketed on ECF. Would it be possible to please docket it
today so that the Court and the defendant have notice of the new indictment before next week's arraignment?
I have attached a color scan of the signed indictment, which can be filed.
Thank you,
From:
Sent: Wednesday, July 8, 2020 12:28 PM
To:
Cc:
Subject: Grand Jury Return - US V. Maxwell, S1 20 Cr. 330 (AJN)
Good afternoon,
Attached is the grand jury return for US V. Maxwell, which was previously wheeled out to Judge Nathan in Manhattan. The
superseding indictment is unsealed. There are no warrants for this matter.
Best Regards,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
EFTA00010965

=== Page 2 ===

=== Page 3 ===


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: ESI review -- Epstein investigation
Date: Tue, 10 Mar 2020 22:28:38 +0000
Thanks, that would be great. Would 10:30 work tomorrow morning?
From:
(USANYS)
Sent: Tuesday, March 10, 2020 6:20 PM
To:
Subject: RE: ESI review -- Epstein investigation
Sure, I'm generally around tomorrow except for a moot at 2.
From:
Sent: Tuesday, March 10, 2020 4:07 PM
To:
(USANYS)
Subject: ESI review -- Epstein investigation
Hi
I question has come up during our review of ESI in the Epstein investigation, and the PC chiefs asked us to seek guidance
from appeals. Do you have a few minutes tomorrow or Thursday for a few questions?
Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00011357


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=== Page 1 ===
From: "KATHERINE W. EZELL"
To:
(USAFLS)"
Subject: RE: Epstein Items
Date: Wed, 17 Sep 2008 22:09:11 +0000
Importance: Normal
Thank you,
We are actually going Friday, but we will give them your regards and those of the agents. I wanted to let
you know that Bob heard your voice message and forwarded it to me. I had already told him that we had spoken, that you
were writing a letter, which I would mirror, etc. To my knowledge he has not heard from Roy Black and Tien. Thanks for all
the help. Kathy
From:
.
(USAFLS) [mailto:
Sent: Wednesday, September 17, 2008 4:29 PM
To: KATHERINE W. EZELL; MERCEDES C. ESTRADA
Subject: Epstein Items
Hi Katherine and Mercy:
I have attached a draft letter to the Florida Bar for your review along with the Non-Prosecution Agreement and
Addendum.
Can you let Amy know that Special Agent
is sending the unredacted documents that she
requested by Federal Express tonight. They will be addressed to Katherine and will arrive tomorrow.
Please let me know if you need anything else. (I will turn my attention to the Victim Notification Log right now
and get that to you in a half-hour.) And please give my regards, and the regards of
and
to the
,
victims with whom you are meeting tomorrow.
Thank you.
<<Epstein NonProsecution Agrmt W Addendum.pdf>>
<<Florida Bar Ltr re Ethics Opinion.pdf>>
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
EFTA00013954


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=== Page 1 ===
From:
To:
Subject: RE: Epstein
Date: Mon, 05 Nov 2007 20:52:16 +0000
Importance: Normal
Thanks. I haven't heard from Jay yet.
From:
Sent: Monday, November 05, 2007 3:52 PM
To:
Subject: Epstein
Hi Jeff - Another girl just called FBI after being approached by private investigators for Epstein.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
EFTA00013526


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=== Page 1 ===
From:
"
)"
To:
"
(USANYS)"
Cc:
"
(USANYS)"
)"
=
Bcc: "USAHUB-USAJournal111"
Subject: Re: Epstein SW returns
Date: Mon, 12 Oct 2020 16:52:16 +0000
Embedded: Re:_Epstein_SW_returns.msg
Sender:
Subject: Re: Epstein SW returns
Message-Id: <3430E72C-113B-4F38-AB40-C13D5359BBCB@usa.doj.gov>
To:
Cc:
Cc:
EFTA00013250


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=== Page 1 ===
Event: Epstein/call in from
Start Date: 2008-06-13 14:00:00 +0000
End Date: 2008-06-13 14:30:00 +0000
Organizer:
Location:
ofc.
Class: X-PERSONAL
Date Created: 2017-04-04 01:32:47 +0000
Date Modified: 2017-04-04 01:32:47 +0000
Priority: 5
DTSTAMP: 2008-06-11 15:27:38 +0000
Attendee:
When: Friday, June 13, 2008 10:00 AM-10:30 AM (GMT-05:00) Eastern Time (US & Canada).
Where:
ofc.
you can participate by phone. Let me know best number, Thanks,
Original Message
From:
To:
Cc:
Sent: Wed Jun 11 10:29:23 2008
Subject: RE: Epstein
Spoke with
Everyone is good for 10:00 this Friday morning.
will be calling
office
From:
Sent: Wednesday, June 11, 2008 10:21 AM
To:
Cc:
Subject: RE: Epstein
EFTA00013985

=== Page 2 ===
I'm available anytime
From:
Sent: Wednesday, June 11, 2008 10:09 AM
To:
Cc:
Subject: RE: Epstein
Absolutely, I'm available from 10 to 11 and after 11 have a conflict.
From:
Sent: Wednesday, June 11, 2008 10:02 AM
To:
Cc:
Subject: Epstein
Would you guys be available Friday morning by telephone to discuss?
EFTA00013986


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Automatic reply: Epstein update
Date: Sat, 10 Aug 2019 13:21:59 +0000
Can you give one of us a call when you get off with
? Thanks
Sent from my iPhone
On Aug 10, 2019, at 8:45 AM,
wrote:
FYI. This is all the information I have- trying to find out more. Will keep you updated.
Sent from my iPhone
Begin forwarded message:
From:
Date: August 10, 2019 at 8:17:53 AM EDT
To:
Subject: FW: Automatic reply: Epstein update
BOP just provided another update- Epstein has passed. I have no additional info. I will push out updates as we
receive.
From:
Sent: Saturday, August 10, 2019 7:52 AM
To:
Subject: Re: Automatic reply: Epstein update
FYI:
The BOP just informed us that Epstein is being taken by ambulance to the hospital from another apparent suicide
attempt- no other information was provided.
They will update us as more info becomes available.
On Aug 10, 2019, at 7:26 AM,
wrote:
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses
may be delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
at
or
EFTA00011505


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=== Page 1 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
04/22/2019 19:25 EDT
Generated By:
Page 1 of 6
Last Name
First Name
DOB
Doc
Document
Date Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
EPSTEIN
JEFFREY
01/20/1953
P
566672615
04/19/2019
*GA
N212JE
O
APIS
PASSENGER
LFPB
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
566672615
04/14/2019
*GA
N212JE
I
A523
APIS
PASSENGER
CUSTOMS
KPBI
TIST
13:08
EPSTEIN
JEFFREY
01/20/1953
P
566672615
04/02/2019
*GA
N212JE
I
A461
APIS
PASSENGER
INS
KTEB
LFPB
18:45
EPSTEIN
JEFFREY
01/20/1953
P
566672615
03/19/2019
*GA
N212JE
o
APIS
PASSENGER
LFPB
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
566672615
03/15/2019
*GA
N212JE
I
A523
APIS
PASSENGER
CUSTOMS
KPBI
TIST
EDWARD
17:34
EPSTEIN
JEFFREY
01/20/1953
P
469911707
03/14/2019
*GA
N212JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
02/19/2019
*GA
N212JE
I
A523
APIS
PASSENGER
CUSTOMS
KPBI
MDPP
EDWARD
16:41
EPSTEIN
JEFFREY
01/20/1953
P
469911707
02/19/2019
*GA
N212JE
o
APIS
PASSENGER
MDPP
TIST
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
02/08/2019
*GA
N212JE
I
A523
APIS
PASSENGER
CUSTOMS
KPBI
TIST
16:44
EPSTEIN
JEFFREY
01/20/1953
P
469911707
02/08/2019
*GA
N212JE
I
APIS
PASSENGER
KPBI
TIST
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
01/30/2019
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
KTEB
LFPB
12:56
EPSTEIN
JEFFREY
01/20/1953
P
469911707
01/22/2019
*GA
N212JE
O
APIS
PASSENGER
LFPB
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
01/16/2019
*GA
N212JE
I
A523
APIS
PASSENGER
CUSTOMS
KPBI
TIST
17:11
EPSTEIN
JEFFREY
01/20/1953
P
469911707
01/08/2019
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
KTEB
TIST
15:02
EPSTEIN
JEFFREY
01/20/1953
P
469911707
01/06/2019
*GA
N212JE
O
APIS
PASSENGER
TIST
KBCT
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
12/14/2018
*GA
N212JE
I
A523
APIS
PASSENGER
CUSTOMS
KPBI
TIST
08:49
EPSTEIN
JEFFREY
01/20/1953
P
469911707
12/14/2018
*GA
N212JE
O
APIS
PASSENGER
KPBI
TIST
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
11/28/2018
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
KTEB
TIST
15:27
EPSTEIN
JEFFREY
01/20/1953
P
469911707
11/28/2018
*GA
N212JE
O
APIS
PASSENGER
KTEB
TIST
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
11/25/2018
*GA
N212JE
O
APIS
PASSENGER
TIST
KBCT
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
11/24/2018
*GA
N212JE
O
APIS
PASSENGER
TIST
KBCT
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
11/11/2018
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
KTEB
LFPB
08:24
For Official Use Only / Law Enforcement Sensitive
EFTA00010345

=== Page 2 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS Person Encounter List
04/22/2019 19:25 EDT
Generated By:
Page 2 of 6
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
EPSTEIN
JEFFREY
01/20/1953
P
469911707
11/02/2018
*GA
N212JE
O
APIS
PASSENGER
LFPB
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
10/30/2018
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
KTEB
TIST
EDWARD
15:36
EPSTEIN
JEFFREY
01/20/1953
P
469911707
10/28/2018
*GA
N212JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
10/11/2018
*GA
N212JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
10/10/2018
*GA
N212JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
09/30/2018
*GA
N212JE
O
APIS
PASSENGER
LFPB
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
09/22/2018
*GA
N120JE
I
A10D
APIS
PASSENGER
INS
KTEB
TIST
EDWARD
17:52
EPSTEIN
JEFFREY
01/20/1953
P
469911707
09/22/2018
*GA
N120JE
I
APIS
PASSENGER
KTEB
TIST
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
09/20/2018
*GA
N120JE
o
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
09/13/2018
*GA
N120JE
I
A10D
APIS
PASSENGER
INS
KTEB
LFPB
18:11
EPSTEIN
JEFFREY
01/20/1953
P
469911707
09/06/2018
*GA
N120JE
O
APIS
PASSENGER
LFPB
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
08/29/2018
*GA
N120JE
I
A523
APIS
PASSENGER
CUSTOMS
KPBI
TIST
EDWARD
17:44
EPSTEIN
JEFFREY
01/20/1953
P
469911707
08/25/2018
*GA
N120JE
O
APIS
PASSENGER
TIST
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
08/15/2018
*GA
N120JE
I
A10D
APIS
PASSENGER
KTEB
TIST
22:03
EPSTEIN
JEFFREY
01/20/1953
P
469911707
08/14/2018
*GA
N120JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
08/06/2018
*GA
N120JE
I
A10D
APIS
PASSENGER
INS
KTEB
TIST
EDWARD
21:13
EPSTEIN
JEFFREY
01/20/1953
P
469911707
08/05/2018
*GA
N120JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
07/29/2018
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
KTEB
LFPB
13:18
EPSTEIN
JEFFREY
01/20/1953
P
469911707
07/21/2018
*GA
N212JE
O
APIS
PASSENGER
LFPB
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
07/10/2018
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
KTEB
TIST
17:48
EPSTEIN
JEFFREY
01/20/1953
P
469911707
07/07/2018
*GA
N212JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
06/27/2018
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
KTEB
LFPB
11:47
EPSTEIN
JEFFREY
01/20/1953
P
469911707
06/20/2018
*GA
N212JE
O
APIS
PASSENGER
LFPB
KTEB
00:00
For Official Use Only / Law Enforcement Sensitive
EFTA00010346

