# docs_fts_content

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=== Page 1 ===
$ 2635.101 Basic obligation of public service., 5 C.F.R. $ 2635.101
Code of Federal Regulations
Title 5. Administrative Personnel
Chapter XVI. Office of Government Ethics
Subchapter B. Government Ethics
Part 2635. Standards of Ethical Conduct for Employees of the Executive Branch (Refs & Annos)
Subpart A. General Provisions
5 C.F.R. $ 2635.101
§ 2635.101 Basic obligation of public service.
Currentness
(a) Public service is a public trust. Each employee has a responsibility to the United States Government and its citizens to
place loyalty to the Constitution, laws and ethical principles above private gain. To ensure that every citizen can have complete
confidence in the integrity of the Federal Government, each employee shall respect and adhere to the principles of ethical conduct
set forth in this section, as well as the implementing standards contained in this part and in supplemental agency regulations.
(b) General principles. The following general principles apply to every employee and may form the basis for the standards
contained in this part. Where a situation is not covered by the standards set forth in this part, employees shall apply the principles
set forth in this section in determining whether their conduct is proper.
(1) Public service is a public trust, requiring employees to place loyalty to the Constitution, the laws and ethical principles
above private gain.
(2) Employees shall not hold financial interests that conflict with the conscientious performance of duty.
(3) Employees shall not engage in financial transactions using nonpublic Government information or allow the improper
use of such information to further any private interest.
(4) An employee shall not, except as permitted by subpart B of this part, solicit or accept any gift or other item of monetary
value from any person or entity seeking official action from, doing business with, or conducting activities regulated by
the employee's agency, or whose interests may be substantially affected by the performance or nonperformance of the
employee's duties.
(5) Employees shall put forth honest effort in the performance of their duties.
(6) Employees shall not knowingly make unauthorized commitments or promises of any kind purporting to bind the
Government.
(7) Employees shall not use public office for private gain.
WESTLAW © 2022 Thomson Reuters. No claim to original U.S. Government Works.
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EFTA00009794

=== Page 2 ===
§ 2635.101 Basic obligation of public service., 5 C.F.R. § 2635.101
(8) Employees shall act impartially and not give preferential treatment to any private organization or individual.
(9) Employees shall protect and conserve Federal property and shall not use it for other than authorized activities.
(10) Employees shall not engage in outside employment or activities, including seeking or negotiating for employment,
that conflict with official Government duties and responsibilities.
(11) Employees shall disclose waste, fraud, abuse, and corruption to appropriate authorities.
(12) Employees shall satisfy in good faith their obligations as citizens, including all just financial obligations, especially
those-such as Federal, State, or local taxes-that are imposed by law.
(13) Employees shall adhere to all laws and regulations that provide equal opportunity for all Americans regardless of
race, color, religion, sex, national origin, age, or handicap.
(14) Employees shall endeavor to avoid any actions creating the appearance that they are violating the law or the ethical
standards set forth in this part. Whether particular circumstances create an appearance that the law or these standards have
been violated shall be determined from the perspective of a reasonable person with knowledge of the relevant facts.
(c) Related statutes. In addition to the standards of ethical conduct set forth in this part, there are conflict of interest statutes
that prohibit certain conduct. Criminal conflict of interest statutes of general applicability to all employees, 18 U.S.C. 201, 203,
205, 208, and 209, are summarized in the appropriate subparts of this part and must be taken into consideration in determining
whether conduct is proper. Citations to other generally applicable statutes relating to employee conduct are set forth in subpart
I and employees are further cautioned that there may be additional statutory and regulatory restrictions applicable to them
generally or as employees of their specific agencies. Because an employee is considered to be on notice of the requirements
of any statute, an employee should not rely upon any description or synopsis of a statutory restriction, but should refer to the
statute itself and obtain the advice of an agency ethics official as needed.
SOURCE: 57 FR 35041, Aug. 7, 1992; 62 FR 48747, Sept. 17, 1997, unless otherwise noted.
AUTHORITY: 5 U.S.C. 7301, 7351, 7353; 5 U.S.C. App. (Ethics in Government Act of 1978); E.O. 12674, 54 FR 15159, 3
CFR, 1989 Comp., p. 215, as modified by E.O. 12731, 55 FR 42547, 3 CFR, 1990 Comp., p. 306.
Notes of Decisions (41)
Current through Nov. 14, 2022, 87 FR 68310. Some sections may be more current. See credits for details.
End of Document
© 2022 Thomson Reuters. No claim to original U.S. Government Works.
WESTLAW © 2022 Thomson Reuters. No claim to original U.S. Government Works.
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=== Page 1 ===
From:
To:
Cc:
Subject: PCU Updates
Date: Fri, 08 Jan 2021 20:31:32 +0000
Attachments: PC_Unit_-_Short_Form_Update.1.8.21_(002).docx
Attached
Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of N
el.
EFTA00013269


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=== Page 1 ===
From: Chris Dilorio
To:
EFTA00009904

=== Page 2 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
Date: Mon, 06 May 2019 12:38:47 +0000
Attachments: IMG_7021.jpg
Inline-Images: image.png
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.
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/apolo-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
EFTA00009905

=== Page 3 ===
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:
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
EFTA00009906

=== Page 4 ===
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:
Subject: Fw: Apollo/ Epstein/Kushner connection
ESWW: A money laundering NASDAQ/OTCM shell
Milken degenerate Leon Black/Joshua Harris: Apollo
AND
EFTA00009907

=== Page 5 ===
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 | 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
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
EFTA00009908

=== Page 6 ===
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/
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 I WilmerHale
EFTA00009909

=== Page 7 ===
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
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
EFTA00009910

=== Page 8 ===
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&ClK=0001082278&owner=exclude&count=40&hidefilings=0
Florida?
Pennsylvania?
or
Canada?
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
EFTA00009911

=== Page 9 ===
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
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
EFTA00009912

=== Page 10 ===
$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!
Fucking A
I am good
Cheers!
Christopher Dilorio
EFTA00009913


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=== Page 1 ===
From:
To:
Cc:
Subject: Hearing re Epstein's Computer Equipment
Date: Tue, 11 Sep 2007 16:00:08 +0000
Importance: Normal
Judge Marra has set us for Tuesday (a week from today) at 9:00. The witness is due to appear before the grand
jury that afternoon. I am calling Roy Black now.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
EFTA00013608


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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
November 9, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These materials are
stamped with control numbers SDNY_GM_02767074 through SDNY_GM_02771980.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. The Department of Justice directed this office to cease the dissemination of materials
marked with the word "confidential" in order to avoid potential confusion with markings reserved
for classified documents. Accordingly, in order to note the appropriate designation of this
production under the operative Protective Order in this case, the materials being produced today
are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,
8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective
Order that govern today's production.
An index of the materials contained in this production is below:
EFTA00010133

=== Page 2 ===
Page 2
Bates Start
Bates End
Summary Description
Confidential Designation
SDNY GM 02767074
SDNY GM 02771980
SDFL Files¹
Confidential
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
I These materials appear to be largely duplicative of materials previously produced to you in
discovery.
EFTA00010134


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=== Page 1 ===
From: "
(USAFLS)"
To:
(USAFLS)"
Subject: RE: Any word on Epstein?
Date: Fri, 28 Mar 2008 18:38:04 +0000
Importance: Normal
I heard you had knee surgery. Hope everything is okay.
I explained to
that our grand jury will not have a quorum on April 8th, so if we do not indict on April 1st we
have to wait until the 15th.
Assistant U.S. Attorney
Fax 561 820-8777
From:
(USAFLS)
Sent: Friday, March 28, 2008 10:25 AM
To:
(USAFLS)
Subject: RE: Any word on Epstein?
No but I'll see what I can find out.
From:
. (USAFLS)
Sent: Thursday, March 27, 2008 2:20 PM
To:
(USAFLS);
(USAFLS)
Cc:
(USAFLS)
Subject: Any word on Epstein?
Hi all - I am finally home from the hospital. I was wondering whether you have heard anything.
Thank you.
Assistant U.S. Attorney
Fax 561 820-8777
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=== Page 1 ===
From:
"
\(USAFLS\)"
To:
\(USAFLS\)"
Subject: RE: Judge Marra -- Epstein -- Urgent
Date: Tue, 11 Sep 2007 13:54:07 +0000
Importance: Normal
I left a message.
Assistant U.S. Attorney
Phone
Fax 561 820-8777
From:
(USAFLS)
Sent: Tuesday, September 11, 2007 9:50 AM
To:
(USAFLS)
Subject: RE: Judge Marra -- Epstein -- Urgent
Yes.
From:
- (USAFLS)
Sent: Tuesday, September 11, 2007 9:49 AM
To:
(USAFLS)
Subject: Judge Marra -- Epstein -- Urgent
Importance: High
Hi
- Sorry, while we were talking Judge Marra's CRD called to see if we can do the hearing on Epstein's
motion to quash tomorrow morning. Do you want me to put it off?
Assistant U.S. Attorney
Phone
Fax 561 820-8777
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=== Page 1 ===
EXHIBIT 1

=== Page 2 ===
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case
UNITED STATES DISTRICT COURT
for the
Southern District of New York
United States of America
)
Ghislaine V. Maxwell
)
)
Case No. 20CR330 (AJN)
)
Defendant
)
SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR
OBJECTS IN A CRIMINAL CASE
To:
(Name of person to whom this subpoena is directed)
YOU ARE COMMANDED to produce at the time, date, and place set forth below the following books, papers,
documents, data, or other objects:
See Attachment A
Place:
United States District Court
Date and Time:
11/29/2021 8:30 am
Southern District of New York, Courtroom 318
40 Foley Square, New York, NY 10007
Certain provisions of Fed. R. Crim. P. 17 are attached, including Rule 17(c)(2), relating to your ability to file a
motion to quash or modify the subpoena; Rule 17(d) and (e), which govern service of subpoenas; and Rule 17(g),
relating to your duty to respond to this subpoena and the potential consequences of not doing so.
(SEAL)
Date:
CLERK OF COURT
Signature of Clerk or Deputy Clerk
The name, address, e-mail, and telephone number of the attorney representing (name of party)
Ghislaine Maxwell
, who requests this subpoena, are:
Jeffrey S. Pagliuca, Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203,
Notice to those who use this form to request a subpoena
Before requesting and serving a subpoena pursuant to Fed. R. Crim. P. 17(c), the party seeking the subpoena is advised to
consult the rules of practice of the court in which the criminal proceeding is pending to determine whether any local rules
or orders establish requirements in connection with the issuance of such a subpoena. If no local rules or orders govern
practice under Rule 17(c), counsel should ask the assigned judge whether the court regulates practice under Rule 17(c) to
1) require prior judicial approval for the issuance of the subpoena, either on notice or ex parte; 2) specify where the
documents must be returned (e.g., to the court clerk, the chambers of the assigned judge, or counsel's office); and 3)
require that counsel who receives produced documents provide them to opposing counsel absent a disclosure obligation
under Fed. R. Crim. P. 16.
Please note that Rule 17(c) (attached) provides that a subpoena for the production of certain information about a victim
may not be issued unless first approved by separate court order.
EFTA00010225

=== Page 3 ===
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 2)
Case No. 20CR330 (AJN)
PROOF OF SERVICE
This subpoena for (name of individual and title, if any)
was received by me on (date)
-
I served the subpoena by delivering a copy to the named person as follows:
on (date)
: or
I returned the subpoena unexecuted because:
Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of
$
My fees are $
for travel and $
for services, for a total of $
0.00
I declare under penalty of perjury that this information is true.
Date:
Server's signature
Printed name and title
Server's address
Additional information regarding attempted service, etc.:
Print
Save As...
Add Attachment
Reset
EFTA00010226

=== Page 4 ===
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 3)
Federal Rule of Criminal Procedure 17 (c), (d), (e), and (g) (Effective 12/1/08)
(c) Producing Documents and Objects.
(1) In General. A subpoena may order the witness to produce any books, papers, documents, data, or other objects the subpoena
designates. The court may direct the witness to produce the designated items in court before trial or before they are to be offered in
evidence. When the items arrive, the court may permit the parties and their attorneys to inspect all or part of them.
(2) Quashing or Modifying the Subpoena. On motion made promptly, the court may quash or modify the subpoena if compliance
would be unreasonable or oppressive.
(3) Subpoena for Personal or Confidential Information About a Victim. After a complaint, indictment, or information is filed, a
subpoena requiring the production of personal or confidential information about a victim may be served on a third party only by court
order. Before entering the order and unless there are exceptional circumstances, the court must require giving notice to the victim so that
the victim can move to quash or modify the subpoena or otherwise object.
(d) Service. A marshal, a deputy marshal, or any nonparty who is at least 18 years old may serve a subpoena. The server must deliver a copy
of the subpoena to the witness and must tender to the witness one day's witness-attendance fee and the legal mileage allowance. The server
need not tender the attendance fee or mileage allowance when the United States, a federal officer, or a federal agency has requested the
subpoena.
(e) Place of Service.
(1) In the United States. A subpoena requiring a witness to attend a hearing or trial may be served at any place within the United
States.
(2) In a Foreign Country. If the witness is in a foreign country, 28 U.S.C. $ 1783 governs the subpoena's service.
(g) Contempt. The court (other than a magistrate judge) may hold in contempt a witness who, without adequate excuse, disobeys a subpoena
issued by a federal court in that district. A magistrate judge may hold in contempt a witness who, without adequate excuse, disobeys a
subpoena issued by that magistrate judge as provided in 28 U.S.C. $ 636(e).
EFTA00010227

=== Page 5 ===
ATTACHMENT A
DEFINITIONS
1. "You" or "Your" means any owner, shareholder, partner or employee of the Epstein Victim's
Compensation Program ("EVCP"), and any former owner, shareholder, partner or employee
of the EVCP.
2. "Accusers" or "Accuser" means
3. Attorneys means legal counsel for any Accuser or the EVCP.
4. "Communication" means all forms of correspondence, including regular mail, email, text
message, memorandum, or other written communication of information of any kind.
5. "EVCP Material" refers to any submission to the Epstein Victim's Compensation Program
made by an Accuser, including any claims on behalf of persons who have accused Jeffrey
Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their
Attorneys, and any compensation received by an Accuser.
INSTRUCTIONS
1. Production of documents and items requested herein shall be made in person to United States
District Court, Southern District of New York, 40 Foley Square, New York, NY 10007,
Courtroom 318.
2. This Request calls for the production of all responsive Documents in Your possession,
custody or control without regard to the physical location of such documents.
3. If any Document was in your possession or control, but is no longer, state what disposition
was made of said Document, the reason for the disposition, and the date of such disposition.
4. In producing Documents, if the original of any Document cannot be located, a copy shall be
produced in lieu thereof, and shall be legible and bound or stapled in the same manner as the
original.
5. Any copy of a Document that is not identical shall be considered a separate document.
6. All Documents shall be produced in the same order as they are kept or maintained by You in
the ordinary course of business.
7. Responsive electronically stored information (ESI) shall be produced in its native form; that
is, in the form in which the information was customarily created, used and stored by the
native application employed by the producing party in the ordinary course of business.
8. Defendant does not seek and does not require the production of multiple copies of identical
Documents.
9. This Request is deemed to be continuing. If, after producing these Documents, you obtain or
EFTA00010228

=== Page 6 ===
become aware of any further information, Documents, things, or information responsive to
this Request, you are required to so state by supplementing your responses and producing
such additional Documents to Defendant.
DOCUMENTS OR THINGS TO BE PRODUCED
1. Any and all EVCP Material submitted by each Accuser, not limited to Claim Forms and
supporting submissions made by each Accuser;
2. Communications between the EVCP to each of the Accusers and/ or their Attorneys;
3. Copies of any payments to the Accusers and their Attorneys;
4. Any and All Releases executed by the Accusers.
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EXHIBIT 1

=== Page 8 ===
Independent
Epstein Victims' Compensation Program
PROTOCOL
May 29, 2020
I.
PURPOSE AND OVERVIEW
The Epstein Victims' Compensation Program (the "Program") is a voluntary, independent Program that
has been established to compensate and resolve the claims of victims-survivors of sexual abuse by
Jeffrey Epstein ("Epstein").
The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims
administration experts Kenneth R. Feinberg, Camille S. Biros and
to design the
Program. Ms.
will also serve as the Administrator of the Program (the "Administrator"). This
Protocol reflects input from victims-survivors, their lawyers, other potentially interested parties, and
representatives of the Estate.
Through the Program, the Estate wishes to acknowledge the wrongs endured by victims-survivors and
offer them an opportunity to voluntarily resolve their individual claims for such sexual abuse.
The Program is governed by the following non-exclusive guiding principles:
The Program is purely voluntary. It does not affect any rights a Claimant may have
unless and until the Claimant accepts the offered compensation and executes a
Release. A Claimant may reject the offer of compensation and may stop
participating in the Program and withdraw the claim at any time prior to execution
of the Release.
The Program is independent and will in no way be administered, controlled or
overseen by the Estate. The Administrator is responsible for all decisions relating to
the review, processing and evaluation of individual claims submitted to the
Program. The Administrator will have final, binding and exclusive authority to
determine Claimant eligibility and the valuation of each eligible individual claim.
Decisions of the Administrator made pursuant to this Protocol are not subject to
review or modification in any way by the Estate or any other party or entity.
There is no cap or limitation on the aggregate amount of funds available to
compensate all eligible Claimants or on the amount of compensation to be made to
each individual Claimant. Each individual claim will be evaluated separately by the
Administrator. The Administrator will determine, in her sole and exclusive
discretion, issues of eligibility and the amount of compensation and the Estate will
pay all eligible claims based on the Administrator's determination.
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All Claimants will be treated with respect, dignity and fairness without regard to
race, color, sexual orientation, national origin, religion, gender or disability. To
ensure claims will be adjudicated fairly, the Administrator will manage the process
so that all Claimants can equally access the Program's claim process. Individuals
with disabilities will be given the opportunity to effectively communicate their
claims and to request special process accommodations.
The Program is available to all victims-survivors regardless of where they were harmed, when they were
harmed, whether the claim is time-barred by the applicable statute of limitations, and whether they
have previously filed a lawsuit against or settled with Epstein and/or the Estate.
The exclusive claims period for filing a claim pursuant to this Protocol shall commence on the to-be-
determined Effective Date and shall conclude nine (9) months after that date ("Filing Deadline"). All
individual claims filed with the Program must be filed within this period.
To complement the Program's resources, the Administrator will, at her discretion and with the consent
of the Claimant, consult with Professor Marci A. Hamilton, a nationally recognized sexual abuse expert,
leading legal academic and advocate of victims' rights. Ms. Hamilton's role will be to further inform the
Administrator and her staff about the dynamics of sexual abuse, common responses to sexual abuse,
and the impact of sexual abuse on victims; to serve as a resource for the Administrator in developing or
updating policies and procedures; to advise the Administrator regarding sensitivities involved in
interactions with victims; and to serve as a referral source for the Administrator in providing post-
determination information to claimants who seek guidance, counseling or other services. The
Administrator may, at her discretion and with the Claimant's prior written consent, request that Ms.
Hamilton review an individual claimant file. The Administrator will determine on a case-by-case basis, in
her discretion, the need to anonymize individual claimants' files before sharing them with Ms. Hamilton.
As set forth above, the Administrator is solely responsible for all decisions relating to the administration
of the Program, including the review, processing, evaluation, and determination of individual claims
submitted to the Program.
During the term of the Program, Ms. Hamilton will not meet or speak with a Claimant or her
representatives concerning any aspect of the Program without the Administrator present. Ms. Hamilton
will maintain in strict confidence and will not disclose outside the Program any information she obtains
through her participation in the Program, including individual Claimants' submissions.
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II.
ELIGIBILITY REQUIREMENTS
A. Eligibility Criteria
The persons eligible to participate in this Program are individuals who allege they were sexually abused
by Epstein. In addition, the following criteria apply:
The claim of sexual abuse must be directed against Epstein.
An individual whose claim is time-barred by the applicable statute of limitations may
participate in the Program provided that other eligibility criteria are met.
An individual who previously entered into a settlement agreement resolving a claim of sexual
abuse against Epstein may participate in the Program provided that other eligibility criteria are
met.
An individual who allegedly assisted Epstein in procuring other victims-survivors may
participate in the Program where there is a credible basis to determine that the individual
acted under duress as a result of her own sexual abuse by Epstein, provided that other
eligibility criteria are met.
If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with
prejudice any existing lawsuits, legal actions or claims filed against the Estate or related entities
and/or related individuals. The Claimant must provide proof of such dismissal along with or
prior to the signed acceptance of the compensation determination offer letter and executed
Release in order to receive payment.
B. Legal Representatives of Claimants
An individual may file a claim on a victim's behalf where that individual has been granted legal authority
to act in a representative capacity pursuant to appropriate law. The "Legal Representative" of an
individual Claimant shall mean: (1) in the case of a Claimant who is currently a minor, a parent or legal
guardian authorized by law to serve as the minor's legal representative; (2) in the case of an
incompetent or legally incapacitated Claimant, a person who has been duly appointed as the Claimant's
legal representative in accordance with applicable law; (3) in the case of a deceased Claimant, a person
who has been duly appointed to act as the personal representative of the Claimant's estate by a court of
competent jurisdiction and is authorized to file and compromise a claim; or (4) an attorney authorized to
represent the Claimant for purposes of pursuing a claim through this Program.
Legal Representatives must provide proper documentation demonstrating representative capacity. Such
proof may include a power of attorney; documentation showing the individual's appointment as
guardian or guardian ad litem; documentation showing the individual's appointment as personal
representative of the Claimant's estate (such as letters of administration); a copy of a retainer
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agreement showing legal representation signed by both the Claimant and the attorney or a signed
statement by an adult Claimant and the attorney that a licensed/admitted attorney is acting on her
behalf.
III.
CLAIMS ADMINISTRATION - SUBMISSION, EVALUATION AND DETERMINATION
A. Claims Submission Process
Individuals who have filed a lawsuit, legal action or claim against Epstein and/or the Estate or have
otherwise been identified as a victim of Epstein by their attorney to the Administrator on or before the
Effective Date will be sent a Claim Form and other relevant Program information, including Instructions
for completion and submission of the Claim Form and a copy of this Protocol. Individuals who have filed
a lawsuit need not agree to a stay of litigation or make any other concession in any pending litigation to
be eligible to participate in the Program. Likewise, individuals who have not yet filed a lawsuit remain
free to file a lawsuit and engage in litigation concurrently with participation in the Program. Individuals
must, however, dismiss with prejudice any and all existing lawsuits, legal actions and claims prior to or at
the time of acceptance of a compensation determination offer in order to receive payment.
Individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the Estate or have
not otherwise been identified as a victim of Epstein by their attorney to the Administrator on or before
the Effective Date may register to participate in this Program on the Program's website at
www.EpsteinVCP.com. To register, such individuals must complete a questionnaire setting forth their
name, contact information, a summary description of the nature of the claim and other requested
information. Upon registration, the Administrator will perform a preliminary review to consider if the
individual is eligible to participate in the Program. If the Administrator deems that the individual is
eligible to participate in the Program, she will then send that individual a Claim Form and other relevant
Program information.
Note: The fact that an individual is sent a Claim Form and other relevant Program information indicates
that the Administrator has determined that such individual is eligible to participate in the Program. It
does not indicate that the Administrator has determined that such individual is eligible to receive
compensation. That determination is made only after a Claim Form and all required documentation has
been submitted and evaluated by the Administrator.
Registrations for individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the
Estate or have not otherwise been identified as a victim of Jeffrey Epstein by their attorney to the
Administrator on or before the Effective Date will be accepted by the Administrator from the Effective
Date through a date that is 45 days prior to the Filing Deadline ("Registration Deadline"). It is important
to note that the Registration Deadline is separate from, and precedes, the Filing Deadline. As explained
above, all claims must be filed by the Filing Deadline.
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=== Page 12 ===
All Claim Forms must be completed to the best of a Claimant's ability and filed no later than the Filing
Deadline. Claim Forms should be uploaded to the Program website at www.EpsteinVCP.com, or mailed
via overnight courier (a pre-paid courier voucher will be included with each packet) to the Administrator
at the following address:
Epstein Victims' Compensation Program
Attn:
Administrator
1050 Connecticut Ave., NW
#65488
Washington, D.C. 20035
Claimants are invited to provide documentation identified in the Claim Form, and any other
corroborating or supporting information sufficient to substantiate the claim, satisfy eligibility
requirements, and allow the Administrator to review, process and evaluate the claim. If the claim is
being presented by a Legal Representative, then the Legal Representative will be responsible for
submitting the necessary documentation relating to the represented Claimant.
Additional documentation may be requested at the discretion of the Administrator. Both the Claimant
and the Estate will be afforded the opportunity to submit to the Administrator any information deemed
relevant to the Administrator's evaluation and determination of the claim before the Administrator's
final disposition of the claim.
If a Claimant submits an incomplete or deficient claim, the Administrator will notify the Claimant,
explain the additional information that is needed, and work with the Claimant or the Claimant's Legal
Representative (where applicable) to assist in submitting a complete claim.
B. Claims Evaluation and Determination
Claims will be evaluated in the order in which they are received, with the Administrator evaluating each
submitted individual claim in a prompt and fair manner. Claims will only be determined once all
required documentation has been submitted to the Administrator, with due consideration granted to
Claimant's good faith explanations for delays and/or absence of documentation.
1. Factors Considered in Evaluating Claims
As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
information available, whether the allegations of sexual abuse are credible. The Administrator will
consider appropriate factors and corroborative support, including but not limited to:
The level of documentation, corroboration or other circumstantial evidence regarding the
nature and extent of the abuse, the frequency, location and other details of the abuse, and the
age of the victim at the time of the abuse. Non-exhaustive examples of such evidence include
(i) medical or psychiatric counseling/therapy records relevant to the abuse, and
(ii) contemporaneous written notification or other correspondence (e.g., letters, emails) of the
abuse by the Claimant to law enforcement authorities, parents, friends or others. The
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=== Page 13 ===
Administrator acknowledges that some Claimants may not be able to provide any
documentation to corroborate their Claim based on the nature and circumstances of Epstein's
conduct. If a Claimant's written and oral presentation is deemed to be credible by the
Administrator, the Claimant may still be eligible for compensation under the Program.
Whether there exists any information and/or pertinent findings offered by the appropriate
Office of the District Attorney, United States Attorney's Office, or other law enforcement
agency.
Whether the Administrator finds the claims of the individual to be credible after complete
review of all relevant documentation and other evidence provided by the Claimant and the
Estate.
As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
information available, the amount of compensation that should be offered to each eligible Claimant.
The Administrator will consider appropriate factors and corroborative support, including but not limited
to:
The nature, duration and extent of the sexual abuse suffered by the Claimant.
The age of the Claimant at the time of the sexual abuse.
The nature and extent of the Claimant's physical or psychological damage resulting from the
sexual abuse, and the effect of the sexual abuse on the Claimant.
The credibility of the claim based upon all of the facts and circumstances, supporting
documentation and corroborating evidence.
Whether the Claimant previously entered into a settlement agreement with Epstein and
received a payment pursuant to such agreement.
The Administrator will confidentially send the Claimant a compensation determination offer letter
including the following: (1) the Administrator's eligibility decision regarding the claim; (2) the amount of
compensation offered; (3) a Release to be signed by the Claimant if the Claimant accepts the offered
compensation; and (4) a Payment Option Form. The Administrator's offer shall be valid for 60 days from
the date of the compensation determination offer letter.
The Administrator's determinations in this Program will not be binding on any potential criminal
investigation involving Claimant's claims.
2. Opportunities to be Heard
The Claimant will be afforded an opportunity to be heard, either before or after the Administrator
renders her determination. Upon request by the Claimant, the Administrator will be available to meet in
person (as practicable in light of the COVID-19 pandemic), by video conference, or by teleconference to
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=== Page 14 ===
further discuss the claim. These meetings are completely optional and voluntary. Requests to meet
with the Administrator should be sent by email to ClaimantServices@EpsteinVCP.com and will be
scheduled at a mutually convenient time and location. The Administrator may also request a meeting
with a Claimant or her Legal Representative at a reasonable mutually convenient time and location,
though the Claimant is not obligated to attend any such meeting.
3. Release
By submitting a claim to the Program, a Claimant is seeking to resolve all claims relating to allegations
of sexual abuse against Epstein and/or the Estate, and related entities and individuals as set forth in the
Release. If a Claimant chooses to accept the offer of compensation pursuant to the Program, the
Claimant will be required to sign and execute a full Release, in a form satisfactory to the Estate, of all
past and future claims (including lis pendens, writs of attachment, etc.) relating to such allegations of
sexual abuse against the Estate, related entities and/or related individuals. A Claimant may reject the
offer of compensation and may stop participating in the Program and withdraw the claim at any time
prior to the execution of the Release.
The Release will waive any rights the Claimant and her heirs, descendants, legatees or beneficiaries
may have to assert any claims relating to allegations of sexual abuse against the Estate, related
entities and/or related individuals, to file an individual legal action relating to such allegations, or to
participate in any civil legal action associated with such allegations, except as a witness. However,
the Release will not operate to preclude or limit the Claimant's ability to report and discuss
allegations of sexual abuse with law enforcement officials or anyone else. In other words, the
Release will not impose any rules of confidentiality on claimants, who are expressly permitted to
discuss their allegations without restriction, should they choose.
Before signing a Release, the Claimant must consult with an attorney selected by the Claimant. If the
Claimant is not represented by an attorney, the Program will provide an attorney to provide free legal
counseling to the Claimant for the sole purpose of advising the Claimant concerning the language and
binding nature of the Release.
No one affiliated with the Program will provide tax or legal advice to those receiving payments under
the Program. Claimants are urged to consult with a tax advisor concerning any questions regarding
tax liability for payments pursuant to the Program.
4. Payments
Upon the Claimant's acceptance of the Administrator's determination, the Administrator's receipt of
the Claimant's executed Release and, where applicable, dismissal with prejudice of any existing
lawsuit, legal actions or claims against the Estate or related entities and/or related individuals, the
Administrator will initiate payment by check or electronic funds transfer to each eligible Claimant as
directed by the Claimant. Checks will be sent to Claimants via overnight courier service. All
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=== Page 15 ===
payments made under the Program shall be for a Claimant's physical injuries, physical sickness and
resulting emotional distress within the meaning of Section 104(a) of the Internal Revenue Code.
C. Program Integrity
For the purpose of protecting both the integrity of the Program and financial resources for eligible
Claimants, the Administrator will institute all necessary measures to prevent payment of fraudulent
claims, including taking steps to verify claims and analyze submissions for inconsistencies,
irregularities or duplication.
Each Claimant who signs the Claim Form at the time of submission certifies that the information
provided in the Claim Form is true and accurate to the best of the Claimant's knowledge, and that the
Claimant understands that false statements or claims made in connection with such submission may
result in fines, imprisonment and/or any other remedy available by law. Claims that appear to be
potentially fraudulent or to contain information known by the Claimant to be false when made will be
forwarded to federal, state or local law enforcement agencies and/or the appropriate Office of the
District Attorney and/or United States Attorney's Office for possible investigation and prosecution.
D. Confidentiality/Privacy
The Program is confidential.¹ By filing a claim with the Program, the Claimant or her Legal
Representative (where applicable) agrees that information submitted by the Claimant pursuant to
the Program will be used and/or disclosed by the Administrator and her designees only for the
following purposes:
1) Processing and evaluating the Claimant's claim;
2) Administering the Program and other Program-related work; and
3) Reports to law enforcement where appropriate, related to potentially fraudulent claims.
When documents or other information maintained or submitted by the Estate become part of a
Claimant's file for purposes of the Program, such materials will be reviewed by the Administrator to
assist in processing and evaluating the claim, but will otherwise remain confidential. No information
provided by Claimants will be provided to the Estate except for the Claimant's name and the date(s)
and location(s) of the alleged abuse, for the sole purpose of processing and evaluating the claim and,
for purposes of the Release, the names of any other individual(s) to whom or by whom the Claimant
alleges she was trafficked or sexually abused. The Estate has agreed that no information obtained
solely through the Program will be disclosed publicly or used by the Estate in defending itself from any
claim, regardless of forum. The Program's files are not available for inspection, review or copying by
the Estate or the Claimant or her representatives during or after the Program, and all pertinent
1 All parties agree that they are using the services of a third-party administrator to help reach a resolution of individual claims
of sexual abuse, and that this Program is entitled to confidentiality, privileges (mediation, settlement and all other pertinent
privileges), and protection from disclosure under applicable law.
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=== Page 16 ===
mediation privileges, settlement privileges and other privileges apply.
To protect the privacy of Claimants participating in the Program, all personal information provided by
the Claimant during this process will be returned or destroyed within one year after the conclusion of
the Program.
Individual Claimants are not bound through the Program by any rules of confidentiality. Claimants may,
at their sole and voluntary option, disclose information in their possession regarding their claim, their
compensation and their experience with the Program.
All confidentiality requirements are subject to law, regulation and judicial process.
E. Reporting
The Administrator shall, on a monthly basis, confidentially provide reports regarding the number and
total value of claims paid each month to the Probate Court of the United States Virgin Islands and the
Attorney General of the United States Virgin Islands. Such reports will report on an aggregate level
only. No individual Claimant information will be published or disclosed in a way that compromises
Claimant confidentiality.
9 I Page
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From:
(USANYS)"
To:
(USANYS) 4"
(USANYS)"
,
Cc:
(USANYS)"
Subject: CAFIs/Epstein
Date: Sun, 30 Jun 2019 20:49:19 +0000
Importance: Normal
For those interested, the call from Friday is being rescheduled for tomorrow (Monday) at 2. I don't have dial-in info yet,
but will circulate a calendar invite shortly.
EFTA00010583


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=== Page 1 ===
From:
To:
Subject: RE: Epstein
Date: Wed, 31 Oct 2007 13:52:55 +0000
Importance: Normal
Thanks
From:
Sent: Wednesday. October 31, 2007 9:52 AM
To:
Subject: RE: Epstein
Hi
The agreement says that they will not contest liability as to the girls on our list. Discovery may be
relevant to the issue of the amount of damages suffered, but not the veracity of the claims.
From:
Sent: Tuesday, October 30, 2007 5:39 PM
To: Jay Lefkowitz
Subject: RE: Epstein
I called Judge Davis before I sent him the agreed upon letter. He indicated his willingness to serve as the "decider." I will
call him tomorrow to see whether anything has changed and when we can anticipate a decision. Regarding the subpoena
question, let me think about that overnight. Thanks,
From: Jay Lefkowitz [mailto:
Sent: Tuesday, October 30, 2007 4:54 PM
To:
Cc: Acosta, Alex (USAFLS)
Subject: Re: Epstein
Thanks
I haven't heard anything from Judge Davis. I assume he is still willing to take on the role you asked him to take on, but can you please
let me know if that is not the case?
Also, we are beginning to think about what discovery we may need to take to verify any claims. I am assuming that your office does
not want to be copied on any subpoenas or anything related to discovery. But please let me know if that is an incorrect assumption.
Thanks Jay
EFTA00013750

=== Page 2 ===
Original Message
From:
Sent: 10/30/200702:42 PM AS1
To: Jay Lefkowitz
Cc: "Acosta, Alex (USAFLS)"
Subject: Epstein
Jay,
Here is an executed version of the addendum. Please Fed Ex the original signature pages to me. Thanks,
<<epstein addendum 10 30.pdf>>
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.
EFTA00013751


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=== Page 1 ===
From:
To:
Subject: RE: Screenshot 2019-08-10 at 2.39.44 PM
Date: Sat, 10 Aug 2019 18:41:22 +0000
Attachments: Jeffrey_Epstein_Statementv2.docx
Think I got it. How is it now?
Original Message
From:
Sent: Saturday, August 10, 2019 2:40 PM
To:
Subject: Screenshot 2019-08-10 at 2.39.44 PM
This is what I'm seeing
EFTA00013179


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=== Page 1 ===
From:
To: "Jay Lefkowitz"
Cc:
"Acosta, Alex (USAFLS)"
<AAcosta@usa.doj.gov>
Subject: Epstein - Addendum and Letter to Judge Davis
Date: Wed, 24 Oct 2007 19:45:10 +0000
Importance: Normal
Attachments: Addendum.wpd; 071015_Special_Master_Letter4.wpd
Jay,
Pursuant to our conversation, here is the revised letter and a new addendum. The only change to the addendum is that I
renumbered the new paragraphs from A,B, and C to 7A, 7B, and 7C. Once you approve, I will contact Judge Davis and send
him the letter. Please execute the addendum, PDF the executed original to me as soon as possible and Fed Ex the original
to me thereafter.
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From:
"
To:
Cc: "
Subject: Barr on Epstein
Date: Wed, 16 Jan 2019 20:49:06 +0000
Importance: Normal
https://www.c-span.org/video/?456626-1/attorney-general-nominee-william-barr-confirmation-hearing
Exchange with Sen. Sasse begins around 5:13:00.
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
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From:
To:
Subject: Bob Josefsberg
Date: Mon, 25 Aug 2008 20:40:45 +0000
Importance: Normal
- He has not heard back from Epstein's folks either. I will draft a letter to
regarding the victim list
and will raise the issue again.
Thanks.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
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Event: Epstein
Start Date: 2009-06-05 15:00:00 +0000
End Date: 2009-06-05 15:30:00 +0000
Organizer:
Location:
Office
Class: X-PERSONAL
Date Created: 2015-04-04 00:22:37 +0000
Date Modified: 2015-07-22 20:34:56 +0000
Priority: 5
DTSTAMP: 2009-06-03 20:37:29 +0000
Attendee:
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From:
(USANYS) 4"
To:
"
(USANYS)"
Cc:
"
(USANYS)"
)"
)"
,
)"
(USANYS)"
Subject: Re: CAFIs/Epstein
Date: Mon, 01 Jul 2019 13:32:38 +0000
Importance: Normal
Thanks,
I won't be able to join today, but happy to help if any issues come up.
On Jun 30, 2019, at 4:49 PM,
(USANYS)
wrote:
For those interested, the call from Friday is being rescheduled for tomorrow (Monday) at 2. I don't have dial-in info yet,
but will circulate a calendar invite shortly.
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=== Page 1 ===
From: Nicole Simmons
To: Nathan NYSD Chambers
Cc: Jeff Pagliuca
Laura Menninger
Subject: [EXTERNAL] U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp Ltrs. re. Co-
Conspirator Statements and Ex. 52]
Date: Mon, 15 Nov 2021 22:55:29 +0000
Attachments: 2021.11.15_JSP_Ltr_re_Rule_801(d)(2)(e).pdf; 2021.11.15_JSP_Ltr_re._EX._52.pdf
Inline-Images: image001.jpg
Dear Judge Nathan:
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Letters in Response to (1) The Government's
Justification for Admission of Co-Conspirator Statements and (2) The Government's Justification for Admission of Exhibit
52.
Pursuant to our established protocol, we are submitting the Letters to the Court under temporary seal to allow the
government to propose any redactions it deems necessary.
Regards,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
150 East 10th Avenue
Denver, Colorado
80203
PH
FX
DIRECT:
www.hmmaw.com
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From:
(USAFLS)"
To:
(USAFLS)"
Subject: Read: RE: Working on a story on deadline re: Jeffrey Epstein
Date: Fri, 19 Sep 2008 20:06:49 +0000
Importance: Normal
EFTA00013673