=== Page 3 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS Person Encounter List
04/22/2019 19:25 EDT
Generated By:
Page 3 of 6
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
EPSTEIN
JEFFREY
01/20/1953
P
547017616
06/15/2018
*GA
N212JE
I
A523
APIS
PASSENGER
CUSTOMS
KPBI
TIST
EDWARD
19:11
EPSTEIN
JEFFREY
01/20/1953
P
469911707
06/15/2018
*GA
N212JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
06/02/2018
*GA
N212JE
I
A47E
APIS
PASSENGER
INS
KISP
TIST
EDWARD
21:21
EPSTEIN
JEFFREY
01/20/1953
P
469911707
06/02/2018
*GA
N212JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
05/27/2018
*GA
N212JE
I
A523
APIS
PASSENGER
KPBI
TIST
EDWARD
18:07
EPSTEIN
JEFFREY
01/20/1953
P
469911707
05/22/2018
*GA
N212JE
I
A47E
APIS
PASSENGER
KISP
LFPB
15:42
EPSTEIN
JEFFREY
01/20/1953
P
469911707
05/13/2018
*GA
N212JE
0
APIS
PASSENGER
LFPB
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
04/27/2018
*GA
N120JE
I
A523
APIS
PASSENGER
CUSTOMS
KPBI
TIST
EDWARD
19:57
EPSTEIN
JEFFREY
01/20/1953
P
469911707
04/27/2018
*GA
N120JE
O
APIS
PASSENGER
TIST
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
04/20/2018
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
KTEB
TIST
22:03
EPSTEIN
JEFFREY
01/20/1953
P
469911707
04/20/2018
*GA
N212JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
04/09/2018
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
KTEB
LFPB
13:22
EPSTEIN
JEFFREY
01/20/1953
P
469911707
03/31/2018
*GA
N212JE
O
APIS
PASSENGER
LFPB
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
03/27/2018
*GA
N212JE
I
A512
APIS
EDWARD
17:39
EPSTEIN
JEFFREY
01/20/1953
P
469911707
03/27/2018
*GA
N212JE
I
APIS
PASSENGER
KPBI
TIST
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
03/13/2018
*GA
N120JE
I
A10D
APIS
PASSENGER
INS
KTEB
LFPB
EDWARD
14:02
EPSTEIN
JEFFREY
01/20/1953
P
469911707
03/08/2018
*GA
N120JE
O
APIS
PASSENGER
LFPB
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
03/03/2018
*GA
N120JE
I
A10D
APIS
PASSENGER
INS
KTEB
TIST
20:36
EPSTEIN
JEFFREY
01/20/1953
P
469911707
03/03/2018
*GA
N120JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
02/21/2018
*GA
N120JE
I
A10D
APIS
PASSENGER
INS
KTEB
TIST
19:53
EPSTEIN
JEFFREY
01/20/1953
P
469911707
02/21/2018
*GA
N120JE
O
APIS
PASSENGER
TIST
KFXE
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
02/07/2018
*GA
N120JE
I
A523
APIS
PASSENGER
CUSTOMS
KPBI
TIST
EDWARD
19:14
EPSTEIN
JEFFREY
01/20/1953
P
469911707
02/07/2018
*GA
N120JE
O
APIS
PASSENGER
TIST
KPBI
00:00
For Official Use Only / Law Enforcement Sensitive
EFTA00010347

=== Page 4 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS Person Encounter List
04/22/2019 19:25 EDT
Generated By:
Page 4 of 6
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
EPSTEIN
JEFFREY
01/20/1953
P
469911707
01/27/2018
*GA
N120JE
I
A10D
APIS
PASSENGER
INS
KTEB
CYYR
16:39
EPSTEIN
JEFFREY
01/20/1953
P
469911707
01/27/2018
*GA
N120JE
I
APIS
PASSENGER
KTEB
CYYR
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
01/21/2018
*GA
N120JE
O
APIS
PASSENGER
LFPB
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
01/20/2018
*GA
N120JE
o
APIS
PASSENGER
LFPB
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
01/16/2018
*GA
N120JE
I
A10D
APIS
PASSENGER
INS
KTEB
TIST
20:06
EPSTEIN
JEFFREY
01/20/1953
P
469911707
01/16/2018
*GA
N120JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
01/07/2018
*GA
N120JE
I
A10D
APIS
PASSENGER
INS
KTEB
TIST
20:08
EPSTEIN
JEFFREY
01/20/1953
P
469911707
01/07/2018
*GA
N120JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
12/20/2017
*GA
N120JE
I
A523
APIS
PASSENGER
CUSTOMS
KPBI
TIST
EDWARD
19:20
EPSTEIN
JEFFREY
01/20/1953
P
469911707
12/20/2017
*GA
N120JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
12/12/2017
*GA
N120JE
I
A10D
APIS
PASSENGER
INS
KTEB
LFPB
16:56
EPSTEIN
JEFFREY
01/20/1953
P
469911707
12/08/2017
*GA
N120JE
O
APIS
PASSENGER
LFPB
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
12/05/2017
*GA
N120JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
11/26/2017
*GA
N120JE
I
A10D
APIS
PASSENGER
KTEB
TIST
EDWARD
20:19
EPSTEIN
JEFFREY
01/20/1953
P
469911707
11/26/2017
*GA
N120JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
11/07/2017
*GA
N120JE
I
A10D
APIS
PASSENGER
INS
KTEB
TIST
21:03
EPSTEIN
JEFFREY
01/20/1953
P
469911707
11/07/2017
*GA
N120JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
11/03/2017
*GA
N120JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
547017616
10/20/2017
*GA
N415LM
I
A10D
APIS
PASSENGER
INS
KTEB
LFPB
EDWARD
09:43
EPSTEIN
JEFFREY
01/20/1953
P
469911707
10/09/2017
*GA
N415LM
O
APIS
PASSENGER
LFPB
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
469911707
10/05/2017
*GA
N415LM
I
A47E
APIS
PASSENGER
INS
KISP
TIST
21:21
EPSTEIN
JEFFREY
01/20/1953
P
469911707
09/13/2017
*GA
N415LM
I
A47E
APIS
PASSENGER
INS
KISP
LFPB
09:07
EPSTEIN
JEFFREY
01/20/1953
P
469911707
09/02/2017
*GA
N415LM
O
APIS
PASSENGER
LFPB
KTEB
00:00
For Official Use Only / Law Enforcement Sensitive
EFTA00010348

=== Page 5 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY DISTON
TECS Person Encounter List
04/22/2019 19:25 EDT
Generated By:
Page 5 of 6
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
EPSTEIN
JEFFREY
01/20/1953
P
547017616
08/29/2017
*GA
N120JE
A514
APIS
EDWARD
08:33
EPSTEIN
JEFFREY
01/20/1953
P
469911707
08/29/2017
*GA
N120JE
I
Name No
APIS
PASSENGER
TEB
XXX
00:00
Name, No
EPSTEIN
JEFFREY
01/20/1953
P
469911707
08/02/2017
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
KTEB
TIST
11:02
EPSTEIN
JEFFREY
01/20/1953
P
547017616
07/20/2017
B
P515
VEHICLE
EDWARD
08:32
EPSTEIN
JEFFREY
01/20/1953
P
469911707
07/20/2017
*GA
N212JE
I
Name No
APIS
PASSENGER
TEB
XXX
00:00
Name, No
EPSTEIN
JEFFREY
01/20/1953
P
469911707
07/16/2017
*GA
N212JE
O
Name No
APIS
PASSENGER
XXX
PBI
00:00
Name, No
EPSTEIN
JEFFREY
01/20/1953
P
469911707
07/11/2017
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
KTEB
LFPB
08:45
EPSTEIN
JEFFREY
01/20/1953
P
469911707
07/02/2017
*GA
N212JE
O
Name No
APIS
PASSENGER
XXX
TEB
00:00
Name, No
EPSTEIN
JEFFREY
01/20/1953
P
469911707
07/01/2017
*GA
N212JE
O
Name No
APIS
PASSENGER
XXX
TEB
00:00
Name, No
Total Number of Records: 100
Legend
Loc
Codes
Value
CYYR
CYYR
TEB
TETERBORO
TIST
TIST
MDPP
MDPP
KTEB
KTEB
PBI
WEST PALM BEACH
KISP
KISP
XXX
UNKNOWN AIRPORT (USED ONLY WHEN THE AIRPORT CODE IS UNKNOWN)
KBCT
KBCT
KFXE
KFXE
LFPB
LFPB
KPBI
KPBI
Doc Type
Codes
Value
P
P - PASSPORT
Site Code
For Official Use Only / Law Enforcement Sensitive
EFTA00010349

=== Page 6 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS - Person Encounter List
04/22/2019 19:25 EDT
Generated By:
Page 6 of 6
Codes
Value
A461
A461 - CBP-TETERBORO, AIRPT HANGER 2
A514
A514 - CBP-ST THOMAS, GAF PREDEPART
A10D
A10D - CBP-TETERBORO, JET AVIATION
A523
A523 - CBP-PALM BEACH, INTERNATIONAL
A512
A512 - CBP-ST THOMAS, VI PREDEPARTURE
P515
P515 - CBP-CYRIL KING GAF, PRE-FLIGHT
A47E
A47E - CBP-LONG ISL, MAC ARTHUR APT
For Official Use Only / Law Enforcement Sensitive
EFTA00010350


c1: EFTA00013631
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00013631.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Re: Epstein
Date: Mon, 10 Dec 2007 15:27:19 +0000
Importance: Normal
Yes
Sent from my BlackBerry Wireless Handheld
Original Message
From:
To:
Sent: Mon Dec 10 10:13:05 2007
Subject: RE: Epstein
Hi
I
I just reviewed it. Are you coming up here today?
Assistant U.S. Attorney
From:
Sent: Monday, December 10, 2007 9:54 AM
To:
Subject: RE: Epstein
Yes. I'm PDF'ing their responses.
From:
Sent: Sunday, December 09, 2007 2:14 PM
To:
Subject: Epstein
Hi
- I haven't heard anything from you or
Did Epstein respond? Am I supposed to do anything? Thank you.
Assistant U.S. Attorney
EFTA00013631


c1: EFTA00013196
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00013196.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
(USANYS)"
Subject: RE: Call tomorrow re Maxwell
Date: Sun, 25 Oct 2020 18:27:16 +0000
Attachments: 2020.10.23,_GM_defense_response_to_Government_letter_re_other_agency_files.pdf
Thanks very much, I'll send a calendar invite for 2pm shortly.
Attached is their Friday evening letter.
From:
(USANYS)
Sent: Sunday, October 25, 2020 2:05 PM
To:
(USANYS)
Cc:
is
is
(USANYS)
Subject: Re: Call tomorrow re Maxwell
2 is good for me.
,
apologies if I missed it, but would you mind circulating the letter? Thanks.
On Oct 25, 2020, at 2:03 PM,
(USANYS)
wrote:
Yes. Subject to
availability would 11 or 2 work?
Sent from my iPhone
On Oct 25, 2020, at 1:39 PM,
)
wrote:
Chiefs,
Would you be available tomorrow for a call with the Maxwell team? We'd like to update you on discovery and discuss
defense's Friday evening letter.
Thanks,
EFTA00013196


c1: EFTA00010724
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00010724.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Chris Dilorio
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Date: Thu, 18 Jul 2019 17:54:54 +0000
Attachments: IMG_7021.jpg
Inline-Images: image.png
Healthcare fraud is pretty serious shit.
What SECURITIES LAWS should be
https://www.law.cornell.edu/uscode/text/18/1347
18 U.S. Code § 1347 - Health care fraud I U.S.
Code | US Law I LII / Legal Information
Institute
to obtain, by means of false or fraudulent pretenses,
representations, or promises, any of the money or property
owned by, or under the custody or control of, any health care
benefit program,
www.law.cornell.edu
EFTA00010724

=== Page 2 ===
Colleran got off pretty easy, eh?
Certainly LOOKS like CRIMINAL fraud and
NOT
CIVIL fraud
Trump:
'acting' Asst DOJ Readler becomes JUDGE Readler just like that
https://en.wikipedia.org/wiki/Chad_Readler
Chad Readler - Wikipedia
August 23, 1972 (age 46) Pontiac, Michigan, U.S.: Education:
University of Michigan (BA, JD): Chad Andrew Readler (born
August 23, 1972) is a United States Circuit Judge of the United
States Court of Appeals for the Sixth Circuit and former Principal
Deputy and former Acting Assistant Attorney General for the
en.wikipedia.org
The criminality associated with this White House is off the charts.
Calk: Lorber
Lorber/Elliman/Icahn: Frost/Honig/Stetson
AND
Alpha Capital: Martin Schlaff: MY CLAIMS
Ladenburg/Gruntal: Refco/Bawag
Also Schlaff AND: Englander/Nordlicht/Kushners
abusive naked shorting to facilitate $$ laundering: Sedona/ Scan Graphics
My claims: NITE/VIRT: Refco on steroids
also CDEL
Frost brings down the WH
Frost/Honig/Stetson: Therapix/FSDDF
Urban: FSDDF/NITE/VIRT
Blackstone: Luckiest fuckers on the Street: Here glitchy glitchy
Epstein: Schwarzman
Epstein: Black
Black/Schwarzman: Kushner (my BX SEC TCR)
SEC: dropped Apollo charges: Avakian/Heiss
SEC NITE/VIRT obstruction: Jay/Sull Crom/Fishman
1MDB: PHUN/Nordlicht/AIPAC: Greek shippers
Economou/EKONOMOU
Bistricers
Feinberg: Danaos
Trump attorney: EKONOMOU
Barr 1MDB waiver: AQR
Cheers!
Follow me on Twitter
I'll follow back
lololol
EFTA00010725

=== Page 3 ===
From: Chris Dilorio
Sent: Saturday, July 13, 2019 7:31 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
More
Trump Ohio fundraiser
Brian Colleran
https://www.cleveland.com/politics/2019/07/donald-trump-coming-to-cleveland-friday-for-fundraiser-at
nursing-home-magnates-house.html
Donald Trump coming to Cleveland Friday for
fundraiser at nursing home magnate's house -
cleveland.com
CLEVELAND, Ohio - Republican President Donald Trump is
visiting Cleveland on Friday for a private fundraiser at the home
of nursing home executive Brian Colleran, sources with
knowledge of the
---
www.cleveland.com
https://www.justice.gov/opa/pr/three-companies-and-their-executives-pay-195-million-resolve-false-claims-act-
allegations
EFTA00010726

=== Page 4 ===
Three Companies and Their Executives Pay $19.5
Million to Resolve False Claims Act Allegations
Pertaining to Rehabilitation Therapy and Hospice
Services
I
OPA | Department of Justice
Ohio based Foundations Health Solutions Inc. (FHS), Olympia Therapy Inc.
(Olympia), and Tridia Hospice Care Inc. (Tridia), and their executives, Brian
Colleran (Colleran) and Daniel Parker (Parker), have agreed to pay
approximately $19.5 million to resolve allegations pertaining to the submission
of false claims for medically unnecessary rehabilitation therapy and hospice
www.justice.gov
Another Honig $$$ laundering shell
Intergetics
Millenium
NMC
Regent
take your pick
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0000072170&owner=exclude&count=40&hidefilings=0
https://www.sec.gov/Archives/edgar/data/72170/000114420410011488/0001144204-10-011488-index.htm
Colleran
https://www.sec.gov/Archives/edgar/data/72170/000114420408023159/0001144204-08-023159-index.htm
Cheers!
Christopher Dilorio
and
From: Chris Dilorio
Sent: Thursday, July 11, 2019 8:07 AM
To:
EFTA00010727

=== Page 5 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
Mr Berman,
Thanks for the shout out, but I'm not a journalist
lololol
Just a very long list of credible information I have provided to the grossly corrupt SEC et al scumbags
Janey, update my various TCR's and derivatives. Separate but related Janey. Separate but related.
Hey, is Jay still working on his NITE/VIRT/Sull Crom disclosures?
https://www.nytimes.com/2019/07/10/business/jeffrey-epstein-net-worth.html
Jeffrey Epstein's Infinite Means' May Be a Mirage
Mr. Epstein, facing sex-trafficking charges, has long been hailed as a financial
wizard. He got rich with the help of two wealthy connections, but there is little
evidence he's a billionaire.
www.nytimes.com
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Monday, July 8, 2019 6:25 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Greetings Grossly corrupt SEC scumbags et al
IMDS: S Florida $$$ laundering shell facilitated by the SEC
Highlighted in my 2013 TCR filed with prestigious Berger Montague
EFTA00010728

=== Page 6 ===
More AML flags than be counted
MASSIVE naked short position
MY claims
SEC cover up. Now, re started so it can be unleashed on the investing public yet again.
Martin Schlaff/Balmore/Alpha Cap
https://www.haaretz.com/israel-news/business/martin-schlaff-is-behind-5-million-investment-in-colpant-
1.5457018
Martin Schlaff: Bag Man
But it gets MUCH better
Graftech
SEC reporting
pronounced "Graft etc"
https://www.sec.gov/Archives/edgar/data/931148/000119312516427770/0001193125-16-427770-index.htm
EDGAR Filing Documents for 0001193125-16-427770
GrafTech Global Enterprises Inc. (Filer) CIK: 0000940404 (see all company filings) IRS No.: 061415602 | State
of Incorp.:DE | Fiscal Year End: 1231 Type: 15-15D | Act
www.sec.gov
https://www.haaretz.com/israel-news/elections/.premium-the-netanyahu-milikowsky-ties-could-be-on-the-
way-to-an-fbi-investigation-1.7090960
The FBI may be about to probe Netanyahu's
ties to cousin Milikowsky
***
www.haaretz.com
Wall Street / CNBC Wiz Karen Finerman
"Save Graft etc"
https://www.sec.gov/Archives/edgar/data/931148/000119312515018174/d857124dex991.htm
EX-99.1 - sec.gov
Exhibit 1 "SAVE GRAFTECH" GROUP NOMINATES FULL SLATE OF SEVEN DIRECTORS TO GRAFTECH BOARD
NEW YORK, January 23, 2015 - Save GrafTech, an investor group led by Nathan Milikowsky, a holder of
over 15 million shares, or over 11.2%, of the common stock of GrafTech International Ltd. (NYSE: GTI), today
sent a letter to the GrafTech Board of Directors disclosing that it has submitted a
www.sec.gov
EFTA00010729

=== Page 7 ===
pg 57 of this SEC reviewed public offering
https://www.sec.gov/Archives/edgar/data/931148/000104746919000874/a2237872zs-1.htm
www.sec.gov
(1) Includes 2,625,000 shares of common stock that the underwriters have the option to purchase from the
selling stockholder. (2) Estimated solely for the purpose of calculating the amount of registration fee in
accordance with Rule 457(c) under the Securities Act of 1933, as amended, based upon the average of the
high and low sales prices of the registrant's common stock as reported by the
www.sec.gov
2018 revenue up 244% vs 2017 due to sharp increase in graphite electrode pricing
BUT, graphite electrode prices rose significantly in 2017
and
FELL in 2018
https://agmetalminer.com/tag/graphite-electrodes/
graphite electrodes Archives - Steel, Aluminum, Copper, Stainless, Rare
Earth, Metal Prices, Forecasting |
MetalMiner
Needle coke, a crude oil derivative, accounts for 40-44% (depending on the year) of the cost to produce
one metric ton of electrodes. Graftech, one of the leaders in graphite electrode production
agmetalminer.com
the Graftech/Graft etc balance sheet is complete fraud as well
insolvent
JP Morgan strikes again
Grossly corrupt SEC "protecting Main Street as usual"
Fraud certainly not limited to the OTCM
Mr Teotia,
congrats on taking Wes Bricker's job
no doubt you're working hard on those KCG 2Q 2017 financials not "published" by Mr Transparency Dougie
Cifu.
Where would a $4 billion+ write down of naked short fails put the NITE/VIRT fraud on the list of egregious
SEC accounting fraud failures?
Top 5?
Let me know if I can help
In furtherance of the conspiracy.
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Wednesday, June 26, 2019 6:07 AM
To: jd@johnnydwyer.net; mmorrison@judicialwatch.org; jfarrell@judicialwatch.org
Subject: Fw: Apollo/ Epstein/Kushner connection
EFTA00010730

=== Page 8 ===
From: Chris Dilorio
Sent: Tuesday, June 25, 2019 2:31 PM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Friday, May 24, 2019 7:27 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Friday, May 24, 2019 7:23 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Getting warmer Ms Strauss
https://www.justice.gov/usao-sdny/pr/bank-ceo-stephen-m-calk-charged-corruptly-soliciting-presidential-
administration
Bank CEO Stephen M. Calk Charged With Corruptly
Soliciting A Presidential Administration Position In
Exchange For Approving $16 Million In Loans | USAO-
SDNY | Department of Justice
Audrey Strauss, the Attorney for the United States, Acting Under Authority
Conferred by 28 U.S.C. § 515, William F. Sweeney Jr., the Assistant Director-in-
EFTA00010731

=== Page 9 ===
Charge of the New York Field Office of the Federal Bureau of Investigation
("FBI"), and Patricia Tarasca, the Special Agent-in-Charge of the New York
5
www.justice.gov
But, this is the beginning of the story
not the end
Calk/Lorber/Elliman: Trump
Lorber: New Valley Corp
https://www.sec.gov/Archives/edgar/data/106374/000095014405003084/g93826e10vk.htm
Apollo Moscow/Kremlin development
AND
Ladenburg Thalman
I asked in previous correspondence:
Does ANYONE believe Frost risked BILLIONS to "MAKE" a few million?
Frost was laundering a few millions.
https://www.barrons.com/articles/sec-charges-phillip-frost-1536608366
SEC Charges Against Phillip Frost Might Just
Be the Tip of the Iceberg
The U.S. Securities and Exchange Commission filed stock fraud
charges late last week against billionaire drug entrepreneur Phillip
Frost and a group of associates, accusing them of making $27
million in pump-and-dump stock schemes
www.barrons.com
Alpha Capital Anstalt Liechtenstein
in my 2013 TCR: Money laundering/Miami based Imaging Diagnostics (see my IMDS e mails)
Bag Men
Also: "Greek Shipping company" FreeSeas (See my FreeSeas TCR)
Despite overwhelming evidence of money laundering, you will find no reference to it in SEC complaints.
https://www.sec.gov/news/press-release/2018-182
SEC.gov | SEC Charges Microcap Fraudsters for Roles in Lucrative Market
Manipulation Schemes
The Securities and Exchange Commission today charged a group of 10 individuals and 10 associated
entities for their participation in long-running fraudulent schemes that generated over $27 million from
EFTA00010732

=== Page 10 ===
unlawful stock sales and caused significant harm to retail investors who were left holding virtually worthless
www.sec.gov
No mention of AML despite glaring red flags
No mention of executing Broker Dealers: Penny stock trading fairies
The SEC has kept Alpha Capital Anstalt up and running so the activity detailed in my complaints can continue.
And it does
https://whalewisdom.com/filer/alpha-capital-anstalt
ALPHA CAPITAL ANSTALT Top Holdings - - WhaleWisdom
Alpha Capital Anstalt is based out of Vaduz Liechtenstein. Whalewisdom has at least 6 13D filings, 158 13G
filings, and 5 Form 4 filings The firm has no submitted 13F filings and does not appear to be an investment
advisor.
whalewisdom.com
Now: Lorber/Calk/Elliman: New Valley: shell
Ladenburg/Frost/Alpha Cap Anstalt $$$ laundering shells
Apollo/Lorber: Moscow/Kremlin "development"
"Tip of the Iceberg" indeed
In furtherance of the conspiracy.
Cheers!
Christopher Dilorio
Whistleblower
From: Chris Dilorio
Sent: Thursday, May 23, 2019 5:59 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
EFTA00010733