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=== Page 1 ===
Exhibit E
EFTA00010010

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EPSTEIN VICTIMS' COMPENSATION PROGRAM ("EVCP")
GENERAL RELEASE
This General Release is made this 3rd day of October
2020 .
WHEREAS,
(the "Claimant"), submitted a claim for
compensation to the Epstein Victims' Compensation Program ("EVCP") asserting that
she is a victim of sexual abuse by Jeffrey E. Epstein; and
WHEREAS, the EVCP Program Administrator (the "Administrator") determined
pursuant to the EVCP Protocol that Claimant is eligible to participate in the EVCP; and
WHEREAS, after reviewing Claimant's submissions and after careful consideration of
documentation and proof, and after due deliberation, the Administrator issued a
compensation determination to Claimant ("Compensation Offer"); and
WHEREAS, several jurisdictions within the United States have enacted claims revival
statutes concerning the timeliness of claims of sexual abuse; and
WHEREAS, Claimant is aware that, by accepting this Compensation Offer from the
EVCP, Claimant waives and releases certain individuals and entities from any and all
claims or causes of action arising from Mr. Epstein's conduct, whether pursuant to claims
revival statutes or otherwise; and
WHEREAS, after careful consideration of the proposed Compensation Offer, including
consultation with her legal counsel regarding the Compensation Offer, Claimant
informed the Administrator that Claimant has decided to accept the Compensation Offer.
NOW THEREFORE,
Claimant, for and on behalf of herself and her heirs, devisees, legatees, distributees,
executors, administrators, trustees, personal representatives, successors and assigns
(collectively, "Releasor"), for and in consideration of
Dollars (
(the Compensation Offer) to be received from the EVCP, the
adequacy and sufficiency of which are hereby acknowledged, hereby releases and forever
discharges the Co-Executors of the Estate of Jeffrey E. Epstein (the "Epstein Estate"), the
Co-Trustees of The 1953 Trust, the Epstein Estate, any entities owned or controlled in
whole or part by the Epstein Estate (the "Epstein Entities") and their respective current
1
CONFIDENTIAL
EFTA00010011

=== Page 3 ===
and former principals, officers, directors, stockholders, managers, members, partners,
limited partners, trustees, beneficiaries, administrators, agents, employees, attorneys,
predecessors, successors, assigns and affiliates, and any entities or individuals who are
or have ever been engaged by (whether as independent contractors or otherwise),
employed by, worked in any capacity for, or provided any services to Mr. Epstein, the
Epstein Entities or the Epstein Estate (jointly and severally, the "Releasees"), from any
and all claims, demands, actions, causes of action, suits, debts, dues, sums of money,
accounts, variances, trespasses, damages and judgments, whether sounding in equity,
tort, common law, contract, statute, regulation or otherwise and whether now existing,
hereafter existing or revived in the future whatsoever in law, admiralty, equity or
otherwise, including without limitation any and all claims or causes of action that arise
or may arise from or which otherwise concern acts of sexual abuse by Mr. Epstein (the
"Claims") which against the Releasees, Releasor ever had, now has or hereafter can, shall
or may have, for, upon, or by reason of any matter, cause or thing whatsoever from the
beginning of the world through the date of this General Release.
This General Release is a broad release of any and all Claims of Releasor against
any and all Releasees, including without limitation any and all causes of action, lawsuits,
claims, demands, damages and liability whatsoever, and also including without
limitation to the extent of their respective liability for the same, any and all such claims
against any and all Releasees for contribution as to any other person or persons who may
be determined to have been joint tortfeasors arising out of or in any way related to any
and all known and unknown personal injuries, and also including without limitation any
derivative claims for loss of consortium, under any federal, state or local law, without
limitation. This General Release is all-encompassing and is specifically made and given
on the premise that any and all Claims by Releasor are hereby released and extinguished,
whether said Claims arose in Florida, New Mexico, New York, the United States Virgin
Islands, France or any other country, state, territory, possession or jurisdiction, or
otherwise.
This General Release extends to released Claims that Releasor does not know or
suspect to exist in her favor, which, if known by Releasor, would have materially affected
her decision to enter into this General Release, and Releasor understands and agrees that
she is releasing any and all such unknown or unsuspected Claims in Releasees' favor.
Releasor acknowledges that she is familiar with Section 1542 of the California Civil Code,
which provides as follows:
A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE
CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN
2
CONFIDENTIAL
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HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE AND THAT, IF
KNOWN BY HIM OR HER, WOULD HAVE MATERIALLY AFFECTED HIS OR HER
SETTLEMENT WITH THE DEBTOR OR RELEASED PARTY.
Releasor expressly waives and relinquishes any right or benefit that Releasor has
or may have under Section 1542 of the California Civil Code and under any other statute
or legal principle with similar effect. In connection with such waiver and relinquishment,
Releasor acknowledges that she is aware that, after executing this General Release,
Releasor or Releasor's attorneys or agents may discover released Claims or facts in
addition to, or different from, those which they now know or believe to exist with respect
to the subject matter of this General Release, but that it is Releasor's intent hereby to fully,
finally and forever settle and release all of the Claims, whether known or unknown,
suspected or unsuspected, which now exist, may exist, or heretofore may have existed.
In furtherance of this intent, this General Release shall be, and remain in effect as, a full
and complete release of the Claims notwithstanding the discovery or existence of any
such additional or different Claims or facts.
The Administrator of the EVCP has retained Garretson Resolution Group, Inc.
d/b/a Epiq Mass Tort ("Epiq") to verify and resolve any lien or reimbursement claim
that may be owed to Medicare Part A and/or Part B ("Medicare") and/or Medicaid with
respect to compensation awarded to any participating claimant under the EVCP. If either
entity asserts a lien or reimbursement claim, Epiq is hereby authorized to act on behalf of
the EVCP to verify and resolve such lien or reimbursement claim. In the Claim Form,
Releasor authorized the Administrator to use and/or disclose information as to Releasor
for the resolution of Medicare and/or Medicaid liens. This includes providing to Epiq
certain information as to Releasor, including: (1) first name, last name and middle initial,
(2) Social Security number; (3) date of birth, (4) gender and (5) basic information
regarding the nature of Releasor's Claims, and authorizing the Administrator and Epiq
to use, exchange and report this information to Medicare and Medicaid, as may be
necessary, for purposes of verifying and resolving Medicare and/or Medicaid liens
and/or reimbursement claims and ensuring compliance with the Medicare Secondary
Payer Act, 42 U.S.C. $ 1395(y)(b), and its accompanying regulations. In the event that
Epiq resolves the asserted claim or lien, the Epstein Estate will pay the negotiated amount
in addition to any Compensation Offer determined by the Administrator.
Releasor represents and acknowledges that she is voluntarily and freely granting
this General Release in exchange for payment of the Compensation Offer, and that she is
legally competent to execute and deliver this General Release. Releasor further
represents that she is represented by legal counsel and has received legal advice prior to
3
CONFIDENTIAL
EFTA00010013

=== Page 5 ===
entering into this General Release and that she has been advised by said attorney
regarding the terms and conditions of this General Release, which she has completely
read and fully understands, including that accepting the Compensation Offer and signing
this General Release is a full and final compromise, adjustment and resolution of any and
all Claims that Releasor may now have or ever will have against Releasees.
Pursuant to the EVCP Protocol, the Administrator will maintain the confidentiality
of all information and documentation relating to claimants who participate in the EVCP
Program. This General Release does not require participating claimants to maintain such
confidentiality and Releasor may - at Releasor's voluntary and sole option - disclose
such information regarding the claims process and/or the Compensation Offer and any
other information pertaining to her claim.
This General Release specifically does not include
as a Releasee or
released party under this Agreement, and all parties expressly acknowledge, agree and
understand that any and all claims that Releasor has or may have against
are expressly preserved.
Releasor represents and warrants that she has not assigned any Claims released
pursuant to this General Release.
Releasor will dismiss with prejudice any and all legal actions - whether lawsuits,
probate claims or otherwise - that Releasor has filed against any of Releasees, with each
party to bear her, his or its own costs and attorneys' fees and will submit proof of
dismissal to the Administrator along with or prior to the signed acceptance of the
Compensation Offer and this executed Release.
This General Release contains the entire understanding of the Releasor and the Co-
Executors of the Epstein Estate. Any modification of any of the provisions of this General
Release shall be effective only if made in writing and executed by Releasor and the Co-
Executors of the Epstein Estate with the same formality as this General Release.
4
CONFIDENTIAL
EFTA00010014

=== Page 6 ===
IN WITNESS WHEREOF, Claimant has executed this General Release on the date
below her signature.
(Signature: Claimant)
10/3/2020
(Date)
STATE OF Texas
)
SS:
COUNTY OF Travis
)
On October 3 , 2020, before me personally came
to
me known, who, by me duly sworn, did depose and say that deponent is the Releasor
who executed the foregoing General Release.
MY COMMISSION EXPIRES
JULY 16, 2023
NOTARY ID: 132089050
Notary Public
Reviewed and approved:
Type (or print) Name of Claimant:
Attorney for Releasor:
Type (or print) Name of Attorney:
Signature:
5
CONFIDENTIAL
EFTA00010015


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=== Page 1 ===
1
Remarks as Prepared for Delivery by
Assistant Director in Charge
FBI New York Field Office
Jeffrey Epstein Arrest
July X, 2019
Preserving the innocence of children is the most important
responsibility we carry as adults. Failing them, in any way, is not an
option.
And yet there are some who blatantly disregard this golden rule, using
whatever tools they have at their disposal to lure children into a life of
which they should never be exposed.
As we allege today, Jeffrey Epstein is one of those people.
As of x a.m., he is under arrest /At X p.m., as he was X, we placed
him under arrest. Epstein has been charged with one count each of sex
trafficking and sex trafficking conspiracy.
For at least a three year period, from 2002-2005, he is alleged to have
sexually exploited and abused dozens of minor girls at his homes in
New York City and Palm Beach, Florida.
The girls were recruited in a variety of ways, usually by employees of
Epstein and victim recruiters themselves.
The victim recruiters and the girls they found typically received
hundreds of dollars in cash.
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2
The estimated dozens of victims were as young as 14 years old at the
time of recruitment.
Children who were made to give Epstein massages while they
were nude or partially nude.
Children who were asked to engage in direct and indirect sex acts
for money.
Children who were enticed to do all of this at the hands of a man
more than or nearly three times their age.
Those who have been victimized by child sexual predators are
frequently haunted by memories of these crimes well into adulthood,
and often for the rest of their lives. They bear the burden of someone
else's criminal behavior.
As an FBI agent, and as a father first, I stand among many who make
it our mission to put child predators behind bars where they belong; to
listen to every child who feels they've been exploited; and to advocate
for the most vulnerable among us.
Today I'm asking everyone to take a good look at this man. If you've
been victimized by him in any way, or have any additional information
about his alleged illegal behavior, we want to hear from you.
Whatever age you are now
Whatever age you were then
And no matter when or where the incident or incidents took place
The number to call is 1-800-CALL-FBI.
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=== Page 3 ===
3
Your bravery might just empower others to speak out about crimes
committed against them.
It's important to remember, there never was, nor will there ever be, an
excuse for this kind behavior. In the eyes of the FBI, the victim always
comes first.
Many thanks, as always, to our partners from the Southern District of
New York. Last but not least, I extend my sincere congratulations to
the FBI's Criminal Division in New York for their hard work on this
investigation.
###
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From:
(FBI)"
To:
(USAFLS)"
Subject: Re: Epstein
Date: Wed, 28 May 2008 22:32:56 +0000
Importance: Normal
Hey we emailed
MOST:) of your comments re any further delays and added a few of our own. The US Atty Gen was here today in
MM. I would love to know if Epstein came up.
and Acosta were going to present to the DAG reasons not to delay any further.
Hopefully they were successful and we r still on for Tues. We interviewed
today. She told Epstein her true age, she belvd was 14 or 15.
Phone records show contact @ age 16. She said Epstein told her he did not care about age. She also said that
told her he had f***d
brought
Anyways, I'll fill u in later. NY getting close to locating
We have cell and good address.
Keep your fingers crossed. Talk to u soon.
Original Message
From:
(USAFLS)
To:
;
(USAFLS);
Sent: Tue May 27 23:45:06 2008
Subject: Re: Epstein
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
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
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=== Page 2 ===
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.
From:
(USAFLS)
Sent: Tuesday, May 27, 2008 2:54 PM
To:
(USAFLS);
(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.
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Case 9:08-cv-80119-KAM Document 23 Entered on FLSD Docket 07/17/2008 Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80119-MARRA-JOHNSON
JANE DOE NO. 2,
Plaintiff,
vs.
FILED BY
JEFFREY EPSTEIN,
Defendant.
/
S.D. S.D.OF FLA OF FLA MIA
CLERK U.S. DIST. CT.
STEVEN H. LARIMORE
08 08JUL 10 JUL 10 PM 12: 19
FILED EX PARTE
UNDER SEAL
DEFENDANT'S MOTION TO FILE EX PARTE AND UNDER SEAL
190
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Case 9:08-cv-80119-KAM Document 23 Entered on FLSD Docket 07/17/2008 Page 2 of 4
Pursuant to S.D. Fla. L.R. 5.4, defendant Jeffrey Epstein hereby moves to
file his Notice of Continued Pendency of Federal Criminal Action, as well as this
motion, ex parte and under seal, stating as follows:
1.
In support of his motion to stay [DE 12], defendant has herewith filed
a Notice of Continued Pendency of Federal Criminal Action.
2.
The Notice relates to a confidential agreement between the United
States Attorney's Office for the Southern District of Florida and the defendant.
3.
The information contained in the Notice is material to this Court's
consideration of Epstein's motion to stay.
4.
To avoid disclosure of confidential material, Epstein requests leave to
file the Notice, and this motion, ex parte and under seal.
5.
Pending a ruling from this Court, Epstein has not served this motion
or the Notice on counsel for plaintiff.
2
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=== Page 3 ===
Case 9:08-cv-80119-KAM Document 23 Entered on FLSD Docket 07/17/2008 Page 3 of 4
WHEREFORE, defendant Jeffrey Epstein respectfully requests leave to file
this motion and his Notice of Continued Pendency of Federal Criminal Action, ex
parte and under seal.
Respectfully submitted,
LEWIS TEIN, P.L.
3059 Grand Avenue, Suite 340
Coconut Grove, Florida 33133
Tel: 305 442 1101 Fax: 305 442 6744
By: Wilutei
GUY A.LEWIS
Fla. Bar No. 623740
MICHAEL R. TEIN
Fla. Bar No. 993522
ATTERBURY, GOLDBERGER & WEISS, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, Florida 33401
Tel. 561 659 8300 Fax. 561 835 8691
By: JACK A. GOLDBERGER
Fla. Bar No. 262013
Attorneys for Defendant Jeffrey Epstein
3
EFTA00013566

=== Page 4 ===
Case 9:08-cv-80119-KAM Document 23 Entered on FLSD Docket 07/17/2008
Page 4 of 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that this motion, in accordance with S.D. Fla. L.R.
5.4, has not been served on opposing counsel and was filed under seal on July 10,
2008.
Willia
Michael R. Tein
4
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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein
Date: Fri, 30 Nov 2018 14:24:55 +0000
Importance: Normal
The December 4 trial - is that the one against DOJ or against Epstein? State or federal court?
Sent from my iPhone
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From:
To:
Bcc:
Subject: RE: news article
Date: Mon, 30 Jun 2008 21:20:56 +0000
Importance: Normal
Yes. The detail that wasn't included is that he has to pay damages to the girls — a minimum of $150,000 to each
of 31 girls.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
From:
Sent: Monday. June 30. 2008 5:02 PM
To:
Subject: news article
Does this resolve your case, too?
Billionaire pleads to Fla. prostitution charge
THE ASSOCIATED PRESS
WEST PALM BEACH, Fla. -- New York billionaire Jeffrey Epstein has pleaded guilty to soliciting prostitution
from underage girls in South Florida.
Circuit Judge Deborah Dale Pucillo sentenced the 55-year-old money manager Monday to 18 months in the
Palm Beach County jail, followed by a year of house arrest. He will also be designated a sex offender.
Epstein was arrested two years ago. Authorities allege he paid several girls under the age of 18 $200 to $300
each in return for naked massages at his Palm Beach home that sometimes became sexual.
He also faces state and federal lawsuits filed by several women over similar allegations.
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From:
To:
Cc:
Subject: Re: New drive for Maxwell
Date: Fri, 04 Dec 2020 12:40:53 +0000
Not a problem.
Best,
)"
12/3/2020 5:24
PM
Hi all,
Today our office is sending via FedEx a replacement drive for Ghislaine
Maxwell, which should arrive at the MDC tomorrow. This drive will
replace the drive that Maxwell recently dropped and broke, and the
accompanying cover letters are attached. Would you please make sure
Maxwell is given access to this drive?
Would you please mail the broken drive back to our office? It can be
mailed to the below address:
Paralegal Specialist
U.S. Attorney's Office, SDNY
New York, NY 10007
Thanks very much, as always, for your help.
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
<mailto:
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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 "Acknowledgment and Notice of Appearance FILED"
Date: Tue, 13 Apr 2021 17:31:59 +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 04/13/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Document(s): Document(s)
Docket Text:
ACKNOWLEDGMENT AND NOTICE OF APPEARANCE, on behalf of Appellant Ghislaine Maxwell,
FILED. Service date 04/13/2021 by CM/ECF.[3076442] [21-58]
Notice will be electronically mailed to:
w.com
Tammy_Torres@ca2.uscourts.gov
Notice will be stored in the notice cart for:
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Acknowledgment and Notice of Appearance FILED
Original Filename: Acknowledgment and Notice of Appearance Form 4.5.21-2.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=04/13/2021] [FileNumber=3076442-0]
[c5024ab6d0b85e0627dbf584811322ded4f4beb7d33cedbleeb585f9c0d33cc6d8e66f4f9ba254ec0cb70336e4b21
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e7b39f9afeaec099c0e8e66e6f9488f4e54]
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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: case records scanning
Date: Mon, 12 Oct 2020 21:34:03 +0000
Embedded: RE:_case_records_scanning.msg
Sender:
Subject: RE: case records scanning
Message-Id:
<SN5P110MB054232540A5AD282D7F888BB92070@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
Cc:
EFTA00013260