=== Page 11 ===
So:
Leon Black/ Apollo/Schwarzman: Trump Kushner
Black/Apollo/Schwarzman: Epstein
Black/Apollo/Schwarzman: Putin/RU
https://www.reuters.com/article/russia-putin-fund-idUSL5E7KG0SI20110916
UPDATE 2-Putin gets SWF, PE backing for
Russia fund
* Apollo's Black shares platform with Putin
www.reuters.com
https://www.swfinstitute.org/news/33645/u-s-treasury-sanctions-russian-direct-investment-fund/amp
Black/Apollo/Schwarzman: money laundering shells
https://www.businessinsider.com/blackstone-dodged-a-bullet-with-knight-capital-2012-8
Blackstone Dodged A Bullet With Knight
Capital - Business Insider
A trader consulted by Business Insider said that Blackstone envied
Knight Capital's market-making team, which executed an average
of more than $20 billion trades last year and is designated market
www.businessinsider.com
https://www.sec.gov/Archives/edgar/data/1082278/000092242313000183/0000922423-13-000183-index.htm
Knight/Trimark/Optimark born out of "worthless paper"/ Russian/US Mafia/ money laundering shell: Ashton
Technologies
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001003740&ovner=exclude&count=40&chidefilings=0
https://ag.ny.gov/press-release/us-attorney-lynch-and-nys-attorney-general-spitzer-announce-20-defendants-
indicted-50
U.s. Attorney Lynch And N.y.s. Attorney General Spitzer Announce 20
Defendants Indicted In $50 Million Boiler Room Stock Fraud Scheme I New
York State Attorney General
LORETTA E. LYNCH, United States Attorney for the Eastern District of New York, ELIOT SPITZER, New York
State Attorney General, BARRY W. MAWN, Assistant Director-in-Charge of the Federal Bureau of
EFTA00010734

=== Page 12 ===
Investigation in New York, and RICHARD H. WALKER, Director of the Division of Enforcement of the
Securities and Exchange Commission, today announced the unsealing of an indictment charging 20
ag.ny.gov
Spitzer taken down by RUSSIAN hooker
https://nypost.com/2016/02/16/spizter-accuser-a-young-jobless-ex-hooker-who-lives-a-life-of-luxury/
Spitzer accuser was a $5K-a-night hooker
who lives life of luxury - New York Post
The Russian vixen who accused Eliot Spitzer of choking her at The
Plaza hotel is a divorced, globe-trotting beauty who once bared
all the dirty details of her life as a $5,000-a-night hooker, The
nypost.com
Any questions?
Cheers traitorous scumbags!
Christopher Dilorio
From: Chris Dilorio
Sent: Sunday, May 19, 2019 8:03 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
I reiterate:
The SEC is a grossly corrupt criminal organization bought and paid for by criminals who threaten the integrity of
our markets to the clear and very egregious detriment of the investing public it is sworn to protect.
http://www.marketrap.com/article/view_article/9152/bernard-madoffthe-mafia-and-the-friends-of-michael-
milken
EFTA00010735

=== Page 13 ===
Bernard Madoff, the Mafia, and the Friends of Michael Milken - Market Rap
- The Investor Empowerment Community
In 2005, Patrick Byrne, the CEO of Overstock.com and future Deep Capture investigative reporter, began a
public crusade against illegal naked short selling (hedge funds and brokers creating phantom stock to
manipulate stock prices down). said, over and over, that the crime was destroying public companies and
had the potential to trigger a systemic meltdown of our financial markets.
www.marketrap.com
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Friday, May 17, 2019 6:22 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Wednesday, May 15, 2019 11:27 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Today (5/15/19) the grossly corrupt scumbags at the SEC approved ANOTHER massive fraud on the investing
public:
https://www.sec.gov/Archives/edgar/data/1665300/999999999519001111/xslEFFECTX01/primary_doc.xml
The "genius f'n quant" AQR/Greek shipping
/Economou/DRYS/ORIG/Astra/Nautilus/Navios/Gerber/AIPAC/Nordlicht/Glass/1MDB/Knitowski/Caneum/Trym
etris/Liquid etc etc etc money laundering shell.
Well done!
BTW, HOW is the George Economou/ Georgios EKONOMOU SEC "investigation" coming along anyway?
https://en.wikipedia.org/wiki/George_Economou_(shipbuilder)
EFTA00010736

=== Page 14 ===
George Economou (shipbuilder) - Wikipedia
George Economou or Georgios Ekonomou (Гешруюс Olkovójiou, born 1953) is a Greek billionaire
shipowner, CEO of DryShips Inc. and Ocean Rig, and the owner of Cardiff Marine.Economou owns oil
tankers as well as dry bulk ships and manages them through Cardiff Marine. He was on the Forbes
Magazines list of the world's billionaires on place 707.
en.wikipedia.org
What a coincidence:
https://www.vanityfair.com/nevs/2018/03/andrew-ekonomou-donald-trump-legal-team/amp
Trump's Last Line of Defense Against Mueller
Is an Obscure Medieval Historian
Andrew Ekonomou had a "mid-life crisis" and became an expert
on Byzantium. Now he's helping lead the president's legal team in
the Russia investigation.
www.vanityfair.com
Dude is DEFINITELY not getting the attention he deserves
Then again,
WHO actually believes Marc Bistricer of Toronto Canada was INVESTING in the $$$ laundering Ekonomou
shell known as DryShips?
https://seekingalpha.com/article/4096781-strong-court-case-dryships-kalani
Very Strong Court Case Against DryShips And
Kalani - DryShips Inc. (NASDAQ:DRYS)
I
Seeking Alpha - Stock Market Insights
I
Seeking Alpha
Source: rgrdlaw.com (court document) In 2012, DRYS generated
$1.23 billion in total revenue, yet posted a $246 million loss. In
fact, the company has been posting losses every year for the last
seekingalpha.com
"Charity not the motive"
https://www.tradewindsnews.com/legal/1738610/kalani-claims-charity-not-a-motive-for-dryships-aid
EFTA00010737

=== Page 15 ===
Kalani claims charity not a motive for DryShips
aid I TradeWinds
Kalani claims charity not a motive for DryShips aid Marc Bistricer-
led investment house says it had risk and profit in mind lending
to George Economou's struggling public company, not attempt to
www.tradewindsnews.com
The Toronto connection runs MUCH deeper though
The overlap with AQR blank check shells and Polar Asset Mgmt Toronto
The Toronto based Bistricer and EKONOMOU
Bistricers in New Jersey TOO!
AND
DAVID Bistricer happens to be a real estate developer
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001649096&owner=exclude&count=40&hidefilings=0
1 Bistricer/Clipper "investor"
Toronto based C I Investments
https://www.sec.gov/Archives/edgar/data/1649096/000116364819000009/0001163648-19-000009-index.htm
Check out this Reg D offering Bistricer/ Clipper did in Jan 2016
https://www.sec.gov/Archives/edgar/data/1649096/000161577416004014/xslFormDX01/primary_doc.xmi
$130,000 Reg D offering for this Bistricer/Clipper publicly traded "real estate" company was done with an
Atlanta based firm called H&L Equities
Atlanta is home of the obscure Trump Russia Counsel Andrew EKONOMOU
Nothing to see here.
Of Course, then there's the Hail Mary pass Kushner threw on his Toronto based Brookfield deal for 666 5th
Avenue
https://www.thestar.com/news/world/2019/03/12/toronto-based-brookfield-faces-scrutiny-from-democrats-
over-deal-with-kushner-company.html
Toronto-based Brookfield faces scrutiny from
Democrats over deal with Kushner company
|
The Star
The real estate giant says politics were not at all involved in its
decision to acquire a New York office tower from the family of
Jared Kushner, President Donald Trump's son-in-law and senior
aide.
www.thestar.com
EFTA00010738

=== Page 16 ===
which was brokered by Apollo/Epstein Degenerate Black/Harris/Rowan
https://therealdeal.com/2018/11/15/brookfield-turns-to-apollo-for-666-fifth-financing/
666 Fifth | Brookfield | Apollo Global
Management
Private equity company Apollo Global Management is funding
Brookfield Property Partners' redevelopment of 666 Fifth Avenue
with a $300 million-plus mezzanine loan, sources told The Real
Deal
therealdeal.com
Apollo and other Kushner financing pal Blackstone just happen to be BOTH granted free reign on the US
insurance/annuity industry.
Crazy shit huh?
Greek shipping Bag man Georgios Ekonomou meets Jared Kushner
But it gets better still:
Stephen Feinberg: Cerberus
https://www.bloomberg.com/news/articles/2018-05-11/trump-chooses-cerberus-s-feinbergto-lead-spy
advisory-panel
Trump Chooses Cerberus's Stephen Feinberg
to Lead Spy Advisory Panel - Bloomberg
President Donald Trump has chosen billionaire investor Stephen
Feinberg to lead his intelligence advisory board, the White House
said Friday. Trump intends to appoint Feinberg, the co-founder
and
www.bloomberg.com
Bawag/Refco
Virtu first bid for Knight post "glitch"
and now: Money Laundering Bank HSH
Stephen Feinberg: Scum of the Earth meet Georgio EKONOMOU
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&ClK=0001369241&owner=exclude&count=40&hidefilings=0
Janey, IG update my various pending TCR's and complaints
Yours VERY TRULY
And INFINITELY smarter than anyone on this e mail list
Christopher J Dilorio
EFTA00010739

=== Page 17 ===
Whistleblower
From: Chris Dilorio
Sent: Monday, May 13, 2019 5:41 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Saturday, May 11, 2019 8:00 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Monday, May 6, 2019 6:38 AM
To
Subject: Fw: Apollo/ Epstein/Kushner connection
Greetings grossly corrupt SEC et al scumbags
As with ALL of my allegations: beyond a shadow of a doubt, 100% accurate
https://www.sec.gov/litigation/complaints/comp17673.htm
Complaint: SEC V.
EFTA00010740

=== Page 18 ===
COMPLAINT. Plaintiff United States Securities and Exchange Commission ("Commission") alleges as
follows: SUMMARY. 1. This case involves a $15 million "pump and dump" scheme involving the securities
of Environmental Solutions Worldwide, Inc. ("Environmental"), a public company whose common stock is
registered with the Commission under the Securities Exchange Act of 1934 ("Exchange Act"), and is
www.sec.gov
ESWW was a money laundering shell.
The SEC knows it. The degenerate Epstein knows it. The Degenerate Leon Black/Kushner BFF/ Milken
proteges/Marc Rowan/Apollo knows it.
The DOJ/IRS knows it.
IG, I have repeatedly offered to come to SEC DC HQ to have the brightest minds at the SEC totally humiliate me
by refuting my allegations 1 by 1. The grossly corrupt SEC scumbags have never taken me up on my generous
offer. For the very simple reason that ALL of my allegations are accurate and true.
So, I again put the offer out there:
refute my claims OR go to jail for the criminal obstruction ACTIVELY being facilitated by your office and the SEC.
So, let's give these scumbags the insurance/annuities market.
This will NOT end well for tens of thousands of Americans.
Who "green lighted" this take over of the insurance industry by PE/Hedge funds?
https://www.forbes.com/sites/antoinegara/2018/02/01/apollo-and-blackstone-pick-insurance-as-their-next-
bet-to-disrupt-wall-street/#5d647dbe7689
Apollo And Blackstone Pick Insurance As Their
Next Bet To Disrupt Wall Street - Forbes
For decades, Wall Street's gambit in insurance was to write
policies and use the float as a source of capital for new
investments. It's a staple of Berkshire Hathaway and copycats like
Markel and
www.forbes.com
Cheers!
Christopher Dilorio
Whistleblower
From: Chris Dilorio
Sent: Thursday, May 2, 2019 3:35 PM
To:
EFTA00010741