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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
01/04/2019 12:55 EST
Generated By:
Page 1 of 7
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
12/14/2018
*GA
N212JE
I
A523
APIS
PASSENGER
CUSTOMS
KPBI
TIST
08:49
EPSTEIN
JEFFREY
01/20/1953
P
12/14/2018
*GA
N212JE
O
APIS
PASSENGER
KPBI
TIST
00:00
EPSTEIN
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01/20/1953
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11/28/2018
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15:27
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01/20/1953
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11/28/2018
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00:00
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01/20/1953
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11/25/2018
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JEFFREY
01/20/1953
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11/24/2018
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01/20/1953
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11/11/2018
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01/20/1953
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11/02/2018
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01/20/1953
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10/30/2018
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15:36
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01/20/1953
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10/28/2018
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00:00
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01/20/1953
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10/11/2018
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00:00
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01/20/1953
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10/10/2018
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00:00
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01/20/1953
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09/30/2018
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00:00
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01/20/1953
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09/22/2018
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17:52
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01/20/1953
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09/22/2018
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00:00
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01/20/1953
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09/20/2018
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TIST
KPBI
00:00
EPSTEIN
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01/20/1953
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09/13/2018
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18:11
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01/20/1953
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09/06/2018
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00:00
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01/20/1953
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08/14/2018
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APIS
PASSENGER
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KPBI
00:00
SDNY_GM_00000799
For Official Use Only / Law Enforcement Sensitive
EFTA00010062

=== Page 2 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS Person Encounter List
01/04/2019 12:55 EST
Generated By:
Page 2 of 7
Last Name
First Name
DOB
Doc
Document
Date - Time
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Insp
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Ref
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Type
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Code
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01/20/1953
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08/06/2018
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00:00
EPSTEIN
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01/20/1953
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07/29/2018
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13:18
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01/20/1953
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07/21/2018
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00:00
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01/20/1953
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07/10/2018
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17:48
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01/20/1953
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07/07/2018
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00:00
EPSTEIN
JEFFREY
01/20/1953
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06/27/2018
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11:47
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01/20/1953
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06/20/2018
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00:00
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01/20/1953
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19:11
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01/20/1953
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06/15/2018
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00:00
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01/20/1953
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06/02/2018
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21:21
EPSTEIN
JEFFREY
01/20/1953
P
06/02/2018
*GA
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KPBI
00:00
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01/20/1953
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05/27/2018
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A523
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PASSENGER
KPBI
TIST
EDWARD
18:07
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JEFFREY
01/20/1953
P
05/22/2018
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N212JE
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KISP
LFPB
15:42
EPSTEIN
JEFFREY
01/20/1953
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05/13/2018
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01/20/1953
P
04/27/2018
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19:57
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JEFFREY
01/20/1953
P
04/27/2018
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N120JE
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APIS
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KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
04/20/2018
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PASSENGER
INS
KTEB
TIST
22:03
EPSTEIN
JEFFREY
01/20/1953
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04/20/2018
*GA
N212JE
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APIS
PASSENGER
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KPBI
00:00
EPSTEIN
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01/20/1953
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04/09/2018
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01/20/1953
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03/31/2018
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01/20/1953
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03/27/2018
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01/20/1953
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03/27/2018
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APIS
PASSENGER
KPBI
TIST
00:00
SDNY_GM_00000800
For Official Use Only / Law Enforcement Sensitive
EFTA00010063

=== Page 3 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS Person Encounter List
01/04/2019 12:55 EST
Generated By:
Page 3 of 7
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
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03/13/2018
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14:02
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01/20/1953
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03/08/2018
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00:00
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JEFFREY
01/20/1953
P
03/03/2018
*GA
N120JE
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APIS
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INS
KTEB
TIST
20:36
EPSTEIN
JEFFREY
01/20/1953
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03/03/2018
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N120JE
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APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
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02/21/2018
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INS
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TIST
19:53
EPSTEIN
JEFFREY
01/20/1953
P
02/21/2018
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00:00
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JEFFREY
01/20/1953
P
02/07/2018
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19:14
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JEFFREY
01/20/1953
P
02/07/2018
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01/20/1953
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16:39
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01/20/1953
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01/27/2018
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01/20/1953
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01/20/1953
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01/20/2018
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00:00
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01/20/1953
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01/16/2018
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20:06
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JEFFREY
01/20/1953
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01/16/2018
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01/20/1953
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01/20/1953
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KPBI
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01/20/1953
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01/20/1953
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11/26/2017
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00:00
SDNY_GM_00000801
For Official Use Only / Law Enforcement Sensitive
EFTA00010064

=== Page 4 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
01/04/2019 12:55 EST
Generated By:
Page 4 of 7
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
11/07/2017
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21:03
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01/20/1953
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JEFFREY
01/20/1953
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JEFFREY
01/20/1953
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06/25/2017
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01/20/1953
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APIS
PASSENGER
LFPB
KTEB
00:00
SDNY_GM_00000802
For Official Use Only / Law Enforcement Sensitive
EFTA00010065

=== Page 5 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS Person Encounter List
01/04/2019 12:55 EST
Generated By:
Page 5 of 7
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
04/30/2017
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INS
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20:16
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JEFFREY
01/20/1953
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JEFFREY
01/20/1953
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04/16/2017
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CUSTOMS
EDWARD
14:43
EPSTEIN
JEFFREY
01/20/1953
P
04/16/2017
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JEFFREY
01/20/1953
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01/20/1953
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01/20/1953
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00:00
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01/20/1953
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03/25/2017
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01/20/1953
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03/25/2017
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00:00
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JEFFREY
01/20/1953
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03/11/2017
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06:17
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JEFFREY
01/20/1953
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03/11/2017
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01/20/1953
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03/10/2017
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15:09
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JEFFREY
01/20/1953
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03/10/2017
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TIST
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JEFFREY
01/20/1953
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JEFFREY
01/20/1953
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JEFFREY
01/20/1953
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N331JE
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TIST
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JEFFREY
01/20/1953
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LFPB
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01/20/1953
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KTEB
00:00
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JEFFREY
01/20/1953
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02/16/2017
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00:00
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JEFFREY
01/20/1953
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02/09/2017
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01/20/1953
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02/09/2017
*GA
N212JE
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APIS
PASSENGER
KPBI
TIST
00:00
SDNY_GM_00000803
For Official Use Only / Law Enforcement Sensitive
EFTA00010066

=== Page 6 ===
KEE DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS- Person Encounter List
01/04/2019 12:55 EST
Generated By:
Page 6 of 7
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
02/06/2017
*GA
N212JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
01/29/2017
B
P512
VEHICLE
EDWARD
12:37
EPSTEIN
JEFFREY
01/20/1953
P
01/29/2017
*GA
N212JE
I
APIS
PASSENGER
KTEB
TIST
00:00
EPSTEIN
JEFFREY
01/20/1953
P
01/27/2017
*GA
N212JE
o
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
01/19/2017
B
P512
VEHICLE
EDWARD
06:52
EPSTEIN
JEFFREY
01/20/1953
P
01/19/2017
*GA
N90JE
I
APIS
PASSENGER
KTEB
TIST
00:00
EPSTEIN
JEFFREY
01/20/1953
P
01/18/2017
*GA
N90JE
I
APIS
PASSENGER
KTEB
TIST
00:00
EPSTEIN
JEFFREY
01/20/1953
P
01/13/2017
*GA
N212JE
o
APIS
PASSENGER
TIST
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
01/02/2017
B
P515
VEHICLE
EDWARD
12:48
EPSTEIN
JEFFREY
01/20/1953
P
01/02/2017
*GA
N212JE
I
APIS
PASSENGER
TEB
XXX
00:00
EPSTEIN
JEFFREY
01/20/1953
P
12/29/2016
*GA
N212JE
O
APIS
PASSENGER
TIST
KPBI
00:00
EPSTEIN
JEFFREY
01/20/1953
P
12/11/2016
B
P512
VEHICLE
EDWARD
06:41
EPSTEIN
JEFFREY
01/20/1953
P
12/11/2016
*GA
N212JE
I
APIS
PASSENGER
KBED
TIST
00:00
EPSTEIN
JEFFREY
01/20/1953
P
12/02/2016
*GA
N212JE
O
APIS
PASSENGER
TIST
KTEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
11/23/2016
*GA
N212JE
I
A523
APIS
PASSENGER
CUSTOMS
KPBI
TIST
08:49
EPSTEIN
JEFFREY
01/20/1953
P
11/11/2016
*GA
N212JE
I
A10D
APIS
PASSENGER
TEB
XXX
09:52
EPSTEIN
JEFFREY
01/20/1953
P
10/28/2016
*GA
N212JE
O
APIS
PASSENGER
XXX
TEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
10/26/2016
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
TEB
XXX
11:22
EPSTEIN
JEFFREY
01/20/1953
P
10/15/2016
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
TEB
XXX
11:18
EPSTEIN
JEFFREY
01/20/1953
P
10/09/2016
*GA
N212JE
O
APIS
PASSENGER
XXX
TEB
00:00
EPSTEIN
JEFFREY
01/20/1953
P
10/02/2016
*GA
N212JE
I
A10D
APIS
PASSENGER
INS
TEB
XXX
16:55
EPSTEIN
JEFFREY
01/20/1953
P
10/02/2016
*GA
N212JE
I
APIS
PASSENGER
TEB
XXX
00:00
Total Number of Records: 136
SDNY_GM_00000804
For Official Use Only / Law Enforcement Sensitive
EFTA00010067

=== Page 7 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
01/04/2019 12:55 EST
Generated By:
Page 7 of 7
Legend
Loc
Codes
Value
KTEB
KTEB
KBCT
KBCT
KFXE
KFXE
KPBI
KPBI
LFPB
LFPB
TUPW
TUPW
CYYR
CYYR
TEB
TETERBORO
GMMX
GMMX
TIST
TIST
TFFJ
TFFJ
KBED
KBED
PBI
WEST PALM BEACH
KISP
KISP
XXX
UNKNOWN AIRPORT (USED ONLY WHEN THE AIRPORT CODE IS UNKNOWN)
KBAF
KBAF
Doc Type
Codes
Value
P
P - PASSPORT
Site Code
Codes
Value
P512
P512 - CBP-ST THOMAS, VI PREFLIGHT
A514
A514 - CBP-ST THOMAS, GAF PREDEPART
A10D
A10D - CBP-TETERBORO, JET AVIATION
A511
A511 - CBP-CYRIL E KING, INTL AIRPORT
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
SDNY_GM_00000805
For Official Use Only / Law Enforcement Sensitive
EFTA00010068


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c3: VOL00008
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=== Page 1 ===
From:
(USAFLS)"
To:
(USAFLS)"
Bcc:
(USAFLS)"
Subject: FW: Jeffrey Epstein
Date: Wed, 30 Jul 2008 17:41:33 +0000
Importance: Normal
FYI -- I was going to respond that it relates to the performance of the Non-Prosecution Agreement. What do you think?
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
Original Message
From: Roy BLACK [mailto:
Sent: Wednesday, July 30, 2008 1:18 PM
To:
(USAFLS)
Subject: Re: Jeffrey Epstein
I am out of town. What is it about?
(USAFLS)"
07/30/08 11:44 AM
Dear Roy: Are you available this afternoon to discuss the Epstein
matter? Please let me know what time works best for you.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
EFTA00013964


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Call with Geoff on Epstein
Date: Tue, 05 Mar 2019 16:07:57 +0000
Importance: Normal
Attachments: unnamed
EFTA00009884


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c3: VOL00008
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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
)"
Cc:
(USANYS)"
Subject: FW: Epstein FOIA Disclosure
Date: Mon, 16 Sep 2019 13:42:02 +0000
Attachments: Epstein_ROIs.pdf; ATT00001.htm; Disclosure_Letter.pdf; ATT00002.htm;
Epstein_Docs.redacted.pdf; ATT00003.htm; ATT00004.htm
Embedded:FW:_Freedom_of_Information_Act_Request:_USMS_files_re:_Jeffrey_Epstein.msg
If of interest, these are the USMS documents that were inadvertently released and are the subject of the NYT piece the
press office circulated.
From:
(USANYS)
>
Sent: Friday, September 13, 2019 5:16 PM
To:
(USANYS)
is
(USANYS)
Subject: FW: Epstein FOIA Disclosure
Per discussion.
From:
(USMS)
Sent: Friday, September 13, 2019 2:08 PM
To:
(USANYS)
Subject: Epstein FOIA Disclosure
Thank you for your prompt return call and your time this afternoon.
Attached above is the material we discussed.
You or anyone on your staff is welcome to call me if you have any questions or concerns about this material.
V/r,
Associate General Counsel
USMS/HQ/OGC
EFTA00009971


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=== Page 1 ===
From:
To:
Bcc:
Subject: RE: Notice of Non-Compliance CONFIDENTIAL
Date: Sun, 29 Jun 2008 16:14:55 +0000
Importance: Normal
Hi
I sent you an e-mail earlier today letting you know that Goldberger agreed to my change, so it looks like Monday is going to
happen. I have spoken with the Chief and he also spoke to the Sheriff about serving the time out at the jail. The Chief also is going to call
some victims to inform them that he received a call from the State Attorney's Office about a plea hearing on Monday.
I am very surprised that there has been no press coverage.
Yes, can we meet on Monday morning. I want to have the victim list ready to go before we head to the hearing in case we can get him to
sign it right then and there.
Assistant U.S. Attorney
Fax
Original Message
From:
Sent: Sunday, June 29, 2008 11:54 AM
To:
Subject: RE: Notice of Non-Compliance
Just wanted to let you know
and I are working on the remaining 5 girls and getting everything ready for GJ. Did you ever hear back
from Jack Goldberger? I spoke with Joe yesterday and he agreed with Dave, that the PBC Detention Center is the jail. He also mentioned
any sentenced under a year is served at the jail. If over that, Epstein will be serving at the Dept of Correction which is the Stockade. Joe
also mentioned that the Sheriff determines how the sentence is carried out. We have already met with the Colonel at the jail some months
ago. If all goes well tomorrow, we should ALL meet with the Colonel again just to reiterate our position. We have not heard from AMOC
but will let you know when we do. Give us a shout later today and let us know if you would like to meet us tomorrow morning prior to
going to the courthouse.
From:
Sent: Saturday, June 28, 2008 11:20 AM
To:
Cc:
Subject: Re: Notice of Non-Compliance
Dear Jack:
I have conferred with a state court practitioner who stated that there is nothing that prohibits you from agreeing to a consecutive six-month
sentence of incarceration followed by one year of community control as specified in the non-prosecution agreement.
If you elect to proceed with the plea agreement as currently drafted, we ask that you insert the word "imprisoned" following the words "six
months" in the second sentencing paragraph.
Please confirm that this change is acceptable. Thank you.
EFTA00014100

=== Page 2 ===
Original Message
From: Jack Goldberger
To:
Cc: Jack Goldberger
Sent: Sat Jun 28 08:49:55 2008
Subject: RE: Notice of Non-Compliance
Dear Ms Villafana,
please allow this e-mail to confirm our telephone conference of 6:30 pm on June 27 wherein we discussed the Epstein plea agreement and
we agreed that the Epstein state plea agreement was in compliance with the September 2007 non-prosecution agreement entered into
between Mr. Epstein and the USAO for the Souhern District of Florida.
Jack Goldberger
From
Sent: Fri 6/27/2008 5:45 PM
To: Jack Goldberger; Roy BLACK
Cc:
Subject: Notice of Non-Compliance
Dear Messrs. Goldberger and Black:
Please see the attached Notification Letter.
<<080627 Goldberger Black notification Itr.pdf>>
Assistant U.S. Attorney
Phone
Fax
EFTA00014101


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=== Page 1 ===
From:
(USAFLS)"
To:
(USAFLS)"
(USAFLS)"
(USAFLS)"
Subject: RE: Epstein
Date: Wed, 28 May 2008 13:37:20 +0000
Importance: Normal
Please fill me in.
Original Message
From:
(USAFLS)
Sent: Wednesday, May 28, 2008 9:21 AM
To:
(USAFLS);
(USAFLS)
Subject: RE: Epstein
This was info that
got from Barry, the state attorney, but he was waiting for an email to confirm. I am much to lowly to have
communications with the "star" team.
Original Message
From:
(USAFLS)
Sent: Tuesday, May 27, 2008 3:09 PM
To:
(USAFLS);
(USAFLS)
Cc:
(USAFLS)
Subject: RE: Epstein
No one has contacted anyone in Miami. Please copy me and
on all communications. Thanks,
Original Message
From:
(USAFLS)
Sent: Tuesday, May 27, 2008 2:54 PM
To:
(USAFLS);
(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.
EFTA00013918


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=== Page 1 ===
From:
To:
Ce:
Subject: SDNY Daily Press Clippings - August 11, 2020
Date: Wed, 12 Aug 2020 01:14:23 +0000
Inline-Images: image001.png
OFFICER OF
SDNY PRESS CLIPPINGS
ENTER
DEPARTMENT
JUSTITIA
MAXWELL
Fox News: https://www.foxnews.com/us/critical-new-information-found-ghislaine-maxwell-case-lawyers-clain
The Sun: https://www.thesun.co.uk/news/12373696/ghislaine-maxwell-of-suicide-watch-moans-jail/
CNN: htps:/wwmn.com/en-us/news/politis/hislin-maxwellatoneys-for-the-epsten-asociate-askt-hat-release-of-sealed-documentsinciviaseofterleaning-of-crical-new
information/ar-BB17OmoY
VF: htps://www.vanityfair.com/hollywood/2020/08/jeffrey-epstein-prince-andrew-sex-ring
HERNANDEZ:
NYPOST:https://pagesix.com/2020/08/10/tekashi-6ix9ine-bodyguards-ride-nyc-subway-without-nasks/
Cheat Sheet: htps://www.cheatsheet.com/entertainment/tekashi-69-and-his-security-sguad-confronted-by-angry-stranger-buthes-not-fazed.html/
WIRECARD:
BLOOMBERG: https://www.msn.com/en-us/news/world/former-wirecard-manager-died-of-blood-poisoning-in-manila-bild/ar-BB17KrNG
WSJ: https://www.wsj.com/articles/singapore-police-bring-first-charges-linked-to-wirecard-11596810092
MATTERS OF INTEREST
VANITY FAIR: https://www.vanityfair.com/news/2020/08/william-barr-of-all-people-accuses-black-lives-matter-protesters-of-being-fascistic
US NEWS & WORLD REPORT: https://money.usnews.com/investing/news/articles/2020-08-10/turkeys-halkbank-urges-dismissal-of-us-indictment-in-iran-sanctions-case
WaPo: https://www.washingtonpost.com/politics/2020/08/11/is-this-voter-fraud-quiz/
Washington Examiner: https://www.washingtontimes.com/news/2020/aug/11/william-barr-sought-dismiss-michael-flynn-case-bas/
EFTA00010955