=== Page 19 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
IG,
This was a blatant attempt to intimidate a whistleblower. "HE" (I think a male although very effeminate voice)
was an anonymous, coward, scumbag who threatened me. AND then called me another 11/12 times after that.
This is a VERY serious matter. Felony. I intend to see "him" prosecuted to the fullest extent of the law. Within
weeks of filing a complaint against the SEC and you.
I obviously have hit a nerve.
https://www.nbcnews.com/politics/white-house/white-house-tells-official-who-gave-kushner-security-
clearance-don-n997476
White House whistleblower speaks out on
security clearance controversy
Carl Kline was supposed to appear before House committee staff
Tuesday to face questions related to his handling of White House
security clearances.
www.nbcnews.com
Cheers!
Christopher Diiorio (no L's scumbag)
From: Chris Dilorio
Sent: Thursday, April 25, 2019 6:27 AM
To:
EFTA00010742

=== Page 20 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
ESWW: A money laundering NASDAQ/OTCM shell
Milken degenerate Leon Black/Joshua Harris: Apollo
AND
Jeffrey Epstein
The SEC has known for years that Epstein is running a extortion/Ponzi/Slush Fund
My Claims AGAIN
https://seekingalpha.com/article/3715526-environmental-solutions-worldwide-revisiting-holding-gone-dark-
can-sleep-better-night?mod=mw_quote_news
Environmental Solutions Worldwide: Revisiting
A Holding That's Gone Dark, So I Can Sleep
Better At Night - Environmental Solutions
Worldwide, Inc. (OTCMKTS:ESWW) | Seeking
Alpha - Stock Market Insights I Seeking Alpha
New CEO and recent trading activity warranted a review of a
holding that no longer files. Based on the environment, difficult
y/y comparisons and results from competitors, 2015 is likely a
down year.
seekingalpha.com
"Not credible"???
How about the SEC's OWN words?
https://www.bloomberg.com/news/articles/2018-10-01/sec-spots-a-way-to-starve-the-most-suspicious-penny-
stocks
EFTA00010743

=== Page 21 ===
SEC Spots a Way to Starve the Most
Suspicious Penny Stocks - Bloomberg
"If a company is a dark company and listed in the OTC market
and hasn't put out financials for six months, maybe it shouldn't
be quoted or offered to retail investors," Redfearn said
www.bloomberg.com
See my comment letters on this subject.
The SEC INTENTIONALLY puts the investing public at risk of frauds like this and thousands others like it.
The core biz at NITE/VIRT,CDEL etc and the reason WHY the OTCM exists: Abusive naked shorting publicly
traded shells to facilitate money laundering.
Shells go dark only AFTER a massive fraud has been perpetrated on the investing public: Main Street
ANOTHER "genius" degenerate: Apollo
the grossly corrupt SEC: Bought and paid for by common criminals and degenerates
IG, I have time for that REQUIRED 3rd party cc today
Call me
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Sunday, April 14, 2019 1:04 PM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
A little Steffie Avakian//Heiss/O'Melveny/Wilmer Hale/ Apollo/Kushner Home Cooking!
https://www.omm.com/professionals/howard-e-heiss/
EFTA00010744

=== Page 22 ===
Howard E. Heiss - O'Melveny & Myers
Howard Heiss has an extensive litigation practice focused on
government regulatory investigations and enforcement actions,
grand-jury investigations, and the defense of clients in criminal
cases, with a particular emphasis on securities matters.
www.omm.com
https://www.sec.gov/Archives/edgar/data/1411494/000119312508077312/ds1.htm
Form S-1 - SEC.gov
Table of Contents. The information in this prospectus is not complete and may be changed. The securities
may not be sold until the registration statement filed with the Securities and Exchange Commission is
effective.
www.sec.gov
https://www.wilmerhale.com/en/people/jamie-gorelick
Jamie Gorelick | WilmerHale
Jamie Gorelick's career has spanned the legal, policy and corporate landscapes. As one of Washington's
best-known litigators, Ms. Gorelick has represented corporations and individuals in a wide array of matters,
particularly in the regulatory and enforcement arenas, involving issues as diverse as antitrust,
environmental regulation, securities enforcement, national security regulation, etc.
www.wilmerhale.com
https://www.wilmerhale.com/en/insights/news/former-director-of-the-fbi-robert-mueller-i-joins-wilmerhale.
Former Director of the FBI Robert Mueller III
Joins WilmerHale
WilmerHale is pleased to announce that Robert S. Mueller III is
joining the firm as a partner after serving as the sixth Director of
the Federal Bureau of Investigation (FBI), a position he took one
week prior to the September 11 attacks and held for 12 years
under two presidents.
www.wilmerhale.com
https://www.sec.gov/biography/avakian-stephanie
EFTA00010745

=== Page 23 ===
SEC.gov
| Stephanie Avakian
Stephanie Avakian was named Co-Director of the U.S. Securities and Exchange Commission's Division of
Enforcement in June 2017, after serving as Acting Director since December 2016.
www.sec.gov
SEC drops Apollo investigation after Kush Jr met with Harris at the WH
and Apollo gives Kush's some $$$$
And, Apollo gets $60 bil+ in inflows in 2018
Did I miss something?
Cheers!
You corrupt fucking scumbags
Christopher Dilorio
From: Chris Dilorio
Sent: Saturday, April 13, 2019 11:30 AM
To:
Subject: Apollo/ Epstein/Kushner connection
Find a shell
Find a fraud
Enviromental Solutions Worldwide Inc
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001082278&owner=exclude&count=40&hidefilings=0
Florida?
Pennsylvania?
or
Canada?
EFTA00010746

=== Page 24 ===
Welcomed on Cromwell/Wimpfheimer OTCM
De registered in 2015 and Frozen in time
Literally
http://eswgroup.com/esw-group-corporate/our-board/
Our Board - ESW Group®
MARK YUNG Mr. Yung is Co-Founder and Managing Principal of
OCV Management, LLC ("OCV"), an investor, owner and operator
of technology and life science companies based in Los Angeles.
Previously, Mr. Yung was a Managing Director at Orchard Capital
Corp., a firm he joined in 2006. Through his affiliation with [...]
eswgroup.com
Dozens of filings by former Milken (ahem) right hand man Leon Black, Apollo, his family Trust, et al
Then,
There's this:
Has anyone (anyone) ever seen Pedophile Jeffrey Epstein on the other side of a trade?
The ONLY SEC filing of Epsteins' Financial Trust Company Inc is in
wait for it
Leon Black/Apollo Environmental Solutions Worldwide
https://www.sec.gov/Archives/edgar/data/1082278/000090901211000390/0000909012-11-000390-index.htm
Enter the Amicus blocking release of Epstein docs
Krieger, Kim and Lewin
https://www.kkllp.com/
Krieger Kim & Lewin LLP
We are committed to providing the highest level of partner-driven representation in order to efficiently
achieve client objectives. Over the last decade, we have conducted and supervised dozens of federal
criminal trials involving some of the highest profile and most sensitive matters prosecuted by the United
States Government.
www.kklllp.com
Financial fraud appears to be a specialty of this recently formed/SDNY Alum firm
Now,
it gets VERY interesting
https://www.cnbc.com/2018/02/28/apollo-citigroup-loaned-kushner-companies-millions-new-york-times.html
EFTA00010747

=== Page 25 ===
Trump: Kushner's security clearance is up to
Kelly
Kushner even discussed the possibility of a White House job for
the founder of private equity firm Apollo, the New York Times
reported on Tuesday.
www.cnbc.com
Where another Milken protégé/Apollo founding partner Josh Harris was considered for a White House job
"Coindences"
https://nypost.com/2018/03/02/sec-dropped-probe-month-after-firm-aided-kushner-company/
SEC dropped probe month after firm aided
Kushner company
The feds last year dropped an investigation into a financial
company a month after the firm gave Jared Kushner's family real
estate business a $180 million loan, a new report said Friday.
There
---
nypost.com
Oh, baby
$60 billion+ inflows in 2018 for Apollo
https://www.businesswire.com/news/home/20180802005343/en/Apollo-Global-Management-LLC-Reports
Quarter-2018
Apollo Global Management, LLC Reports
Second Quarter 2018 Results I Business Wire
NEW YORK--(BUSINESS WIRE)--Apollo Global Management, LLC
(NYSE:APO) (together with its consolidated subsidiaries, "Apollo")
today reported results for the second quarter ended June 30,
2018.
www.businesswire.com
Mr's Krieger,Kim,Boltz et al:
Discovery will be a hoot!
EFTA00010748

=== Page 26 ===
Fucking A
I am good
Cheers!
Christopher Dilorio
EFTA00010749


c1: EFTA00010083
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00010083.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 1 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
12/25/1961
P
06/11/2019
215
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
21:42
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
12/25/1961
P
06/02/2019
212
O
APIS
ON BOARD
LHR
BOS
NOELLE
00:00
MARION
MAXWELL
GHISLAINE
12/25/1961
P
12/27/2018
8
I
A041
APC
APIS
ON BOARD
BOS
NRT
NOELLE
17:08
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
12/25/1961
P
12/17/2018
7
O
APIS
ON BOARD
NRT
BOS
00:00
MAXWELL
GHISLAINE
12/25/1961
P
08/29/2018
743
I
APIS
NOT ON
BOS
DOH
NOELLE
00:00
BOARD
MARION
MAXWELL
GHISLAINE
12/25/1961
P
08/15/2018
59
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
12:05
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
12/25/1961
P
08/01/2018
58
O
APIS
ON BOARD
LHR
BOS
NOELLE
00:00
MAXWELL
GHISLAINE
12/25/1961
P
05/30/2018
213
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
13:20
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
12/25/1961
P
05/21/2018
744
O
APIS
ON BOARD
DOH
BOS
NOELLE
00:00
MARION
MAXWELL
GHISLAINE
12/25/1961
P
11/28/2017
59
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
11:46
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
12/25/1961
P
11/21/2017
12
O
APIS
ON BOARD
LHR
BOS
NOELLE
00:00
MAXWELL
GHISLAINE
12/25/1961
P
09/09/2017
59
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
12:32
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
12/25/1961
P
08/22/2017
58
O
Name No
APIS
ON BOARD
LHR
BOS
NOELLE MAR
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
01/08/2017
11
I
A041
APC
APIS
ON BOARD
BOS
LHR
21:32
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
12/25/1961
P
01/02/2017
12
O
APIS
ON BOARD
LHR
BOS
00:00
SDNY_GM_00000820
For Official Use Only / Law Enforcement Sensitive
EFTA00010083

=== Page 2 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 2 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
12/25/1961
P
11/20/2016
213
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
13:42
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
12/25/1961
P
11/13/2016
212
O
Name No
APIS
ON BOARD
LHR
BOS
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
08/18/2016
11
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
15:57
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
12/25/1961
P
07/25/2016
12
O
Name No
APIS
ON BOARD
LHR
BOS
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
11/27/2015
I
L382
VEHICLE
NOELLE
15:30
MAXWELL
GHISLAINE
12/25/1961
P
08/28/2015
213
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
13:26
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
12/25/1961
P
08/18/2015
112
O
Name No
APIS
ON BOARD
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
07/02/2015
9
I
A471
APC
APIS
ON BOARD
JFK
LHR
NOELLE
19:07
AUTOMATED
PASSPORT
CONTROL, JFK
MAXWELL
GHISLAINE
12/25/1961
P
06/15/2015
474
O
Name No
APIS
ON BOARD
VCE
JFK
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
03/29/2015
4363
I
A741
APC
APIS
ON BOARD
MIA
NAS
11:15
AUTOMATED
PASSPORT
CONTROL, NAS
MAXWELL
GHISLAINE
12/25/1961
P
03/27/2015
4270
O
Name No
APIS
NOT ON
NAS
MIA
00:00
Name, No
BOARD
MAXWELL
GHISLAINE
12/25/1961
P
11/19/2014
1048
I
A471
APIS
PASSENGER
JFK
LTN
04:57
MAXWELL
GHISLAINE
12/25/1961
P
11/19/2014
193
I
Name No
APIS
NOT ON
DFW
LHR
00:00
Name, No
BOARD
MAXWELL
GHISLAINE
12/25/1961
P
11/15/2014
214
O
Name No
APIS
ON BOARD
LHR
BOS
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
11/09/2014
7462
I
A792
APC
APIS
ON BOARD
LGA
YUL
NOELLE
17:35
AUTOMATED
PASSPORT
CONTROL, YUL
MAXWELL
GHISLAINE
12/25/1961
P
11/07/2014
5089
O
Name No
APIS
ON BOARD
YUL
LGA
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
11/02/2014
615
I
A472
APIS
ON BOARD
JFK
KEF
NOELLE
18:22
MAXWELL
GHISLAINE
12/25/1961
P
10/29/2014
630
O
Name No
APIS
ON BOARD
KEF
BOS
NOELLE
00:00
Name, No
SDNY_GM_00000821
For Official Use Only / Law Enforcement Sensitive
EFTA00010084