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(NYPD)"
(NY) (FBI)"
Cc:
)"
)"
)"
(USANYS) [Contractor]"
,
(USANYS)"
Subject: RE: 1As for 31E-MM-108062
Date: Wed, 29 Sep 2021 19:17:03 +0000
Importance: Normal
Attachments: Copy_of_1A-Report_-_MM-108062_filtered_by_original_notes.xlsx
Hi
Is it possible for you to please pull the 44 files listed in the attached spreadsheet as original notes and send them to us?
Right now, the spreadsheet lists the date the files were acquired on, instead of the date of the corresponding interview;
for us to compare the files against what we already have, we need - at a minimum - the dates the notes were written. If
you could send us the files themselves, that would be easiest for us.
Please let me know if USAfx or a physical hard drive would be easiest for this, and I'm happy to coordinate. We'd also like
this tomorrow or in the next few days, if possible, so that we may continue our review of the 3500 material as
expeditiously as possible before our upcoming production deadline.
Happy to jump on a call to explain anything as needed, too. Thank you so much for your help!
From:
(USANYS)
Sent: Tuesday, September 28, 2021 9:38 PM
To:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Cc:
is
)
is
Subject: Fwd: 1As for 31E-MM-108062
As part of our 3500 project, we asked the agents to send us the attached spreadsheet. We want to make sure we have
produced the notes and reports of witness interviews. Can you please check the spreadsheet entries referring to original
notes and compare them to what we have produced or will be producing in 3500? If anything is missing or we aren't sure,
we will ask
for the notes to add to the production. Please let us know if you have any questions. If my
email doesn't make sense, happy to hop on a call to explain.
Thanks!
Begin forwarded message:
From:
Date: September 28, 2021 at 6:50:20 PM EDT
To:
)"
(USANYS)"
EFTA00013395

=== Page 2 ===
Cc:
Subject: 1As for 31E-MM-108062
Attached is the 1A list for 31E-MM-108062. I added the disks the 1As are on, so you'll see that on the last column. Let
me know if you have questions.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk
EFTA00013396


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00013432.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
C STERNHEIM
To:
)"
)"
(USANYS)"
,
)"
Cc: Christian Everdell
>, , Laura Menninger
>, , Jeff Pagliuca
Subject: U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Thu, 29 Apr 2021 19:01:00 +0000
Attachments: Letter_re-_Sleep_Deprivation-4-29-21.pdf; ATT00001.hm
Good afternoon-
Attached is a courtesy copy of today's ECF fling.
Regards-
Bobbi
EFTA00013432


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00013840.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USAFLS)"
Subject: Read: Petition for Enforcement of Crime Victim's Rights Act.pdf re Epstein
Date: Mon, 07 Jul 2008 19:39:16 +0000
Importance: High
Priority: Urgent
EFTA00013840


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00011411.pdf
c6: pdf
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=== Page 1 ===
From:
To:
Subject: RE: SDNY NEWS CLIPS, OCTOBER 13, 2020
Date: Tue, 13 Oct 2020 15:27:16 +0000
Inline-Images: image001.png
thanks
From
Sent: Tuesday. October 13. 2020 11:11 AM
To
Subject: FW: SDNY NEWS CLIPS, OCTOBER 13, 2020
Oops, forgot to copy you!
From
Sent: Tuesday, October 13, 2020 11:03 AM
To: 'Chiefs'
Cc:
Subject: SDNY NEWS CLIPS, OCTOBER 13, 2020
OF
SDNY PRESS CLIPPINGS
DEPARTMENT
JUSTITIA
MAXWELL
NYDN: https://www.nydailynews.com/new-york/nmy-jeffrey-epstein-maxwel-case-20201013-jmzhl7zdrzdgrbbs7yc6bfnszu-story.html-
NY POST: https://nypost.com/2020/10/11/new-photos-show-ghislaine-maxwell-at-anti-sex-trafficking-event/
US NEWS: https://www.usnews.com/news/top-news/articles/2020-10-13/ghislaine-mawell-to-urge-us-appeals-court-to-keep-damaging-deposition-secrelt
MOTHER JONES: https://www.motherjones.com/politics/2020/10/i-called-everyone-in-jeffrey-epsteins-little-black-book/
CNN: https://www.cnn.com/2020/10/12/business/leon-black-jeffrey-epstein-apollo/index.html
OK: https://okmagazine.com/exclusives/jeffrey-epstein-withdrew-800k-cash-arrest/
NYT: https://www.nytimes.com/2020/10/13/books/review/what-tech-calls-thinking-adrion-daub.htm
MATTERS OF INTEREST
POLITICO: https://www.politico.com/newsletters/weekly-transportation/2020/10/13/a-tale-of-two-responses-to-pandemic-travel-790929
TELEGRAPH: https://www.telegraph.co.uk/technology/2020/10/12/microsoft-takes-massive-cyber-crime-network-feors-wil-used/
CNN: https://www.cnn.com/2020/10/12/politics/judges-reject-voter-fraud-claims/index.html
BLOOMBERG: https://news.bloombergtax.com/financial-accounting/fraud-and-ineptitude-undermine-covid-relief-opinion
NYT: https://www.nytimes.com/2020/10/12/nyregion/cuomo-coronavirus-orthodox-shutdown.htm
BUZZFEED NEWS: https://www.buzzfeednews.com/article/kenbensinger/new-york-owed-money-man-tweeted-trump-ventilators
JD SUPRA: https://www.jdsupra.com/legglnews/rnc-deputy-finance-chair-elliott-broidy-29590/7
THE HILL: https://thehill.om/homenews/house/520712-two-ethics-groups-cal-on-house-to-begin-impeachment-proceedings-against-bar
WAPOhttps://www.washingtonpost.com/politics/2020/10/13/democrats-confirmation-hearing-flubs-oom-over-barrett-hearng/
BUFFNEWS: https://buffolonews.com/news/local/inexplicable-pensive-colinspepores-for-prison-whileblasting-prosecutrsjudge/article_d80624e-0c6-1eb-a885-ef62ad25901.hml
BUSINESS INSIDER: https://www.businessinsider.com/exclusive-interview-rick-gates-book-mueller-star-witness-2020-10
BREITBART: https://www.breitbart.com/2020-election/2020/10/12/polak-oe-bidens-disastrous-shortlist-for-attorneygeneral-cuono-yotes-abrams-bharara-weisman/
EFTA00011411

=== Page 2 ===
C:https://www.nbcrightnow.com/crime/free-human-trgfficking-owareness-webinar/article_ec374086-0c1-11eb-803a-fb10c24d21d4.html
BARRON'S: https://www.barrons.com/articles/deutsche-bank-makes-bold-buy-call-on-ford-stock-51602597239
LEXOLOGY: https://www.lexology.com/library/detail.aspx?g=6b349d6e-egfe43d4-ae3e-33005f4ffe6d
CNN: https://www.cnn.com/2020/10/13/us/nypd-election-protest-deployment/index.html
EFTA00011412


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00009829.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Epstein FOIA Next Steps - Noel Team
Date: Tue, 13 Apr 2021 18:10:57 +0000
Have a proffer then, sorry.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 2:10 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
That window works for me.
?
From:
(USANYS)
Sent: Tuesday, April 13, 2021 2:09 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Re: Epstein FOIA Next Steps - Noel Team
I'd have to move something but can do if nothing else works. I am wide open between 12 and 3 if there's anything good
during that time.
Sent from my iPhone
On Apr 13, 2021, at 1:26 PM,
(USANYS)
wrote:
Tomorrow morning fairly booked for me, but do have 10-10:30 if that's better for everyone.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 1:26 PM
To:
(USANYS)
i
(USANYS)
is
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
This afternoon isn't ideal. I can do 6pm if absolutely necessary, but I would prefer any time tomorrow morning.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 1:10 PM
To:
(USANYS)
is
(USANYS)
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
Doesn't work for me. Could you do 6pm?
EFTA00009829

=== Page 2 ===
Original Appointment
From:
(USANYS)
Sent: Tuesday, April 13, 2021 1:09 PM
To:
(USANYS);
(USANYS);
(USANYS)
Subject: Epstein FOIA Next Steps - Noel Team
When: Tuesday, April 13, 2021 4:00 PM-4:30 PM (UTC-05:00) Eastern Time (US & Canada).
Where:
:
please let me know if this time doesn't work
has availability tomorrow as well. Thanks.
Please use dial in
with passcode
EFTA00009830


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=== Page 1 ===
From: "Lilly Ann Sanchez"
To:
Subject: sorry
Date: Tue, 11 Mar 2008 20:18:22 +0000
Importance: Normal
i am writing to you because i feel badly about the fact that you might be upset with my handling of the jeffrey epstein
matter. you and i have known each other for a long time and i consider you a friend. i truly apologize if you believe that i
somehow overstepped the bounds. as i said at the meeting, i was trying to protect the Office, not offend you.
hope you are well.
Lilly Ann Sanchez, Esq.
FOWLER WHITE BURNETT P.A.
Espirito Santo Plaza, 14th Floor
1395 Brickell Avenue
Miami, Florida 33131-3302
**TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance
with requirements imposed by the IRS, we inform you that any tax
advice contained in this communication (including attachments) was
not intended or written to be used, and cannot be used, for the
purpose of (i) avoiding penalties under the Internal Revenue Code
or (ii) promoting, marketing or recommending to another party any
transaction or matter addressed herein. If you would like such advice,
please contact us.
***Attention: The information contained in this E-mail message
is attorney privileged and confidential information intended only
for the use of the individual(s) named above. If the reader of this
message is not the intended recipient, you are hereby notified that any
dissemination, distribution or copy of this communication is strictly
prohibited. If you have received this communication in error, please
contact the sender by reply E-mail and destroy all copies of the original
message. Thank you.
EFTA00013725


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Jeffrey Epstein: About the sex trafficking case & accusations | Miami Herald
Date: Sat, 01 Dec 2018 01:27:08 +0000
Importance: Normal
Great! Would be happy to add another investigation if there's something.
> On Nov 30, 2018, at 8:22 PM,
wrote:
>
>
May have something else for you
>
>
Original Message
> From:
>
Sent: Friday, November 30, 2018 8:05 PM
> To:
> Cc:
>
Subject: Re: Jeffrey Epstein: About the sex trafficking case & accusations I Miami Herald
>
>
No problem, sounds like an interesting case!
>
On Nov 30, 2018, at 7:58 PM,
wrote:
I fear it is. Sorry!
Sent from my iPhone
On Nov 30, 2018, at 7:11 PM,
wrote:
Is it staffed already?
Original Message
From:
Sent: Friday, November 30, 2018 7:06 PM
To:
Cc:
Subject: Re: Jeffrey Epstein: About the sex trafficking case & accusations | Miami Herald
Yes. As of today. On the d/l for now.
Sent from my iPhone
On Nov 30, 2018, at 6:56 PM,
wrote:
Are we open on this? Can we be?
https://www.miamiherald.com/news/local/article220097825.html
EFTA00009976


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=== Page 1 ===
From
To:
Subject: 20cr330, US V. Maxwell
Date: Thu, 11 Nov 2021 02:45:04 +0000
Attachments: 20cr330_Order_11.10.21.pdf
Counsel:
Judge Nathan has granted the parties additional time on two sets of supplemental briefing. Please see the
attached order, which will be docketed tomorrow morning.
Sincerely,
Chambers of the Hon. Alison J. Nathan
EFTA00010019


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=== Page 1 ===
From:
(USAFLS)"
To:
(USAFLS)"
Subject: RE: Jeffrey Epstein
Date: Wed, 30 Jul 2008 18:27:26 +0000
Importance: Normal
Sounds good
Original Message
From:
(USAFLS)
Sent: Wednesday, July 30, 2008 1:42 PM
To:
(USAFLS)
Subject: FW: Jeffrey Epstein
FYI -- I was going to respond that it relates to the performance of the Non-Prosecution Agreement. What do you think?
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
Original Message
From: Roy BLACK [mailto:
Sent: Wednesday, July 30, 2008 1:18 PM
To:
(USAFLS)
Subject: Re: Jeffrey Epstein
I am out of town. What is it about?
(USAFLS)"
07/30/08 11:44 AM
Dear Roy: Are you available this afternoon to discuss the Epstein
matter? Please let me know what time works best for you.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
EFTA00014107


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
i
(USANYS)"
Subject: Meet on Epstein
Date: Tue, 17 Sep 2019 00:47:22 +0000
Importance: Normal
Attachments: unnamed
EFTA00010141


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=== Page 1 ===
From:
To:
Subject: what a fucking clown
Date: Fri, 13 Mar 2020 23:09:08 +0000
https://www.foxnews.com/media/jeffrey-epstein-suicide-fox-nation
I don't believe a word of what he says here. He was about to replace the attorneys who had been working for the dude
for years and years?? No goddamn way. Ugh, unreal.
Anyway thought you might appreciate.
Assistant U.S. Attorney
Southern District of New York
EFTA00011360


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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 2, 2020
BY ELECTRONIC MAIL
New York, NY 10022
Denver, CO 80203
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
In recognition of the Government's ongoing discovery obligations, today we are producing
copies of the materials listed in the below index, which materials are stamped with control numbers
SDNY GM 000174967 through SDNY_GM__00328863. The password for the drive is
The materials are available for pickup at the U.S. Attorney's Office in Manhattan.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case.¹ This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
SDNY GM 00174967
SDNY_GM 00270985
Deutsche Bank records
Confidential
SDNY_GM_00270986;
JPMorgan Chase records
Confidential
SDNY GM 00323935
SDNY GM 00324015
GM Documents
1 Files in PDF format designated as "confidential" under the protective order have been stamped
"confidential." However, certain files cannot be individually labeled as confidential on the
documents themselves due to their file format. Such files include in their electronic names the
word "Confidential."
06.20.2018
EFTA00010287

=== Page 2 ===
Page 2
SDNY_GM_00324016
SDNY_GM_00324036
Citibank records for Ghislaine Maxwell
UBS records for Angara Trust, Montepelier
Trust, Terramar Project, Inc., Max
Foundation, Ghislaine Maxwell, Ghislaine
SDNY_GM_00324037
SDNY_GM_00325754
Maxwell IRA, & Ellmax, LLC
SDNY_GM_00325755
SDNY_GM_00325761
LSJ Scene2Go
American Express records for Jeffrey
SDNY GM 00325762
6908700  ANGS
Epstein and Ghislaine Maxwell
Confidential
The Government is also reproducing to the defendant the files specified in Defense's
September 21, 2020 letter. In order to avoid further difficulties with respect to viewing the files,
the Government offers the following instructions:
1. Any .dat, .dvt, and .vol files can be opened and viewed by right-clicking on the file and
selecting "Edit with Notepad" or a similar text-viewing program.
2. Any video file can be opened with VLC, which has been included.
3. Accessory files (i.e. .dii, .ami, .cms, etc.) are to be ignored, as they serve no functional
purpose besides assisting in the operation of other (i.e. video) files.
4. Any previously flagged files that are not noted here have been converted to PDFs and/or
had their file paths shortened to enable viewing.
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials or if you wish to arrange a time to
review physical items in the FBI's custody.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
06.20.2018
EFTA00010288


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=== Page 1 ===
From:
To:
Subject: Read: Emailing: Villafana Supplemental Declaration.wpd re Epstein
Date: Fri, 19 Dec 2008 22:04:30 +0000
Importance: Normal
EFTA00013847


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=== Page 1 ===
From:
)"
To:
Subject: RE: documents for Relativity
Date: Wed, 24 Apr 2019 15:52:28 +0000
Importance: Normal
Thanks - and apologies for the belated info on the first link.
From:
Sent: Wednesday, April 24, 2019 11:52
To:
Cc
Subject: RE: documents for Relativity
I will make the adjustments for the first set of documents and then let you know when everything is available in
Relativity.
Thank you.
From:
Sent: Wednesday, April 24, 2019 11:36 AM
To:
Cc:
is
is
Subject: RE: documents for Relativity
We've received some additional documents in this same production we'd like to include in the same general subfolder on
Relativity ("BSF second production" under "BSF returns"), please. I'm sending them in a separate folder link so that they
don't mess up your process with the initial results; they're here:
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#2018 SDNYinvestigation\Subpoena
Returns\Boies Schiller\2019-04-23, Boies Schiller second subpoena response (follow-up)
Please note there are a few things from that folder that do NOT need to be uploaded - the folder titled "!Original Zips"
and the two PDF documents (in the main folder) don't need to go onto Relativity. And I think I neglected to give similar
info for the original folder linked to below ("2019-04-18, Boies Schiller second subpoena response") - in that folder, we do
not need the "!Original Zips" folder or its contents, and do not need the three PDF documents in the main folder to be
uploaded.
As always, please let me know if any questions or issues, and thanks very much.
EFTA00010256

=== Page 2 ===
From:
Sent: Monday, April 22, 2019 15:55
To:
Cc:
i
is
Subject: RE: documents for Relativity
We can keep the folder structure that currently exists. If I have any questions regarding the documents I will let you
know.
Thank you.
From:
Sent: Monday, April 22, 2019 3:51 PM
To:
Cc:
i
)
is
Subject: RE: documents for Relativity
Following up on the below, and for the same case - US V. Epstein (USAO # 2018R01618) - could we please load the
documents in the following folder into Relativity:
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#2018 SDNYinvestigation\Subpoena
Returns\ Boies Schiller\2019-04-18, Boies Schiller second subpoena response
In terms of structure, they can go under the "BSF returns" subfolder (under the folder "Subpoena Returns") under a new
subfolder identified as "BSF second production". And under that, we'd like to keep the same folder structure as exists at
the link. Does that work?
And I don't believe there is DVD information (as in the "BSF first production" documents), but if there is, please let us
know. Please also let me know if any questions or if any other information would be helpful, and if you could let us know
when it's all uploaded?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Thursday, March 28, 2019 11:16
To:
Cc:
is
)
is
Subject: RE: documents for Relativity
Perfect, thanks very much.
EFTA00010257

=== Page 3 ===
From:
Sent: Thursday, March 28, 2019 09:02
To:
Cc:
i
is
Subject: RE: documents for Relativity
Hello
The documents would need to be converted to a different format. I will talk to someone about getting the documents
converted to a different format.
Thank you.
From:
Sent: Wednesday, March 27, 2019 7:15 PM
To:
Cc:
i
is
Subject: RE: documents for Relativity
That's no problem, we don't need those on Relativity. Separately, though will we be able to play those video files *not*
on a DVD? That is, we only have them in electronic format (in the file folders) - I haven't tried to play them, so maybe it's
just as easy as that, but wanted to check if we need to get them processed in some other fashion to be able to view
independently of a DVD player.
thanks,
From:
Sent: Tuesday, March 26, 2019 09:32
To:
Cc:
i
^
i
Subject: RE: documents for Relativity
Good Morning
I have noticed that some of these documents contain data that appears to be from a DVD. A DVD contains a bunch of
separate files to make everything play on a DVD, but it will not make sense to load DVD information into Relativity. The
following should not be loaded to Relativity:
1.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q^3\FS09LP\_AMUFM*3\S90B8H*H\B3KTU3*5\2MQV99
I\G6WHHA~F\7EJDCF~7\Interview H. R\VIDEO_TS
2.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q*3\FS09L*P\_AMUFM*3\S90B8H*H\B3KTU3*S\2MQV991
\GWR892~P\60AFYC*X\Interview J. H\VIDEO_TS
EFTA00010258