=== Page 3 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY DISTON
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 3 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
12/25/1961
P
09/01/2014
215
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
20:22
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
12/25/1961
P
07/30/2014
292
O
Name No
APIS
ON BOARD
LHR
IAD
NOELLE MAR
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
01/04/2014
45
I
A471
APC
APIS
ON BOARD
JFK
LHR
NOELLE
16:37
AUTOMATED
PASSPORT
CONTROL, JFK
MAXWELL
GHISLAINE
12/25/1961
P
12/27/2013
5
I
Name No
APIS
NOT ON
MIA
LHR
NOELLE
00:00
Name, No
BOARD
MAXWELL
GHISLAINE
12/25/1961
P
12/27/2013
1487
O
Name No
APIS
NOT ON
SXM
JFK
00:00
Name, No
BOARD
MAXWELL
GHISLAINE
12/25/1961
P
12/26/2013
175
I
Name No
APIS
NOT ON
JFK
LHR
NOELLE
00:00
Name, No
BOARD
MAXWELL
GHISLAINE
12/25/1961
P
12/09/2013
208
O
Name No
APIS
ON BOARD
LHR
MIA
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
11/09/2013
45
I
A471
APC
APIS
ON BOARD
JFK
LHR
NOELLE
16:00
AUTOMATED
PASSPORT
CONTROL, JFK
MAXWELL
GHISLAINE
12/25/1961
P
10/30/2013
10
O
Name No
APIS
REQUEST
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
10/29/2013
22
O
Name No
APIS
NOT ON
LHR
IAD
00:00
Name, No
BOARD
MAXWELL
GHISLAINE
12/25/1961
P
10/14/2013
617
I
A472
APIS
ON BOARD
JFK
KEF
NOELLE
19:30
MAXWELL
GHISLAINE
12/25/1961
P
10/09/2013
614
O
Name No
APIS
ON BOARD
KEF
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
09/02/2013
3
I
A471
APIS
ON BOARD
JFK
LHR
NOELLE
12:16
MAXWELL
GHISLAINE
12/25/1961
P
07/18/2013
46
O
Name No
APIS
ON BOARD
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
06/22/2013
7732
I
A795
APIS
ON BOARD
LGA
YOW
NOELLE
12:33
MAXWELL
GHISLAINE
12/25/1961
P
06/21/2013
7733
O
Name No
APIS
ON BOARD
YOW
LGA
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
06/19/2013
25
I
A471
APIS
NOT ON
JFK
LHR
NOELLE
12:36
BOARD
MAXWELL
GHISLAINE
12/25/1961
P
06/19/2013
3
I
Name No
APIS
ON BOARD
JFK
LHR
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
06/03/2013
10
O
Name No
APIS
ON BOARD
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
06/01/2013
10
O
Name No
APIS
NOT ON
LHR
JFK
NOELLE
00:00
Name, No
BOARD
SDNY_GM_00000822
For Official Use Only / Law Enforcement Sensitive
EFTA00010085

=== Page 4 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 4 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
12/25/1961
P
04/05/2013
183
I
A472
APIS
JFK
LHR
NOELLE
22:51
MAXWELL
GHISLAINE
12/25/1961
P
03/22/2013
22
O
Name No
APIS
LHR
IAD
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
03/14/2013
177
I
Name No
APIS
JFK
LHR
NOELLE MAR
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
02/08/2013
687
O
Name No
APIS
SXM
MIA
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
01/07/2013
9103
I
A151
APIS
ILM
SXM
14:52
MAXWELL
GHISLAINE
12/25/1961
P
01/02/2013
2144
I
A52B
Name No
APIS
MIA
SXM
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
12/22/2012
177
I
AB52
Name No
APIS
JFK
LHR
NOELLE MAR
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
11/16/2012
845
O
Name No
APIS
HKG
JFK
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
11/15/2012
841
O
Name No
APIS
HKG
JFK
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
11/14/2012
10
O
Name No
APIS
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
10/03/2012
1031
I
A27G
APIS
LAX
LTN
NOELLE
03:52
MAXWELL
GHISLAINE
12/25/1961
P
10/03/2012
1031
I
A27F
Name No
APIS
LAX
LTN
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
10/03/2012
17
I
AB5J
Name No
APIS
EWR
LHR
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
10/02/2012
1031
I
A27F
Name No
APIS
LAX
LTN
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
09/28/2012
78
O
Name No
APIS
LHR
DFW
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
09/28/2012
738
O
Name No
APIS
YYZ
SFO
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
09/03/2012
83
I
AB52
Name No
APIS
JFK
NCE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
08/30/2012
MFALC
I
APIS
BGR
XXX
13:22
MAXWELL
GHISLAINE
12/25/1961
P
08/30/2012
MFALC
I
Name No
APIS
TEB
XXX
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
06/15/2012
8057
O
Name No
APIS
GIG
MIA
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
05/29/2012
45
I
A471
APIS
JFK
LHR
16:35
MAXWELL
GHISLAINE
12/25/1961
P
05/21/2012
172
O
Name No
APIS
LHR
JFK
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
04/12/2012
7
O
Name No
APIS
CDG
JFK
00:00
Name, No
SDNY_GM_00000823
For Official Use Only / Law Enforcement Sensitive
EFTA00010086

=== Page 5 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 5 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
12/25/1961
P
04/05/2012
651
O
Name No
APIS
BGI
MIA
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
01/05/2012
5239
I
A461
APIS
TEB
DAV
NOELLE
18:26
MAXWELL
GHISLAINE
12/25/1961
P
01/05/2012
2192
I
ABFT
Name No
APIS
MIA
PTY
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
12/28/2011
687
O
Name No
APIS
SXM
MIA
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
12/21/2011
219
I
A337
APIS
DEN
LHR
NOELLE
18:06
MAXWELL
GHISLAINE
12/25/1961
P
12/09/2011
286
O
Name No
APIS
LHR
SFO
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
10/29/2011
268
O
Name No
APIS
TLV
JFK
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
08/28/2011
1078
I
A524
APIS
MIA
BGI
18:55
MAXWELL
GHISLAINE
12/25/1961
P
07/27/2011
182
O
Name No
APIS
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
05/08/2011
N2767
I
Name No
APIS
BGR
XXX
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
05/07/2011
N2767
I
Name No
APIS
BGR
XXX
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
04/29/2011
N2767
O
Name No
APIS
XXX
NUQ
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
04/26/2011
1078
I
A524
APIS
MIA
BGI
19:04
MAXWELL
GHISLAINE
12/25/1961
P
04/20/2011
871
O
Name No
APIS
BGI
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
03/28/2011
3
I
A471
APIS
JFK
LHR
13:10
MAXWELL
GHISLAINE
12/25/1961
P
02/14/2011
45
I
A471
APIS
JFK
LHR
NOELLE
16:14
MAXWELL
GHISLAINE
12/25/1961
P
02/14/2011
3
I
AB52
Name No
APIS
JFK
LHR
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
02/09/2011
46
O
Name No
APIS
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
11/06/2010
179
I
A472
APIS
JFK
LHR
NOELLE
21:29
MAXWELL
GHISLAINE
12/25/1961
P
10/29/2010
262
O
Name No
APIS
AMM
JFK
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
10/01/2010
N923CL
I
APIS
TEB
XXX
15:43
MAXWELL
GHISLAINE
12/25/1961
P
10/01/2010
923CL
I
A10D
AIRLINE
TEB
NOELLE
14:09
(NOT
API)
SDNY_GM_00000824
For Official Use Only / Law Enforcement Sensitive
EFTA00010087

=== Page 6 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 6 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
12/25/1961
P
10/01/2010
N923CL
I
Name No
APIS
TEB
XXX
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
09/28/2010
N923CL
O
Name No
APIS
XXX
TEB
00:00
Name, No
MAXWELL
GHISLAINE
12/25/1961
P
08/29/2010
183
I
A472
APIS
JFK
LHR
NOELLE
20:11
MAXWELL
GHISLAINE
12/25/1961
P
08/29/2010
115
I
AB52
Name No Name
APIS
JFK
LHR
NOELLE
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
08/01/2010
N17ND
O
Name No Name
APIS
XXX
TEB
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
07/26/2010
N17ND
I
APIS
APA
XXX
01:29
MAXWELL
GHISLAINE
12/25/1961
P
07/12/2010
N17ND
O
Name No Name
APIS
XXX
TEB
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
07/11/2010
N17ND
o
Name No Name
APIS
XXX
TEB
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
07/10/2010
N17ND
I
Name No Name
APIS
FRG
XXX
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
06/21/2010
N17ND
O
Name No Name
APIS
XXX
TEB
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
06/12/2010
N17ND
I
APIS
IAD
XXX
11:54
MAXWELL
GHISLAINE
12/25/1961
P
06/11/2010
N17ND
o
Name No Name
APIS
XXX
IAD
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
04/16/2010
N17ND
I
A276
AIRLINE
PSP
22:06
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
04/16/2010
N1 7ND
I
Name No Name
APIS
PSP
XXX
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
04/05/2010
N17ND
O
Name No Name
APIS
XXX
SAN
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
03/21/2010
N1 7ND
I
APIS
SAN
XXX
18:46
MAXWELL
GHISLAINE
12/25/1961
P
03/20/2010
N17ND
I
Name No Name
APIS
SAN
XXX
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
03/16/2010
N17ND
O
Name No Name
APIS
XXX
OPF
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
03/03/2010
N17ND
I
APIS
TEB
XXX
17:24
MAXWELL
GHISLAINE
12/25/1961
P
03/03/2010
17ND
I
A10D
AIRLINE
TEB
17:13
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
03/03/2010
N17ND
I
Name No Name
APIS
HPN
XXX
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
03/01/2010
N17ND
O
Name No Name
APIS
XXX
SAN
00:00
N
SDNY_GM_00000825
For Official Use Only / Law Enforcement Sensitive
EFTA00010088

=== Page 7 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 7 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
12/25/1961
P
01/22/2010
N1 7ND
I
APIS
TEB
XXX
23:48
MAXWELL
GHISLAINE
12/25/1961
P
01/22/2010
N1 7ND
I
A10D
AIRLINE
TEB
NOELLE
23:43
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
01/22/2010
N1 7ND
I
Name No Name
APIS
HPN
XXX
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
01/19/2010
N1 7ND
O
Name No Name
APIS
XXX
KSA
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
01/07/2010
N1 7ND
I
APIS
HPN
XXX
21:23
MAXWELL
GHISLAINE
12/25/1961
P
01/06/2010
N1 7ND
I
Name No Name
APIS
HPN
XXX
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
12/27/2009
N1 7ND
O
Name No Name
APIS
XXX
KSA
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
11/14/2009
N17ND
I
APIS
SAN
XXX
17:20
MAXWELL
GHISLAINE
12/25/1961
P
11/08/2009
N1 7ND
o
Name No Name
APIS
XXX
PAN
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
10/31/2009
N17ND
I
APIS
HPN
XXX
10:12
MAXWELL
GHISLAINE
12/25/1961
P
10/30/2009
N1 7ND
I
Name No Name
APIS
HPN
XXX
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
10/28/2009
N1 7ND
O
Name No Name
APIS
XXX
KIA
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
08/13/2009
N1 7ND
I
Name No Name
APIS
SAN
XXX
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
07/30/2009
N1 7ND
I
Name No Name
APIS
SAN
XXX
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
07/19/2009
N1 7ND
O
Name No Name
APIS
XXX
KSA
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
07/18/2009
269
I
A273
APIS
LAX
LHR
NOELLE
22:07
MAXWELL
GHISLAINE
12/25/1961
P
07/11/2009
278
O
Name No Name
APIS
LHR
LAX
NOELLE
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
07/08/2009
N1 7ND
O
Name No Name
APIS
XXX
KOM
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
07/05/2009
N1 7ND
O
Name No Name
APIS
XXX
KDS
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
06/28/2009
N1 7ND
I
Name No Name
APIS
SAN
XXX
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
06/15/2009
N1 7ND
O
Name No Name
APIS
XXX
KSA
00:00
N
MAXWELL
GHISLAINE
12/25/1961
P
05/03/2009
N1 7ND
I
A262
AIRLINE
TUS
NOELLE
12:37
(NOT
API)
SDNY_GM_00000826
For Official Use Only / Law Enforcement Sensitive
EFTA00010089

=== Page 8 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 8 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINENOE
12/25/1961
P
06/12/2008
10
I
A477
APIS
JFK
CDG
LLE
19:02
MAXWELL
GHISLAINE
12/25/1961
P
06/06/2008
112
O
APIS
LHR
JFK
NOELLE MAR
00:00
MAXWELL
GHISLAINE
12/25/1961
000
06/02/2008
17
I
A10D
AIRLINE
TEB
21:35
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
04/30/2008
428WT
I
A10D
AIRLINE
TEB
10:26
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
01/24/2008
428WT
I
A10D
AIRLINE
TEB
18:31
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
11/17/2007
614RD
I
A523
AIRLINE
PBI
09:53
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
08/22/2007
208
O
APIS
LHR
MIA
NOELLE
00:00
MAXWELL
GHISLAINE
12/25/1961
P
04/21/2007
1
I
A471
APIS
JFK
STN
13:23
MAXWELL
GHISLAINE
12/25/1961
P
01/01/2007
UNKN
I
A511
AIRLINE
16:41
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
12/23/2006
N908
I
A511
AIRLINE
STT
10:19
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
C
09/26/2006
2
I
A52B
AIRLINE
MIA
14:21
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
06/28/2006
4
I
A52B
AIRLINE
MIA
22:51
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
05/28/2006
279
I
A273
APIS
LAX
LHR
NOELLE
16:39
MAXWELL
GHISLAINE
12/25/1961
P
01/02/2006
401WJ
I
A511
AIRLINE
STT
11:57
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
12/22/2005
491GM
I
A511
AIRLINE
STT
14:22
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
11/20/2005
268
O
APIS
LHR
LAX
NOELLE MAR
00:00
-
MAXWELL
GHISLAINE
12/25/1961
P
10/17/2005
312P
I
A311
AIRLINE
ANC
09:18
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
07/04/2005
182
O
APIS
LHR
JFK
NOELLE
00:00
SDNY_GM_00000827
For Official Use Only / Law Enforcement Sensitive
EFTA00010090

=== Page 9 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 9 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
12/25/1961
P
06/29/2005
401WJ
I
A523
AIRLINE
PBI
11:56
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
06/04/2005
1
I
A492
AIRLINE
SJU
16:51
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
05/29/2005
909JE
I
A523
AIRLINE
PBI
18:17
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
02/19/2005
909JE
I
A523
AIRLINE
PBI
20:13
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
02/12/2005
I
A52B
AIRLINE
20:48
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
01/02/2005
401WJ
I
A523
AIRLINE
PBI
13:19
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
08/25/2004
908JE
I
A523
AIRLINE
PBI
17:42
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
07/18/2004
9
I
A471
APIS
JFK
LHR
22:03
MAXWELL
GHISLAINE
12/25/1961
P
07/11/2004
46
O
APIS
LHR
JFK
00:00
MAXWELL
GHISLAINE
12/25/1961
P
06/04/2004
174
O
APIS
LHR
JFK
NOELLE MAR
00:00
MAXWELL
GHISLAINE
12/25/1961
P
05/12/2004
8
I
A477
AIRLINE
JFK
CDG
21:10
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
02/07/2004
207
I
A520
APIS
MIA
LHR
14:43
MAXWELL
GHISLAINE
12/25/1961
P
01/02/2004
1
I
A523
AIRLINE
PBI
18:03
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
12/24/2003
909JE
I
A523
AIRLINE
PBI
17:52
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
11/02/2003
23
O
APIS
CDG
JFK
00:00
MAXWELL
GHISLAINE
12/25/1961
P
10/08/2003
115
I
A472
APIS
JFK
LHR
19:09
MAXWELL
GHISLAINE
12/25/1961
P
09/30/2003
2
O
APIS
LHR
JFK
00:00
MAXWELL
GHISLAINE
12/25/1961
P
06/14/2003
909JE
I
A523
APIS
PBI
20:29
MAXWELL
GHISLAINE
12/25/1961
P
05/29/2003
1
I
A472
APIS
JFK
LHR
17:43
SDNY_GM_00000828
For Official Use Only / Law Enforcement Sensitive
EFTA00010091

=== Page 10 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 10 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
12/25/1961
P
04/11/2003
1
I
A523
APIS
PBI
00:45
MAXWELL
GHISLAINE
12/25/1961
P
04/01/2003
491GM
I
A511
APIS
STT
14:38
MAXWELL
GHISLAINE
12/25/1961
P
03/23/2003
909JE
I
A523
APIS
PBI
21:43
MAXWELL
GHISLAINE
12/25/1961
P
02/21/2003
1
I
A471
APIS
JFK
LHR
09:33
MAXWELL
GHISLAINE
12/25/1961
P
01/02/2003
615A
T
A491
APIS
STT
EIS
00:00
MAXWELL
GHISLAINE
12/25/1961
P
12/31/2002
222
T
A491
APIS
SBH
STT
00:00
MAXWELL
GHISLAINE
12/25/1961
A
08/30/2002
672
I
A512
AIRLINE
12:50
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
08/04/2002
283
I
2720
APIS
LAX
LHR
19:00
MAXWELL
GHISLAINE
12/25/1961
A
04/18/2002
908JE
I
A523
AIRLINE
17:57
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
A
03/18/2002
5
I
A511
AIRLINE
09:45
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
A
01/13/2002
1
I
A523
AIRLINE
20:59
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
A
12/23/2001
I
A511
AIRLINE
16:21
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
10/01/2001
209
I
5206
APIS
MIA
LHR
18:20
MAXWELL
GHISLAINE
12/25/1961
P
08/01/2001
6
I
4701
APIS
JFK
CDG
18:31
MAXWELL
GHISLAINE
12/25/1961
A
07/01/2001
1
I
A511
AIRLINE
15:04
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
A
06/29/2001
909
I
A511
AIRLINE
00:36
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
A
02/21/2001
672
I
A511
AIRLINE
14:02
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
A
09/05/2000
115
I
A472
AIRLINE
18:15
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
07/17/2000
115
I
4701
APIS
JFK
LHR
17:59
SDNY_GM_00000829
For Official Use Only / Law Enforcement Sensitive
EFTA00010092

=== Page 11 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 11 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
12/25/1961
P
06/23/2000
1
I
4701
APIS
JFK
LHR
09:22
MAXWELL
GHISLAINE
12/25/1961
A
04/16/2000
733TA
I
A523
AIRLINE
20:59
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
P
03/09/2000
175
I
4701
APIS
JFK
LHR
13:28
MAXWELL
GHISLAINE
12/25/1961
A
02/05/2000
20700
I
A511
AIRLINE
15:34
(NOT
API)
MAXWELL
GHISLAINE
12/25/1961
A
01/21/2000
505LS
I
A523
AIRLINE
23:35
(NOT
API)
Total Number of Records: 203
Legend
Loc
SDNY_GM_00000830
For Official Use Only / Law Enforcement Sensitive
EFTA00010093

=== Page 12 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS - - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 12 of 14
Codes
Value
YOW
OTTAWA
NAS
NASSAU INTL
LAX
LOS ANGELES, CA INTL
OPF
OPA LOCKA
CDG
PARIS, CH. DE GAULLE
SXM
ST MAARTEN, PRINCE JULIANA
ILM
NEW HANOVER COUNTY
STN
LONDON, STANSTED
JFK
JOHN F KENNEDY INTL
NRT
NARITA, TOKYO
STT
C.E. KING
DFW
DALLAS/FT WORTH INTL
PBI
WEST PALM BEACH
KDS
KDS
DOH
DOHA#INTERNATIONAL, QATAR
AMM
QUEEN ALIA INTL
KIA
KIA
MIA
MIAMI INTL, FL
GIG
RIO DE JANEIRO
HKG
HONG KONG
BGI
BARBADOS, GRANTLEY ADAMS INTL
BOS
BOSTON / LOGAN INTL
LGA
LA GUARDIA
BGR
BANGOR
PSP
PALM SPRINGS
KEF
REYKJAVIK / KEFLAVIK INTL
IAD
DULLES INTL
EIS
BEEF ISLAND, VIRGIN ISLAND (BRITISH)
YUL
DORVAL, MONTREAL
NCE
COTE D'AZUR
ANC
ANCHORAGE
VCE
MARCO POLO
YYZ
TORONTO, PEARSON INTERNATIONAL
SAN
LINDBERG FLD S.DIEGO
LTN
LUTON INTERNATIONAL
HPN
WESTCHESTER
PTY
PANAMA, OMAR TORRIJOS H
LHR
LONDON / HEATHROW INTL
KSA
KOSRAE, CAROLINE IS. #ARPT, P. OCEAN
SDNY_GM_00000831
For Official Use Only / Law Enforcement Sensitive
EFTA00010094

=== Page 13 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 13 of 14
Codes
Value
SBH
ST. BARTHELEMY#ARPT, GUADELOUPE
XXX
UNKNOWN AIRPORT (USED ONLY WHEN THE AIRPORT CODE IS UNKNOWN)
SFO
SAN FRANCISCO INTL AIRPORT
TLV
BEN GURION INTL
SJU
SAN JUAN, LUIS MUNOZ MARIN INTL
EWR
NEWARK INTERNATIONAL
KOM
KOM
NUQ
MOFFETT FIELD
DEN
DENVER INTERNATIONAL AIRPORT
TEB
TETERBORO
APA
ARAPAHOE CO
TUS
TUCSON
DAV
ENRIQUE MALEK
FRG
REPUBLIC FIELD
PAN
PAN
Doc Type
Codes
Value
P
P - PASSPORT
000
000
A
A - U.S. ALIEN REGISTRATION CARD
C
C - PERMANENT RESIDENT CARD
Site Code
SDNY_GM_00000832
For Official Use Only / Law Enforcement Sensitive
EFTA00010095