=== Page 4 ===
3.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q*3\FS09L*P\_AMUFM*3\S90B8H*H\B3KTU3*5\2MQV91
I\GWR892*P\60AFYC*X\InterviewS. V\VIDEO_TS
4.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q*3\IFS09L*P\_AMUFM*3\S90B8H*H\B3KTU3*S\2MQV91
I\GYCEJB~B\53V7CE~B\Interview A. D\VIDEO_TS
5.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q^3\FS09L*P\_AMUFM*3\S90B8H*H\B3KTU35\2MQV99
I\GYCEJB~B\53V7CE~B\Interview A. T\VIDEO_TS
6. \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY
investigation\Subpoena Returns\ Boies Schiller\2019-03-04, Boies Schiller first subpoena response\GJ SUBPOENA
RESPONSE 004582 (State Disc 1)\2. Walkthrough Video
Please let me know if there are any questions.
Thank you.
From:
Sent: Monday, March 25, 2019 7:00 PM
To:
Cc:
i
>;
is
Subject: RE: documents for Relativity
Could we please load the documents in the following folder into Relativity for US V. Epstein (USAO # 2018R01618):
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#2018 SDNYinvestigation\Subpoena
Returns\Boies Schiller\2019-03-04, Boies Schiller first subpoena response
In terms of structure, we'd like to create a folder identified as "Subpoena Returns" (at the same level as "FBI Case File" is
currently), and in a subfolder within Subpoena Returns, a folder titled "BSF returns," and within that a subfolder identified
as "BSF first production" that the docs in the above link can be deposited into (including any additional subfolders). Does
that work?
Please let me know if any questions or if any other information would be helpful, and if you could please let us know
when it's all uploaded?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00010259


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=== Page 1 ===
From:
"
To:
Cc:
Bcc:
Subject: MCC discovery letter
Date: Tue, 13 Oct 2020 21:08:41 +0000
Embedded: MCC_discovery_letter.msg
Sender:
Subject: MCC discovery letter
Message-Id:
<DM3P110MB0540059862B0F508C7C8FD58ED040@DM3P110MB0540.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
Cc:
EFTA00011416


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=== Page 1 ===
From:
)"
To:
Cc:
)"
(USANYS)"
Subject: RE: Request re Ghisliane Maxwell
Date: Fri, 08 Jan 2021 16:58:16 +0000
Good morning,
Following up on this email, would it be acceptable for someone from the defense to deliver this new drive from our office
to the MDC today, please?
Thank you,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From:
Sent: Thursday, January 7, 2021 4:35 PM
To:
Cc:
>;
(USANYS)
^
Subject: Request re Ghisliane Maxwell
Good afternoon,
At the request of defense counsel, our office is preparing a new drive with a copy of discovery material that was
previously produced to Ghislaine Maxwell on a CD, but which she has been unable to view. The drive will be ready
tomorrow. Today, defense counsel asked that Maxwell be able to review those materials over this coming weekend, but
no one from our office is available to hand deliver the drive tomorrow, and we understand that Maxwell would not
receive a FedEx package sent out tomorrow until next week. Defense counsel has offered to pick the drive up from our
office and hand deliver it to the MDC themselves tomorrow. Would that be permissible?
Thank you,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00013267

=== Page 2 ===
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=== Page 1 ===
From:
(USANH)"
@usa.doj.gov>
To:
)"
)"
Subject: FW: Activity in Case 1:20-mj-00132-AJ USA V. Maxwell Notice of Attorney Appearance -
Defendant
Date: Mon, 06 Jul 2020 16:23:42 +0000
Attachments: Maxwell_NOA.pdf
From: ecf_bounce@nhd.uscourts.gov <ecf_bounce@nhd.uscourts.gov>
Sent: Monday, July 6, 2020 12:19 PM
To: nef@nhd.uscourts.gov
Subject: Activity in Case 1:20-mj-00132-AJ USA V. Maxwell Notice of Attorney Appearance - Defendant
This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
e-mail because the mail box is unattended.
***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. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
U.S. District Court
District of New Hampshire
Notice of Electronic Filing
The following transaction was entered by Vogelman, Lawrence on 7/6/2020 at 12:19 PM EDT and filed on
7/6/2020
Case Name:
USA V. Maxwell
Case Number:
1:20-mj-00132-AJ
Filer:
Dft No. 1 - Ghislaine Maxwell
Document Number: 5
Docket Text:
NOTICE OF ATTORNEY APPEARANCE: Lawrence A. Vogelman appearing for Ghislaine Maxwell
. Attorney Lawrence A. Vogelman added to party Ghislaine Maxwell(pty:dft).(Vogelman,
Lawrence)
1:20-mj-00132-AJ-1 Notice has been electronically mailed to:
gov,CaseView.ECF@usdoj.gov,
@usdoj.gov,
@usdoj.gov,
@usdoj.gov
Lawrence A. Vogelman
1:20-mj-00132-AJ-1 Notice, to the extent appropriate, must be delivered conventionally to:
EFTA00010372

=== Page 2 ===
The following document(s) are associated with this transaction:
Document description:Main Document
Original filename:n/a
Electronic document Stamp:
[STAMP dcecfStamp_ID=1045603718 [Date=7/6/2020] [FileNumber=2213882-0]
[27dda6f745ad0ed7f48f5a46a6de59adc4e0fb29f2e1cf1012a203e9bf6acd55aab4
995962cfd39bb761fd9be3ca44b0dd0f81f4b77ef05a7e4be62ccab43bdc]]
EFTA00010373


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein
Date: Tue, 03 Jul 2007 10:26:25 +0000
Importance: High
Priority: Urgent
I have received a couple of calls and an e-mail from Lilly Ann Sanchez asking for an extension of time to
respond to several subpoena. She also states that they intend to provide us with a "supplement" to their
presentation and what they believe will be their resolution with the state. I intend to send a response stating that
the subpoenas for financial documents can be put off, but we want to get the computer equipment that was
removed from Epstein's home prior to the state search warrant as soon as possible. I also intend to invite her to
call me to discuss a resolution of the federal investigation that could include concurrent time.
If anyone has communicated anything to any of Epstein's attorneys that is contrary to this, please contact my
assistant,
as soon as possible. I have asked
o send out the e-mail while I am in trial. You
will all receive a copy of the e-mail when it is sent.
Thank you.
EFTA00013606


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of Florida
500 South Australian Ave., Suite 400
West Palm Beach, FL 33401
Facsimile: (561) 820-8777
October , 2007
DELIVERY BY FACSIMILE
The Hon. Edward B. Davis (Ret.)
Akerman Senterfitt
One Southeast Third Avenue, 25th Floor
Miami, Florida 33131
Re: Service as a Special Master
Dear Judge Davis:
Thank you for agreeing to serve as a Special Master and for assisting the United States
Attorney's Office in the selection of an attorney representative to represent a group of identified
victims. This letter is meant to assist you in performing your duties by providing you with
background information regarding the agreement between the United States and Jeffrey Epstein
and the duties that the attorney representative will have to perform.
The Federal Bureau of Investigation and the U.S. Attorney's Office conducted an
investigation of Mr. Epstein. As a result of that investigation, the U.S. Attorney's Office and Mr.
Epstein entered into a Non-Prosecution Agreement and an Addendum that contains, inter alia
the following terms:
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 7C, 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.
8.If any of the individuals referred to [in the paragraphs above] 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
EFTA00013511

=== Page 2 ===
right to contest damages up to an amount agreed to between Epstein and the
identified individual, 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, with respect 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.
Epstein's signature on this agreement also is not to be construed 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 [the above paragraphs], 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.
The most recent version of the statute referenced above, 18 U.S.C. $ 2255, provides that:
Any person who, while a minor, was a victim of a violation of section
2422 or
2423 of this title and who suffers personal injury as a result of such violation,
regardless of whether the injury occurred while such person was a minor, may sue
in any appropriate United States District Court and shall recover the actual
damages such person sustains and the cost of the suit, including a reasonable
attorney's fee. Any person as described in the preceding sentence shall be deemed
to have sustained damages of no less than $150,000 in value. F1
Section 2422 prohibits the use of a facility of interstate commerce to induce minors to
engage in sexual activity and prostitution, and section 2423 prohibits interstate travel for the
purpose of engaging in sexual activity or prostitution with minors The United States has
identified
victims as defined by this statute.
Due to the circumstances of the case and the number and caliber of the attorneys who
represent Mr. Epstein, in selecting the victims' attorney representative, the United States suggests
that you consider the following criteria:
1. Experience doing both plaintiffs' and defense litigation.
1. Experience with state and federal statutory and common law tort claims.
1. The ability to communicate effectively with young women (the victims' current ages are
between 16 and 24).
1. Experience litigating against large law firms and high profile attorneys who may test the
veracity of the victims' claims.
1. Sensitivity to the nature of the suit and the victims' interest in maintaining their privacy.
1. Experience litigating in federal court in the Southern District of Florida.
1. The resources to hire experts and others, while working on a contingency fee basis, in
order to prepare for trial, if a settlement cannot be reached.
1. The ability to negotiate effectively.
Pursuant to this letter, the United States assigns to you the responsibility for consulting
with and selecting the attorney representative for the individuals. The United States and Epstein
retain the right to make good faith objections to the attorney representative you select prior to the
final designation of the attorney representative. In that regard, after you have reached a decision
EFTA00013512

=== Page 3 ===
regarding the attorney representative, please provide me with his or her name and contact
information.
If I can provide you with any further information, please do not hesitate to contact me.
Thank you again for your assistance with this matter.
Sincerely,
R. Alexander Acosta
United States Attorney
By:
First Assistant United States Attorney
cc: AUSA
F1
An earlier version of this statute deems that any person described in the preceding sentence shall have
sustained damages of no less than $50,000 in value.
EFTA00013513


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=== Page 1 ===
From: Roy BLACK
To:
(USAFLS)"
Subject: Re: Jeffrey Epstein
Date: Wed, 30 Jul 2008 18:37:49 +0000
Importance: Normal
Ok. I am on the road in california and can call in about an hour or so.
Original Message
From:
(USAFLS)"
To: Roy BLACK
Sent: 7/30/2008 2:31:56 PM
Subject: RE: Jeffrey Epstein
Hi Roy -- It relates to the performance of the criminal Non-Prosecution Agreement.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
Original Message
From: Roy BLACK [mailto:
Sent: Wednesday, July 30, 2008 1:18 PM
To:
(USAFLS)
Subject: Re: Jeffrey Epstein
I am out of town. What is it about?
(USAFLS)"
07/30/08 11:44 AM
Dear Roy: Are you available this afternoon to discuss the Epstein
matter? Please let me know what time works best for you.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
EFTA00013963


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein
Date: Fri, 01 Mar 2019 19:33:42 +0000
Importance: Normal
- For
we spoke t
the National Coordinator for Child Exploitation and Interdiction, in ODAG. Her
contact info is:
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00009883


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=== Page 1 ===
From:
=
)"
</O=USA/OU=FLS/CN=RECIPIENTS/CN=
To: "Acosta, Alex (USAFLS)"
>, "
=
Subject: Just got back from Epstein hearing
Date: Fri, 11 Jul 2008 15:24:35 +0000
Importance: High
We need to talk.
and I are at
Assistant U.S. Attorney
EFTA00013558


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=== Page 1 ===
From:
=
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To:
"Senion
Subject: Emailing: Work Release Notice --
wpd
Date: Thu, 04 Dec 2008 22:24:05 +0000
Importance: Normal
Attachments: Work_Release_Notice_-- --
vpd
I have attached a draft letter to victims notifying them of Epstein's work release. I will fill in the blank tomorrow. Any
objections to the language?
Thanks.
The message is ready to be sent with the following file or link attachments:
Work Release Notice -
wpd
Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file
attachments. Check your e-mail security settings to determine how attachments are handled.
EFTA00013589


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=== Page 1 ===
From:
To:
Subject: Re: Epstein
Date: Wed, 12 Dec 2007 14:44:10 +0000
Importance: Normal
No thx, I have it.
Sent from my BlackBerry Wireless Handheld
Original Message
From:
To:
Sent: wed Dec 12 09:00:04 2007
Subject: Epstein
Do you want me to send you the indictment package on Epstein?
EFTA00013717


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=== Page 1 ===
From:
To:
Cc:
Subject: JE
Date: Mon, 17 Dec 2018 21:14:40 +0000
Importance: Normal
and I have our quarterly meeting to speak with
about Human Trafficking issues. She may ask about Epstein.
Besides the generalities, is there anything particular you would like us to convey?
Thanks,
Assistant United States Attorney
Human Trafficking Co-Coordinator
Violent & Organized Crime
Southern District of New York
EFTA00011384


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=== Page 1 ===
From:
To:
Subject: Questions re: Epstein ESI
Date: Tue, 10 Mar 2020 22:31:10 +0000
Importance: Normal
Attachments: unnamed
EFTA00011355


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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From: AUSA
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:
Time:
Witness Needed to Appear for:
Trial (X)
Date:
Grand Jury ( )
Date:
Trial Prep (X)
Date:
Estimated Dates Witness will Arrive:
Depart:
Is the person a Fact Witness and not an Expert Witness?
(Yes/No):
Current Federal Civilian or Military Employee?
(Yes/No):
Is the Witness Facing Criminal Charges?
(Yes/No):
Does the Witness Reside Outside the Continental United States?
(Yes/No):
Is this Witness a Victim-Witness?
(Yes/No):
Hotel Required?
(Yes/No):
Has the Witness advised you of any unusual travel expenses?
(Yes/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
EFTA00010174

=== 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
EFTA00010175


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=== Page 1 ===
From:
To:
Cc
Subject: travel approval request
Date: Thu, 14 Mar 2019 22:32:01 +0000
Importance: Normal
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.
Assistant U.S. Attorney
Southern District of New York
EFTA00011093


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=== Page 1 ===
From:
To:
Subject: RE: Maxwell
Date: Thu, 02 Jul 2020 14:47:03 +0000
thank you!!
From:
Sent: Thursday, July 02, 2020 10:45
To:
is
Subject: FW: Maxwell
Congrats guys! Great work on such an important case.
From:
Sent: Thursday, July 2, 2020 10:43 AM
To:
Subject: Maxwell
PCU - Please join me in congratulating
on the arrest this morning of Ghislaine Maxwell.
spoke a bit about the case on our call on Tuesday and the truly remarkable job the team has done in bringing it. I won't
repeat all of that, buy you should know, as you read press coverage today that already is making it seem like these charges
were inevitable, that they were anything but, and that they are instead the result of an extraordinary amount of work and
perseverance and creativity by
in building a case based on conduct that I'm pretty sure is older
than all of our paralegals.
will be holding a press conference at 12, and while it is sadly not possible for all of us to be there to join her given
current conditions, I hope we can all take a moment to remotely congratulate the team on a terrific accomplishment in
bringing an extremely important case against a woman very worthy of criminal prosecution.
EFTA00010431


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=== Page 1 ===
From: "
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=.
To:
Cc:
(USAFLS)"
Subject: RE: Epstein settlement agreement
Date: Fri, 02 Nov 2007 13:50:32 +0000
Importance: Normal
Dear
I was just informed that a case disposition conference has been set in the Epstein case on January 7, 2008. Our
agreement with Mr. Epstein contemplated a simultaneous plea and sentencing for October (or, as we later agreed,
November), followed by Mr. Epstein self-surrendering to begin serving his sentence not later than January 4,
2008. From your last e-mail, it appeared that the judge was under the impression that Mr. Epstein could not be
sentenced before January 2008. We are hoping that Judge McSorley would consider conducting the
simultaneous plea and sentencing some time before January 4, 2008, so that Mr. Epstein can comply with the
terms of our agreement and begin serving his sentence on January 4, 2008.
I also would appreciate it if you could send me a copy of the plea agreement, the Information that you plan to file
(if it hasn't been filed already), and any factual proffer or other documents related to the plea. Please also let me
know the date and time of the plea and sentencing so that someone from our office can attend and insure Mr.
Epstein's compliance with the terms of his federal non-prosecution agreement.
If you need any information regarding the federal investigation, or if you have any questions about the terms of
the federal non-prosecution agreement, please do not hesitate to contact me at the number below or
in the
West Palm Beach office.
Thank you,
First Assistant United States Attorney
Assistant U.S. Attorney
From:
Sent: Monday, October 29, 2007 9:22 PM
To:
(USAFLS)
Subject: Epstein settlement agreement
EFTA00013524

=== Page 2 ===
Good evening. I am the ASA with the Epstein case in Palm Beach County. The negotiated settlement is a
definite go. A difficulty arose last week at a conference with the judge on the case. She wants the plea and
sentence to occur concurrently; not a plea with a sentencing at a later date. Therefore, the case was set for the
first week of January, but the plea and sentence will definitely occur before the January 4th date that was agreed
on by all for the sentencing.
If you have any questions, please contact me at
EFTA00013525


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=== Page 1 ===
From:
To:
Subject: FW: Epstein
Date: Tue, 13 Aug 2019 14:56:44 +0000
I don't think there's a harm in taking it into evidence, but don't think it's necessary - thoughts?
From:
Sent: Tuesday, August 13, 2019 10:55 AM
To:
Subject: RE: Epstein
I reached out to David to see if we want the original ligature used on July 23 to compare to the ligature from August 10th?
From:
Sent: Tuesday, August 13, 2019 10:52 AM
To:
Cc:
Subject: RE: Epstein
Thanks. We spoke with Dr. Graham at OCME, and he said he would set up a phone call between us and Dr. Roman
tomorrow, so we can address these issues with her then.
From:
Sent: Tuesday, August 13, 2019 10:39 AM
To:
Cc:
Subject: FW: Epstein
From:
Sent: Tuesday, August 13, 2019 10:34 AM
To:
Cc:
Subject: Re: Epstein
I can answer about determination of time of death- I cannot determine a time of death reliably, especially not within the
already tight timeframe that you have already delineated with the phone call and the time found.
Sent from my iPhone
On Aug 13, 2019, at 10:20 AM,
wrote:
Dr,
Is it possible to determine a time or timeframe of death? Additionally, the AUSA office is asking of your findings of the
ligature. If possible could you give me a call, may be easier than emailing back and forth. We are working on getting the
interviews of those who discovered the body but there are some legalities to that.
EFTA00013194

=== Page 2 ===
Subject: RE: Epstein
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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: FW: Search Terms for Maxwell Case
Date: Tue, 08 Dec 2020 18:10:18 +0000
Embedded: FW:_Search_Terms_for_Maxwell_Case.msg
Sender:
Subject: FW: Search Terms for Maxwell Case
Message-Id:
<SN5P110MB05420AAD754412C9B276B29B92CD0@SN5P110MB0542.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
EFTA00011166