=== Page 14 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY DISTON
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 14 of 14
Codes
Value
L382
L382 - CBP-DETROIT, WINDSOR TUNNEL
AB5J
AB5J - INS-NEWARK ASYLUM *HIST*
A524
A524 - CBP-MIAMI, AIRPORT CNTRL TERML
A523
A523 - CBP-PALM BEACH, INTERNATIONAL
A520
A520 - CBP-MIAMI, AIRPORT N TERMINAL
A741
A741 - CBP-NASSAU, BAHAMAS PRECLEAR
A461
A461 - CBP-TETERBORO, AIRPT HANGER 2
A041
A041 - CBP-BOSTON, LOGAN AIRPORT
A262
A262 - CBP-TUCSON, IAP ARRIVALS
2720
2720 - 2720
4701
4701 - 4701
A27F
A27F - CBP-LOS ANGELES, ATLANTIC AVN
A27G
A27G - CBP-LOS ANGELES, LANDMARK GAF
AB52
AB52 - INS-JFK AIRPORT
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A512 - CBP-ST THOMAS, VI PREDEPARTURE
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A477 - NEW YORK, JFK AIRPORT, TERM 1
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A472 - NEW YORK, JFK AIRPORT, TERM 7
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ABFT - INS-MIAMI OGC *HIST*
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For Official Use Only / Law Enforcement Sensitive
EFTA00010096


c1: EFTA00011164
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c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00011164.pdf
c6: pdf
c7: images
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Motions in Limine]
Date: Tue, 19 Oct 2021 17:17:56 +0000
Attachments: Maxwell's_Motions_in_Limine.zip
Inline-Images: image001.jpg
From:
)
Sent: Tuesday, October 19, 2021 9:50 AM
To:
(USANYS)
is
SANYS)
Cc:
>;
(USANYS)
>;
Subject: RE: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Motions in Limine]
Oh sure! I've attached the zip file, but also happy to add you to the share drive if you like.
From:
(USANYS)
Sent: Tuesday, October 19, 2021 9:19 AM
To:
)
is
(USANYS)
Cc:
is
(USANYS)
>;
)
Subject: RE: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Motions in Limine]
Thanks,
I don't seem to have access to the shared. Would you mind asking IT to add me and
? And/or
emailing the PDF?
From:
Sent: Tuesday, October 19, 2021 12:15 AM
To:
(USANYS)
>;
(USANYS)
Cc:
is
(USANYS)
i
Subject: FW: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Motions in Limine]
The defense filed 13 motions in limine. I've attached their two cover letters, and the various motions are saved here:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\!Trial\MIL\DefenseMLs
From: Nicole Simmons
Sent: Monday, October 18, 2021 11:41 PM
To: 'Nathan NYSD Chambers'
Cc: Jeff Pagliuca
>; ; Laura Menninger
i
is
is
(USANYS)
Subject: [EXTERNAL] U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Motions in Limine]
Dear Judge Nathan:
EFTA00011164

=== Page 2 ===
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Motions in Limine and supporting documents.
Regards,
Nicole Simmons
Nicole Simmons
-
Haddon, Morgan and
Foreman, P.C.
www.hmflaw.com
EFTA00011165


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=== Page 1 ===
From: Sigrid McCawley
To:
)"
Subject: RE: Filing
Date: Tue, 15 Dec 2020 14:59:37 +0000
I should be able to get it to you today but just in case it is great to know I can get it to you by the morning.
Thank you very much for all your hard work!
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
200
www.bsfllp.com
From:
)
[mailto:
Sent: Tuesday, December 15, 2020 9:52 AM
To: Sigrid McCawley
Subject: RE: Filing
The filing is due tomorrow, and we will likely aim to file it around 5pm ET, but we can file it later in the evening if needed.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Tuesday, December 15, 2020 9:49 AM
To:
)
Subject: RE: Filing
Thanks
- is your filing date today or tomorrow?
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
EFTA00009865

=== Page 2 ===
www.bsfllp.com
From:
)
[mailto:
Sent: Tuesday, December 15, 2020 9:41 AM
To: Sigrid McCawley
Subject: RE: Filing
Hi again,
My colleagues just pointed out that a letter addressed to Judge Nathan may be the most natural format for this pdf. But
we of course defer to you and
regarding how she would like to format this statement.
Best,
From:
Sent: Tuesday, December 15, 2020 9:35 AM
To: Sigrid McCawley
Subject: RE: Filing
Hi Sigrid,
Thank you very much for sending this along. We do not need this to be a signed declaration, but it would helpful if you
could please provide
statement in a separate pdf with whatever attribution she is comfortable with. We will plan
to publicly file that pdf as an exhibit to our memorandum of law in opposition to the bail motion.
Feel free to call my cell
) if you'd like to discuss or have any questions.
Best,
From: Sigrid McCawley
Sent: Monday, December 14, 2020 8:39 PM
To:
Cc: Sigrid McCawley
Subject: Filing
Hello Maureen,
I hope you are doing great. This is the statement that
would like to submit. What format would you like me to send
it in? Should it be as a signed declaration? She is comfortable having it attributed to her name.
"I appreciate the opportunity to again be heard by the Court in this matter and once more request that Ghislaine
Maxwell not be released prior to her trial. I write this not only on behalf of myself, but all of the other girls and
young women who were victimized by Maxwell. Ghislaine Maxwell sexually abused me as a child and the
government has the responsibility to make sure that she stands trial for her crimes. I do not believe that will
happen or that any of her victims will see justice if she is released on bail. She has lived a life of privilege,
EFTA00009866

=== Page 3 ===
abusing her position of power to live beyond the rules. Fleeing the country in order to escape once more would
fit with her long history of anti-social behavior.
Drawing on my personal experience with Maxwell and what I have learned of how she has lived since that time,
I believe that she is a psychopath. Her abuse of me and many other children and young women is evidence of her
disregard for and violation of the rights of others. She has demonstrated a complete failure to accept to
responsibility in any way for her actions and demonstrated a complete lack of remorse for her central role in
procuring victims for Epstein. She was both charming and manipulative with me during the grooming process,
consistent with what many of her victims have described. She has frequently lied to others, including repeatedly
lying about me and my family. Maxwell has for decades lived a parasitic lifestyle relying on Epstein and others
to fund her lavish existence.
Maxwell has repeatedly demonstrated that her primary concern is her own welfare, and that she is willing to
harm others if it benefits her. She is quite capable of doing so once more. She will not hesitate to leave the
country irrespective of whether others will be on the hook financially for her actions because she lacks empathy,
and therefore simply does not care about hurting others. She would in fact be highly motivated to flee in order to
reduce the possibility of continued imprisonment, the conditions of which she has continuously complained. Her
actions over the last several years and choice to live in isolation for long periods suggest that being comfortable
is more important to her than being connected. Even more concerning, is if she is let out she has the ability to
once again abuse children and the painful consequences of that type of trauma can last a lifetime. I implore the
Court to make sure that Ghislaine Maxwell does not escape justice by keeping her incarcerated until her trial."
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
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=== Page 1 ===
Ignorance of age not valid defense in sex cases, expert says
Page 1 of 3
PRINTTHIS
PalmBeachPost.com
Ignorance of age not valid defense in sex cases,
expert says
UPDATED
WEEKLY
By Larry Keller
Browse
Palm Beach Post Staff Writer
Specials
& Deals
Friday, August 04, 2006
From Local
Dealerships
Even if Palm Beach money manager Jeffrey Epstein didn't know that girls who
police say gave him sexual massages at his Intracoastal home were under the legal
Autos
age, that alone wouldn't have exempted him from criminal charges of sexual activity
PalmBeachPost.com
with minors.
"Ignorance is not a valid defense," said Bob Dekle, a legal skills professor who was a Lake City
prosecutor for nearly 30 years, half of that time specializing in sex crimes against children.
Jeffrey Epstein
"There is no knowledge element as far as
Billionaire
the age is concerned," Dekle said.
financier
Jeffrey
After an 11-month investigation, Palm
Epstein has
Beach police said there was probable cause
been indicted
to charge Epstein, 53, with unlawful sex
acts with a minor and lewd and lascivious
for felony solicitation of
prostitution by a grand
molestation. They contend that Epstein -
friend of the rich and famous and financial
jury following
accusations by teen girls.
patron of Democratic Party organizations
Past headlines
and candidates - committed those acts
with five underage girls.
In the past week, New York Attorney
More crime coverage
General and gubernatorial candidate Eliot
Most recent headlines
Spitzer has returned about $50,000 in
Fugitives Sex offenders
campaign contributions he received from
Epstein, and Mark Green, a candidate to
Behind
crime
reporters
The Yellow Tape
replace Spitzer in his current job, has
Post
returned $10,000 to him because of the
crime blog
Palm Beach scandal, the New York Daily
More local news
News has reported.
http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=lgnorancetoftage+.
1/2/2008
EFTA00013769

=== Page 2 ===
Ignorance of age not valid defense in sex cases, expert says
Page 2 of 3
Latest breaking news, photos and all of today's Post stories. Rather than file charges, the state attorney's
Share This Story
office presented the case to a county grand
jury. The panel indicted Epstein last week
on a single, less serious charge of felony solicitation of prostitution.
The case raised eyebrows because the state attorney's office rarely, if ever, kicks such charges to a grand
jury. And it increases the difficulty of prosecuting child sex abuse cases, especially when the defendant
is enormously wealthy and can hire high-priced, top-tier lawyers.
At least one of Epstein's alleged victims told police he knew she was underage when the two of them got
naked for massages and sexual activity. She was 16 years old at the time and said Epstein asked her
questions about her high school, according to police reports.
A girl who said she met Epstein when she was 15 said he told her if she told anybody what happened at
his house, bad things could happen, the police reports state.
Epstein's youngest alleged victim was 14 when she says she gave him a massage that included some
sexual activity. She is now 16. The girl's father says he doesn't know whether she told Epstein her age.
"My daughter has kept a lot of what happened from me because of sheer embarrassment," he said. "But
she very much looked 14. Any prudent man would have had second thoughts about that."
Defense attorney Jack Goldberger maintains that not only did Epstein pass a polygraph test showing he
did not know the girls were minors, but their stories weren't credible. The state attorney's office also
implied that their credibility was an issue when it decided not to charge Epstein directly, but instead give
the case to the grand jury.
"A prosecutor has to look at it in a much broader fashion," a state attorney's spokesman said last week.
Epstein hired Harvard law Professor Alan Dershowitz when he became aware he was under
investigation, and Dershowitz gave prosecutors information that some of the alleged victims had spoke
of using alcohol and marijuana on a popular Web site, according to a Palm Beach police report.
Prosecutors typically consider two things in deciding whether to charge somebody with sex-related
offenses against minors - whether there is sufficient evidence and whether there is a public interest in
doing so, Dekle said.
If two teens are in a sexual relationship and the boy turns 18 before the girl, he could be charged with a
sex crime if the sex continues. There would be no public interest in pursuing that, Dekle said.
But where there is a large gap in ages - and especially in cases of teachers with students - there is a
public interest in prosecuting, he said. Likewise if the accused has a track record of sex with minors.
Still there is a "universal constant" in prosecuting these cases, Dekle said. Men who exploit underage
children for sex often carefully choose their victims in ways that will minimize the risk to them, he said.
Victims usually are from a lower social status, and they may suffer from psychological problems, Dekle
said.
"Lots of child sexual abuse victims have been victimized by multiple people over a period of time. Then
http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&ctitle=lgnorance+oftage+.
1/2/2008
EFTA00013770

=== Page 3 ===
Ignorance of age not valid defense in sex cases, expert says
Page 3 of 3
the act of abuse produces behavior in the victims that further damages their credibility." Examples
include promiscuous behavior and drug abuse.
Some of the alleged victims in the Epstein case returned to his home multiple times for the massage
sessions and the $200 to $300 he typically paid them per visit. "That would be a definite problem for the
prosecutor," said Betty Resch, who prosecuted crimes against children in Palm Beach County for five
years and now is in private practice in Lake Worth.
"The victim becomes less sympathetic" to a jury, Resch said. "But she's a victim nevertheless. She's a
kid."
Most men charged with sex crimes against minors look normal, Dekle said. A jury expecting to see a
monster seldom will. And the victims' ages work against them and in favor of the defendant in a trial,
Dekle said.
If a child and an adult tell different stories and both swear they're telling the truth, adult jurors are more
likely to believe the adult, Dekle said.
"You have all these things working against you in a child sex abuse case. Prosecutors normally try to be
very careful in filing those cases because they know what they're getting into. There is no such thing as
an iron-clad child sexual abuse case."
Find this article at:
http://www.palmbeachpost.com/localnews/content/local_news/epaper/2006/08/04/s1b_epstein_0804.htm
Check the box to include the list of links referenced in the article.
http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=lgnorance+ofaget. 1/2/2008
EFTA00013771