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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 01:32:50 +0000
Date Modified: 2017-04-04 01:32:50 +0000
Priority: 5
DTSTAMP: 2008-06-11 15:27:38 +0000
Attendee:
is
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:
(USAFLS)
To:
);
(ODAG) (SMO)
Cc:
(ODAG) (SMO)
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
(305) 961-9299.
From:
)
Sent: Wednesday, June 11, 2008 10:21 AM
To:
(USAFLS);
(ODAG) (SMO)
Cc:
(ODAG) (SMO)
Subject: RE: Epstein
EFTA00013987

=== Page 2 ===
I'm available anytime
From:
(USAFLS)
Sent: Wednesday, June 11, 2008 10:09 AM
To:
(ODAG) (SMO);
)
Cc:
(ODAG) (SMO)
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:
);
(USAFLS)
Cc:
(ODAG) (SMO)
Subject: Epstein
Would you guys be available Friday morning by telephone to discuss?
EFTA00013988


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=== Page 1 ===
Subject: Re: Forthwith authority
Date: Sat, 10 Aug 2019 14:53:53 +0000
Thank you. Look forward to having you back!
I approve.
If
can respond quickly he will, but if he cannot due to Epstein calls I think he would want you to move
ahead.
You should judge how long you can wait and see. Move forward if you need to.
Sent from my iPhone
nas to
determine, as quickly as possible, if he is working with others, including people in the United States.
EFTA00011507

=== Page 2 ===
Thanks,
EFTA00011508


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=== Page 1 ===
U.S. Department of Justice
ORd
United States Attorney
Southern District of Florida
West Palm Beach, FL 33401
Facsimile:
September 18, 2008
VIA ELECTRONIC MAIL
Ethics Counsel
The Florida Bar
CONFIDENTIAL
651 East Jefferson Street
Tallahassee, FL 32399-2300
Re:
Request for Written Staff Opinion
Dear Sir or Madam:
I am an Assistant United States Attorney and a member in good standing of the
Florida Bar. I am writing to request a written staff opinion on an issue related to contact with
unrepresented parties.
As part of my employment, I have investigated and presented for prosecution a case
involving the sexual abuse of several young women who were teenagers at the time of the
abuse. There is a federal statute, 18 U.S.C. $ 2255, that provides a civil cause of action for
victims of the federal crimes that I investigated, which sets a minimum of $150,000 in
damages.
At the request of counsel for the putative defendant, the U.S. Attorney's Office
entered into pre-indictment plea negotiations that resulted in the signing of a Non-
Prosecution Agreement ("Agreement"). The Agreement called for the putative defendant to
plead guilty to state criminal offenses that would result in the defendant's designation as a
sex offender. The Agreement also sought to place the victims in the same position where
they would have been if the defendant had been convicted of the federal offenses.
Accordingly, the Agreement required the defendant to agree to waive challenges to liability
and damages related to claims brought pursuant to 18 U.S.C. § 2255. In light of the large
¹In addition to the general rules regarding confidentiality, this letter relates to a confidential
Non-Prosecution Agreement, and, accordingly, I would ask that the information contained herein
remain confidential.
EFTA00014016

=== Page 2 ===
ETHICS COUNSEL
FLORIDA BAR
SEPTEMBER 18, 2008
PAGE 2
number of young, vulnerable, and unsophisticated victims, the U.S. Attorney's Office also
included agreement terms requiring the defendant to pay for the services of an independent
attorney-representative, whose services would be offered (without obligation) to the victims
free of charge. The U.S. Attorney's Office asked the former Chief United States District
Judge to serve pro bono as a Special Master for the selection of the attorney-representative.
The Special Master selected Robert Josefsberg and his firm, Podhurst Orseck, to serve as the
attorney-representative.
Under federal law, I have several obligations related to victims, including an
obligation to confer with them and advise them of resolution of their matters. See, e.g., 18
U.S.C. $ 3771. Accordingly, I have prepared a letter informing the victims of how the matter
was resolved, including the appointment of Mr. Josefsberg. The letter advises the victims
that Mr. Josefsberg will be in contact with them shortly and invites the victims to contact Mr.
Josefsberg directly if they so choose. A copy of the letter, with some identifying information
redacted, is attached. This letter was reviewed by attorneys for the defendant before it was
sent.
During the pendency of the investigation, some of the victims retained civil attorneys
to represent them in civil suits against the defendant. For those victims whom I knew to be
represented, I sent a modified version of the letter to the attorney, rather than to the victim,
and asked the attorney to convey the substance of the letter to the victim. In that letter, the
discussion of contact with Mr. Josefsberg made clear that Mr. Josefsberg's contact would be
with the attorney only, not directly with the victim. A copy of the letter for those victims
already represented by counsel also is attached.
I understand that you do not opine on past events, and some of these letters already
have been distributed, but several victims have yet to be notified, and I need guidance on
how to proceed.
Unbeknownst to me, one victim had obtained counsel prior to receiving my letter. I
have received a letter from that attorney asserting that my contact with the victims violates
Florida Bar Rule 4-7.4. I have reviewed the rule and do not understand how it would apply
to me because: (1) I am not soliciting employment from a prospective client; (2) I am not
seeking pecuniary gain; (3) none of the victims has expressed a desire not to receive
communications from me; (4) the letter does not involve coercion, duress, fraud,
overreaching, harassment, intimidation, or undue influence; (5) the letter is not false,
fraudulent, misleading, or deceptive; and (6) there is nothing about the mental or physical
EFTA00014017

=== Page 3 ===
ETHICS COUNSEL
FLORIDA BAR
SEPTEMBER 18, 2008
PAGE 3
states of the victims that leads me to believe that they cannot review and understand the
information that is included in the letter.
Can you provide me with a written opinion on this issue so that I may revise the letters
that have not yet been distributed if you deem it necessary?
I understand that the same attorney has made contact with Mr. Josefsberg, also
accusing him of violating the same rule. Since the benefit to these victims will be lost if Mr.
Josefsberg cannot advise them in detail of their rights under the Agreement, I understand that
his firm will be contacting your Office for similar guidance.
Please let me know if you need any additional information, and thank you for your
kind assistance with this matter.
Sincerely,
R. Alexander Acosta
United States Attorney
By:
Assistant United States Attorney
cc:
AUSA and Professional Responsibility Officer
, AUSA
EFTA00014018


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From:
"
(USAFLS)"
To:
(USAFLS)"
Bcc:
"
(USAFLS)"
Subject: Immunity
Date: Thu, 16 Oct 2008 19:47:57 +0000
Importance: Normal
Attachments: US_Response_to_Quash_subpoenas_v3.wpd; Surreply_Final.wpd
<<US Response to Quash subpoenas v3.wpd>>
<<Surreply Final.wpd>>
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
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From:
To:
Subject: E-mail to State Attorney's Office
Date: Thu, 01 Nov 2007 21:22:35 +0000
Importance: Normal
Hi
Here is my suggestion:
Dear
The FBI has informed us that a case disposition conference has been set in the Epstein case on
January 7, 2008. Our agreement with Mr. Epstein contemplated a simultaneous plea and sentencing for October
(or, as we later agreed, November), followed by Mr. Epstein self-surrendering to begin serving his sentence not
later than January 4, 2008. From your last e-mail, it appeared that the judge was under the impression that Mr.
Epstein could not be sentenced before January 2008. We are hoping that Judge McSorley would consider
conducting the simultaneous plea and sentencing some time before January 4, 2008, so that Mr. Epstein can
comply with the terms of our agreement and begin serving his sentence on January 4, 2008.
I also would appreciate it if you could send me a copy of the plea agreement, the Information that you plan to file
(if it hasn't been filed already), and any factual proffer or other documents related to the plea. Please also let me
know the date and time of the plea and sentencing so that someone from our office can attend and insure Mr.
Epstein's compliance with the terms of his federal non-prosecution agreement.
If you need any information regarding the federal investigation, or if you have any questions about the terms of
the federal non-prosecution agreement, please do not hesitate to contact me at the number below or
in the
West Palm Beach office.
Thank you.
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From:
(USAFLS)"
To: "Acosta, Alex (USAFLS)"
>,
(USAFLS)"
Subject: Epstein Press Coverage
Date: Wed, 02 Jan 2008 18:27:41 +0000
Importance: Normal
Attachments: Leap_Year_Press_Coverage.doc; ABC_Blotter_Article_2.doc; New_York_Epstein_article.doc;
Jeffrey_Epstein_article.doc; Jeffrey_Epstein_Archives.doc 071116_Epstein_Editorial.pdf
Here are the documents that I have electronically. The "Jeffrey Epstein Archives" document has several stories
contained within it.
I do not have the letter that the Chief handed out, but some of these stories reference the letter. I do not believe
that the letter mentioned any specifics. But, when the State Attorney's Office basically shut down the case, the
Chief deemed the police investigation "closed," which meant that the PC affidavits for the arrests of Epstein,
, and
became public. "The Smoking Gun" published the redacted PC affidavits and later
published a portion of the Incident Report. Here are links to their stories.
http://www.thesmokinggun.com/archive/0726062epstein1.html
http://www.thesmokinggun.com/archive/0727061epstein1.html
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
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Event: Accepted: Meeting re MCC/Epstein
Start Date: 2019-08-13 15:45:00 +0000
End Date: 2019-08-13 16:15:00 +0000
Location:
office
Class: X-PERSONAL
Comment:
Date Created: 2019-08-13 12:17:25 +0000
Date Modified: 2019-08-13 12:17:25 +0000
Priority: 5
DTSTAMP: 2019-08-13 12:09:07 +0000
Attendee:
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From
To:
(USANYS)"
Cc:
)"
)"
Subject: FW: 20cr330, U.S. V. Maxwell
Date: Fri, 15 Oct 2021 22:57:32 +0000
Attachments: 20cr330_ME_10.15.21.pdf
Attaching her order on the defense's motion on FRE 412.
From: Nathan NYSD Chambers
Sent: Friday, October 15, 2021 6:34 PM
To
>;
i
is
is
n; Laura Menninger
>; Jeff Pagliuca
>;
Subject: 20cr330, U.S. V. Maxwell
Counsel:
Attached please find a memo endorsement issued by Judge Nathan. It will be filed on the public docket on
Monday morning.
Please confirm receipt.
Sincerely,
Chambers of the Hon. Alison J. Nathan
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From:
To:
Cc:
Subject: 16(d) letter
Date: Thu, 01 Oct 2020 19:27:20 +0000
Attachments: 2020-10-01,_GM,_16(d)_letter.docx; 2020-10-01,_GM,_affidavit_of_certification.docx
Chiefs,
Attached for review is a public version of the 16(d) letter in Maxwell and a Local Rule 16.1 affidavit.
Thanks,
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From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein
Date: Fri, 26 Apr 2019 15:39:58 +0000
Importance: Normal
Are you at the airport? I wouldn't mind chatting for just a minute to make sure we're on the same page on bullet
points before I draft.
Original Message
From:
(USANYS)
Sent: Friday, April 26, 2019 11:37 AM
To:
(USANYS)
Cc:
(USANYS)
i
(USANYS)
Subject: Re: Epstein
I'm traveling today, back on Sunday so could do it then or otherwise have to defer to
sorry.
Sent from my iPhone
> On Apr 26, 2019, at 10:35,
(USANYS)
wrote:
V
V
is going to meet with Brad Weinshiemer on Monday - can you guys put together an update memo this
afternoon on where we are, what we've done since the last update memo, and next steps? This just for
for now, not for sending down to DC.
V
> Sent from my iPhone
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=== Page 1 ===
From:
To:
Subject: News Brief
Date: Fri, 22 Jan 2021 00:54:18 +0000
The No. 2 official at the F.B.I. is departing - The deputy director of the F.B.I. announced to the bureau's staff on
Thursday that he was retiring, departing the bureau as the Biden administration takes over.
The exit of the official, David L. Bowdich, comes as the White House offered assurances on Thursday that President Biden
would keep Christopher A. Wray as the bureau's director.
US soldier hoped to team up with ISIS to attack 9/11 Memorial: feds https://nypost.com/2021/01/19/us-soldier-wanted-
to-team-with-isis-to-attack-9-11-memorial-feds/?
tm_source=maropost&utm_medium=email&utm_campaign=nypevening&utm_content=20210119&tpcc=evening_upda
te&mpweb=755-9252354-720539873
U.S. Soldier Accused Of Wanting To Plot ISIS Strike On 9/11 Memorial In New York City [NBC] NY/AT/CV
A U.S. soldier was arrested Tuesday [Jan. 19] for allegedly saying he wanted to help ISIS strike the 9/11
Memorial in New York City and attempting to help ISIS to target U.S. soldiers in the Middle East.
Cole James Bridges, 20, from Stow, Ohio went into an online forum and chatted with a person he thought
was with ISIS, but was in fact an FBI undercover agent.
Bridges is currently assigned to Fort Stewart in Georgia with the 3rd infantry division of the Army. He was
arrested on charges of attempting to provide material support to a designated foreign terrorist
organization and attempting to murder U.S. military service members. He faces up to 40 years in prison.
"Cole James Bridges: is positive in FBI holdings. Program Manager: CTD
January 20, 2021
New York, NY
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Man arrested on Upper East Side with SUV loaded with ammo, shotgun in aftermath of Capitol siege
A man was arrested on the Upper East Side Wednesday with an arsenal of ammunition, a shotgun and other tactical items
in his SUV in connection with the ongoing raids surrounding the siege of the Capitol, according to documents in the
vehicle and a law enforcement official.
Samuel Fisher was arrested near E. 89th St. and York Ave. on unspecified charges related to the Jan. 6 siege. He was
awaiting arraignment in Manhattan Federal Court.
A search warrant return - a document which lists what was seized in a search - visible in the Chevrolet 1500 Tahoe SUV
listed the shotgun, six cases of shotgun shells, 12 boxes of .9-mm ammunition, a black tactical vest with a loaded clip, eight
more loaded clips, a second vest with ballistic plates and a knife, and two machetes.
Members of the Joint Terrorism Task Force huddled around Fisher's SUV as cops blocked E. 88th St. after making the
arrest. Video from the scene showed an FBI officer carrying the shotgun seized from the SUV to an evidence van.
Also spotted in the car were an American flag, a copy of the Daily News with President Trump's face on it, an emergency
poncho and B12 vitamins.
It wasn't immediately clear if Fisher is accused of being part of the Capitol siege or was arrested purely for online activity.
A second man, Patrick Edward McCaughey III, was arrested Tuesday night in the upstate town of South Salem. He is in
custody and will be arraigned later Wednesday in White Plains Federal Court.
McCaughey is charged with using a riot shield to press against a Capitol police officer shown on video screaming as he's
squeezed between a door in the midst of a violent confrontation with rioters at a key entry point in the Capitol, law
enforcement sources said. The arrests followed dozens of others across the nation as federal authorities seek to hold people
who stormed the Capitol responsible for their conduct, as well as anyone making online threats to kill elected officials. Five
people died in the Capitol riot, including a police officer, in the hours-long siege that took place after President Trump
extorted a crowd to march to the Capitol. The unrest came as Congress was certifying the electoral college votes that won
Sen. Joe Biden the presidency.
http://www.nydailynews.com/new-york/nyc-crime/ny-capitol-riot-aftermath-arrest-upper-east-side-
20210120-xxjoqypbpfavteabboxdhlaou4-story.html
Terror cells in Indonesia continue to recruit and plot attacks amid COVID-19 - As Indonesia grapples with the
impact of COVID-19, terrorism cells in the country continue to spread radical messages, actively seeking new recruits
and plotting their next attacks, a senior counterterrorism official said.
In an exclusive interview with CNA, the National Counter Terrorism Agency's (BNPT) director for enforcement,
Eddy Hartono said although there has been no major terrorist attack during the pandemic, terrorism cells in Indonesia
"are not sitting back and relaxing."
"They are actively recruiting, spreading their ideology, raising funds and conducting training," the Brigadier General
said, adding that the only thing that has slowed during the pandemic is the sending of militants to join the ranks of the
Islamic State in Iraq and Syria.
The police's counterterrorism unit Densus 88 arrested a total of 232 people last year for alleged involvement in
terrorism activities.
"They are indeed planning attacks on security officials, state institutions, military and the police," Mr Hartono said.
"Thank goodness we have been able to prevent (these attacks) from happening."
Among those who were arrested last year were two of Indonesia's most wanted terrorists Zulkarnaen and Upik
Lawanga who have evaded capture for 19 and 14 years respectively.
Zulkarnaen, who goes by one name, was believed to be behind at least three terror attacks, including the 2002 Bali
Bombings while Upik Lawanga was suspected of aiding a series of terror attacks between 2004 and 2006. Zulkarnaen
was arrested in December and Lawanga was arrested in November
https://www.channelnewsasia.com/news/asia/indonesia-terrorism-attack-recruitment-plot-covid-19-bnpt-13959304
NCTC CT Weekly
(U) TERRORISM FINANCING TRENDS OVER THE LAST
The Hague (ICCT) published a paper titled "Funding in Place: Local Financing Trends Behind Today's Global
Terrorist Threat," describing how the terrorist financing landscape has changed over the last decade. ICCT
highlighted areas of terrorism financing including cryptocurrencies, criminal activities, hawala networks, and
more. A major area of focus was the increasing trend of
terrorists using localized financing, otherwise known as "funding in place."
(U) In mid-November, the International Centre for Counter-Terrorism in The Hague (ICCT) published a
paper titled "Funding in Place: Local Financing Trends Behind Today's Global Terrorist Threat",
describing how the terrorist financing landscape has changed over the last decade. ICCT highlighted
areas of terrorism financing including cryptocurrencies, criminal activities, hawala networks, and more.
EFTA00011040

=== Page 3 ===
A major area of focus was the increasing trend of terrorists using localized financing, otherwise known
as "funding in place."
(U) Whereas al-Qa'ida historically financed its affiliate groups and actors from afar, sending money for
recruitment, transportation, training, etc., terrorist groups today are less reliant on funding from group
leadership. "Funding in place" not only provides a layer of security by not having to worry about financial and
intelligence tools interrupting funding streams, but also makes it significantly harder to detect possible terrorist
financing scenarios and future attack plans. (ICCT)
U.S. Africa Command Forces Conduct Two Strikes On Al-Shabaab Operatives [DOD]
In coordination with the Federal Government of Somalia, U.S. Africa Command forces conducted two
airstrikes in the vicinities of Jamaame and Deb Scinnele, Somalia, Jan. 19.
Initial assessments indicate the strikes killed three al-Shabaab operatives.
From Radio Dalsan - SOM: A US airstrike has destroyed radio station of the Al-Qaeda-linked militant
group, Al-Shabaab, in southern Somalia. According to pro-Al-Shabaab media, the airstrike destroyed
Radio Andalus in the Tiyeglow Bakool region. US Airstrikes Target Al-Shabaab Radio
Global Terrorism
Russia
A senior Chechen official announced Wednesday that police had killed an alleged leader of the Islamic
State (ISIS) in the volatile republic, according to media reports Asharq Al-Awsat
The leader was designated in 2016 as a "global terrorist" by the U.S. Department of State, which
said he had become an ISIS leader in June of 2015
The State Department also said the man was responsible for suicide bombings in Russia
including the January 2011 attack on Moscow's Domodedovo airport that killed 35
The senior official said Chechen police officers had killed the ISIS leader and five militants
associated with him who were on Russia's wanted list
Somalia
On Tuesday, U.S. Africa Command (AFRICOM) killed three al-Shabaab operatives after launching two
airstrikes within the vicinity of Jamaame and Deb Scinnele in the Lower Juba region of southern Somalia,
media reported Wednesday Garowe Online
"These strikes targeted known al-Shabaab leaders involved in IED facilitation, fighter training, and
attack planning," a U.S. Air Force official with Joint Task Force-Quartz said
No civilians were killed or injured during the operation, AFRICOM added
Turkey
Security teams arrested a suspect in southern Turkey over alleged links to ISIS, local authorities said on
Wednesday Anadolu Agency
The suspect, who was a so-called emir of the terror group in Syria and entered Turkey illegally, was
arrested in an anti-terror operation in the Mersin province, local authorities said in a statement
The suspect was plotting terrorist attacks against public institutions and organizations in the
province, it added
Pro-AQ Unit Publishes Article Inciting Sudanese Muslims To Wage Jihad, Target "Crusaders" And Soldiers [SITE
Intelligence]
An al-Qaeda (AQ)-aligned media unit published an article inciting Sudanese Muslims to wage jihad
domestically, urging they target "dens and centers of the Crusaders" and gatherings of soldiers.
Thabaat News Agency distributed the article, entitled, "The Fighting, the Fighting.. 0 Heroes of Sudan,"
on January 19, 2021.
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=== Page 4 ===
Abu al-Bara' al-Libi, argued that the government of Prime Minister Abdalla Hamdok "facilitated" the
"Crusaders" plundering Sudan's resources, reaping benefits that the people do not receive, and together,
conspired to normalize relations with Israel. He praised the Sudanese for their participation in all jihadi
fronts, and said it is now their turn to turn Sudan into a battleground.
Kenya Defense Force Arrests Mastermind Of 2015 Mandera Bus Attack [Standard Media - KEN via Strategic
Intelligence Service - KEN]
The Kenya Defense Forces (KDF) working together with Jubaland Security Forces (JSF) have arrested
Abdullahi Dimbil Ahmed, the mastermind of the 2015 Mandera bus attack, Strategic Intelligence, an
online [Kenyan] publication, reports.
Dimbil was arrested on Monday [Jan. 18] together with one of his associates outside the Jubbaland
Security Forces camp in Southern Somalia.
Mexico's Attorney General Escalates Fight With U.S. Over Former Minister [Reuters]
Mexican Attorney General Alejandro Gertz said on Tuesday [Jan. 19] he was considering elevating to
international courts a dispute with the United States over Mexico dropping an investigation into a former
defense minister.
Gertz said the U.S. Department of Justice had effectively declared ex-defense minister Salvador
Cienfuegos innocent when it sent him back to Mexico and dropped U.S. charges against him after he was
arrested in California last year.
He defended his own decision to close a Mexican probe into whether Cienfuegos had colluded with a
drug cartel, saying the U.S. evidence was inconsistent, included questionable physical descriptions of the
retired general, and used testimony from two dead witnesses.
OCCRP
#GROUPAMERICA NEWS
Group America's Alleged Labor Ties - The criminal case against James Cahill, the president of the New York State
Building and Construction Trades Council, has taken a turn that is relevant to OCCRP's work.
Federal prosecutors say they have audio and video recordings that show Cahill has worked with the Serbian-
American drug-trafficking.gang known as Group America. He even allegedly spoke with the gang's leader, whom he
referred to as "my guy" and part of a "mass murdering crew" in the recordings.
More Reading: Haven't heard of Group America? Read our investigation into this pervasive syndicate, which
allegedly has ties to the CIA.
Maduro Ally Faces Extradition
- A court in Cape Verde ruled on Monday that Venezuelan special envoy Alex Saab
can be extradited to the United States where he faces money laundering charges. The law firm representing Saab
compared the ruling to the U.S. extradition request for Julian Assange, who they also represented in the U.K.
Italian Foreign Fighter Arrested By Turkish Authorities [ANSA - ITA]
A 24-year Italian man who allegedly fought with Al-Qaeda-linked terrorist groups in Syria and Iraq was
recently arrested by the Turkish authorities. The man moved to the Middle East in 2014 and an
international arrest warrant was put out for him in 2017.
He was arrested after being tracked down in the Syrian city of Idlib. He was transferred to the Turkish
province of Hatay, where he was handed over to the Italian authorities.
He is already in jail in Italy. The man's Turkish wife and three children stayed in Turkey.
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=== Page 5 ===
From Reuters: The hunt began on information from his parents in Switzerland, where he had lived and
was radicalized. Italy Jails Suspected Al Qaeda Foreign Fighter Caught In Turkey
Saudi-American Relations Could Waiver Over Biden's Position On Khashoggi [Jerusalem Post]
Questions abound regarding the fate of relations between Saudi Arabia and the United States under
newly installed President Joe Biden, whose incoming administration has vowed to uncover the
circumstances behind the murder of Saudi journalist Jamal Khashoggi in 2018 in the Saudi consulate in
Istanbul.
Avril Haynes, President Biden's candidate [update - now confirmed - see CONUS 3] to direct national
intelligence, has pledged to declassify the intelligence report on the murder of Khashoggi, a columnist for
the Washington Post, and to present it to Congress.
"Yes, I will abide by the law," Hines said during a Senate hearing on January 19, in response to a question
from Sen. Ron Wyden, D-Ore., about whether she would submit a report to Congress, if appointed
director of national intelligence.
Portland [Oregon] Protesters Smash Windows Of Local Democratic Party Headquarters [MSN via New York
Times] PD/SE/DN
In Portland [OR], about 200 people clad in black marched to the local Democratic headquarters, where
some of them smashed windows and tipped over garbage containers, lighting the contents of one on fire.
Those who took to the streets on Wednesday said they were a mix of anarchists, anti-fascists and racial
justice protesters. One of their signs said, "We don't want Biden - we want revenge" for killings
committed by police officers and "fascist massacres."
In Seattle, about 150 people marched with large banners that said "Abolish ICE, no cops, prisons, borders,
presidents." Some spray-painted buildings with an anarchist symbol and broke windows, including at a
federal courthouse.
For video and photos see Daily Mail - UK: We Don't Care Who's President: Antifa Rioters Smash
Windows At Oregon's Democratic Party Headquarters In Portland, Burn American Flags In Denver And
Vandalize Stores In Seattle Just Hours After Biden Took Office
'A Total Failure': The Proud Boys Now Mock Trump Members of the far-right group, who were among Donald Trump's
staunchest fans, are calling him "weak" as more of them were charged for storming the U.S. Capitol.
https://www.nytimes.com/2021/01/20/technology/proud-boys-trump.html?
aign_id=2&emc=edit_th_20210121&instance_id=26148&nl=todaysheadlines&regi_id=618988318segment_id=4988
0&user_id=e1b0b0aa6b6cfe71980fae20cb1fb321
Self-styled militia members planned on storming the U.S. Capitol days in advance of Jan. 6 attack, court documents say
https://www.washingtonpost.com/local/legal-issues/conspiracy-oath-keeper-arrest-capitol-riot/2021/01/19/fb8487a-
5a4f-11eb-8bcf-3877871c819d_story.html?wpmk=1&wpisrc=al_news__alert-politics-alert
national&utm_source=alert&utm_medium=email&utm_campaign=wp_news_alert_revere&location-alert&pwapi_token
=eyJ0eXAiOiJKV1QiLCJhbGciOilzl1NiJ9.eyJjb29raWVuYW1ljoid3BfY3J0aWQitClpc3MiOiJDYX0YSIsImNvb2tpZXZhbHVil)
oiNTk2Y2RhZGZhZGU0ZTI0MTE5ZDgxOTFmliwidGFnljoid3BfbmV3c19hbGVydF9yZXZlcmUiLCJ1cmwiOiJodHRwczovL3d3dy
53YXNoaW5ndG9ucG9zdC5jb20vbG9jYWwvbGVnYWwtaXNzdWVzL2NvbnNwaXJhY3ktb2F0aC1rZWVwZXItYXJyZXN0LWNh
cGl0b2wtcmlvdC8yMDlxLzAxLzE5L2ZiODQ4NzdhLTVhNGYtMTFlY04YmNmLTM4Nzc4NzFjODE5ZF9zdG9yeS5odG1sP3dwb
Ws9MSZ3cGlzcmM9YWxfbmV3c19fYWxlcnQtcG9saXRpY3MtLWFsZXJ0LW5hdGvbmFsinV0bV9zb3VyY2U9YWxlcnQmdXRt
X21ZGl1bT1lbWFpbCZ1dG1fY2FtcGFpZ249d3BfbmV3c19hbGVydF9yZXZlcmUmbG9jYXRpb249YWxlcnQifQ.NA3x7wlgl1uJ
GoZQLQ_2k55r8m-MLPIV6E57Qqb5mtl
SITE: Bloomberg Interview with Rita Katz: "Online Extremism Expert Says Far Right Has Adapted ISIS Playbook"
In a post-Capitol Siege interview with Bloomberg, SITE director Rita Katz says the trajectory of the Far Right movement in
the U.S. is very similar to that of ISIS, as "both were formed out of rejection of their movements' establishments, both
EFTA00011043

=== Page 6 ===
were adept at leveraging social media for recruitment and setting up vast online infrastructures, and both have prioritized
action over a coherent ideology."
https://www.bloomberg.com/news/articles/2021-01-15/far-right-radicalization-site-intelligence-s-rita-katz-tracks-
movement
U.S. Lawmakers Aim To Curtail Face Recognition Even As The Technology IDs Capitol Attackers [Reuters]
WFO/Multiple Field Offices
U.S. lawmakers are moving ahead with efforts to ban facial recognition software even as the technology
helps identify supporters of President Donald Trump who ransacked their workplace and forced them to
evacuate this month.
Researchers and law enforcement have been running photographs from the Jan. 6 siege of the Capitol
through facial recognition, which looks for similar faces in databases of mugshots, social media headshots
or other images.
Senator Ed Markey said that the technology may not be worth the risks. Racial justice activists have
warned that facial recognition can perpetuate discriminatory policing and constant tracking could
become the norm.
'No Plan, No Q, Nothing': QAnon Followers Reel As Biden Inaugurated [Reuters] multiple field offices
On Wednesday [Jan. 20], QAnon adherents grappled with a harsh reality check: Trump had left office with
no mass arrests or other victories against the supposed cabal of Satan-worshipping pedophile cannibal
elites, especially Democrats, he was ostensibly fighting.
In one Telegram channel with more than 18,400 members, QAnon believers were split between those still
urging others to 'trust the plan' and those saying they felt betrayed. "It's obvious now we've been had.
No plan, no Q, nothing," wrote one user.
Some messages referenced theories that a coup was going to take place before the end of Inauguration
Day. Others moved the goalposts again, speculating that Trump would be sworn into office on Mar. 4.
See also Wall Street Journal: What Is QAnon? What We Know About the Conspiracy-Theory Group
Articles on Parler:
https://cybernews.com/news/new-report-violent-hashtags-on-parler-skyrocketed-on-january-6/
https://cybernews.com/news/70tb-of-parler-users-messages-videos-and-posts-leaked-by-security-researchers/
Ghislaine Maxwell hearing illegally streamed by apparent QAnon followers
https://nypost.com/2021/01/20/apparent-ganon-followers-illegally-stream-ghislaine-maxwellhearing/
'The Shining' Scene, Stuff of Nightmares, Turns a Criminal Case Upside Down A prosecutor erred by likening a man
charged with robbing a bank to Jack Nicholson's violent psychopath, New Jersey's highest court ruled.
https://www.nytimes.com/2021/01/20/nyregion/the-shining-bank-robbery.html?
ampaign_id=2&emc=edit_th_20210121&instance_id=26148&nl=todaysheadlines&regi_id=61898831&segment_id=4988
D&user id=e1b0b0aa6b6cfe71980fae20cb1fb321
Opinion The Problem With Trump's Odious Pardon of Steve Bannon It is corrupt and a possible obstruction of
justice and should be legally challenged. https://www.nytimes.com/2021/01/20/opinion/trump-bannon-
pardon.html?
ampaign_id=2&emc=edit_th_20210121&instance_id=26148&nl=todaysheadlines&reg_id=61898831&segmer
t_id=49880&user_id=e1b0b0aa6b6cfe71980fae20cb1fb321
Take care,
Senior Intelligence Specialist
U.S. Attorney's Office - SDNY
Terrorism & International Narcotics Unit
One St. Andrew's Plaza
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New York, NY 10007
(Please note: my current cell phone coverage is not dependable and the voicemail can be delayed, if you don't receive a
call back within an hour, please text, email or call me a
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From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
(USANYS)"
i
[Contractor]"
Subject: RE: SDFL Epstein-related documents
Date: Mon, 31 Aug 2020 22:16:00 +0000
Thank you very much for looking into this and for all of your help. For now, we would like to look into having a vendor
scan the entire file and make copies of any CDs and cassette tapes in the files. Would you be able to send us the names of
vendors you have used in the past please?
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
NV
10007
From:
Sent: Friday, August 28, 2020 5:39 PM
To:
(USANYS)
Cc:
is
is
i
(USANYS)
[Contractor]
Subject: Re: SDFL Epstein-related documents
Sorry it took time to get back to you. In answer to the questions from the call.
1. You are welcome to come to our office in West Palm Beach. We can set up a floor where you will be reasonably alone
and can safely scan materials. There is a Marriott within a block of our office if you decide to come.
2. Turns out we cancelled our copy service earlier this year and never got it going again due to Covid. I can get names of
vendors we used in the past if you want to go that route.
3. There are cds and cassette tape in the materials according to the legal assistant that has done the inventory.
Feel free to contact me with any other questions.
Best regards
EFTA00009860

=== Page 2 ===
Sent from my iPhone
On Aug 25, 2020, at 11:02 AM,
(USANYS)
wrote:
Thanks very much for the quick response,
3pm today works for us. We can circulate a dial in and look forward to
talking further then.
From:
Sent: Tuesday, August 25, 2020 9:31 AM
To:
(USANYS)
Cc
is
)
>;
is
(USANYS)
is
(USANYS) [Contractor]
Subject: RE: SDFL Epstein-related documents
Hello
I can do a call this afternoon. Any time between 2:00 p.m. and 4:00 p.m. is best. Alternatively, I am available tomorrow
during the same time period. Let me know which time is more convenient for you and your team. If these times don't
work, let me know and we will work out an alternate time.
In the meantime, we have all the materials in a secure room on our second floor in West Palm Beach. There are the
case files and also boxes of files that were gathered for the OPR inquiry. We have an inventory of our materials and also
OPR has their own inventory of the materials.
When OPR was here earlier, we had a scanner on that floor dedicated for their exclusive use. They were able to scan the
documents that they wanted and have those documents sent directly to their own DOJ accounts. I was overseas at the
time on detail, but I was told that this worked rather well.
A copy of our inventory is attached.
I look forward to assisting you in this matter.
Best regards,
Managing Assistant United States Attorney
West Palm Beach Regional Office - SDFL
From:
(USANYS)
Sent: Tuesdav. August 25. 2020 9:00 AM
To:
EFTA00009861

=== Page 3 ===
Cc:
is
>;
is
(USANYS)
>;
(USANYS) [Contractor]
Subject: SDFL Epstein-related documents
We supervise the team in New York that is currently prosecuting Ghislaine Maxwell, and
suggested we reach out to you. As discussed briefly with
we are hoping to locate the boxes of documents and
other records regarding the prior SDFL investigation into Jeffrey Epstein and his co-conspirators that we understand are
currently being stored in the West Palm Beach office. In particular, we would like to make arrangements to review and
scan those materials in connection with our own case, and
suggested that we touch base with you on how best to
do so.
I've copied the trial team here. Please let us know if you have time for a call in the near future to discuss further.
Alternatively, if there is a more appropriate point of contact on this issue, please feel free to point us in that direction.
Thanks very much,
Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00009862


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=== Page 1 ===
From:
)"
To: Laura Menninger
>, , Jeff
Pagliuca
Cc:
(USANYS)"
)"
)"
Ann Lundberg
Subject: RE: questionnaires
Date: Sat, 13 Nov 2021 23:08:15 +0000
Attachments: 2021-11-13_joint_letter_regarding_juror_questionnaires.pdf
Laura,
Attached is a draft of the joint letter. Please note that we've joined the defense's position with respect to the prospective
jurors with numbers 626, 629, 632, 640, 643, 646, 649, 657, 681, 682, 647, and 655.
From: Laura Menninger
Sent: Saturday, November 13, 2021 5:24 PM
To:
is
;
Jeff Pagliuca
Cc:
(USANYS)
>;
>;
>; Ann Lundberg
Subject: [EXTERNAL] RE: questionnaires
Hi
Checking in. Do you have the compiled lists ready for us to review yet?
-Laura
From:
Sent: Saturday, November 13, 2021 11:31 AM
To: Laura Menninger
i
;
; Jeff Pagliuca
Cc:
(USANYS)
is
>;
)
<
V
Subject: RE: questionnaires
Thanks, that's helpful. Attached is our list.
From: Laura Menninger
Sent: Saturday, November 13, 2021 12:45 PM
To:
is
; Jeff Pagliuca
Cc:
(USANYS)
i
)
is
Subject: [EXTERNAL] RE: questionnaires
EFTA00010218

=== Page 2 ===
Please let me know when you're ready to exchange the last batch of juror questionnaire positions. We have prepared
ours in Excel this time and hope that will be easier for you to import.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
From:
Sent: Friday, November 12, 2021 12:00 PM
To:
;
; Laura Menninger
>; Jeff Pagliuca
Cc:
(USANYS)
is
>;
Subject: questionnaires
All,
The prospective juror questionnaires completed today are available on USAfx. We will let you know when printed copies
are available for pickup. If you could please send us your list of objections by tomorrow at 1 p.m., we can handle putting
together the joint letter to the Court, in the same process as before.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00010219


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=== Page 1 ===
From: Christian Everdell
To:
)"
)"
(USANYS)"
Cc: "Mark S. Cohen"
>, , Bobbi Sternheim
>, Jeff Pagliuca
>, , "Laura Menninger"
Subject: RE: Discovery Requests
Date: Fri, 29 Jan 2021 20:52:49 +0000
Inline-Images: image001.jpg; image002.jpg
Thanks for the follow-up. Please send the documents to the FTP link below:
https://cohengresser.sharefile.com/r-r16397a3bc183400da73b80cbfa69f256
Also, we are missing the Bates ranges listed below.
SDNY_GM_00167911 through SDNY_GM_00168477
SDNY_GM_00168488 through SDNY_GM_00169165
SDNY_GM_00169184 through SDNY_GM_00169491
SDNY_GM_00169505 through SDNY_GM_00169735
We had discussed these ranges several months ago and I believe you had agreed to reproduce them in the 11/9
production. But we do not appear to have received them. Can you send these ranges via the FTP site as well?
Thanks,
Chris
From:
) [mailto:
Sent: Friday, January 29, 2021 10:31 AM
To: Christian Everdell;
);
(USANYS)
Cc: Mark S. Cohen; Bobbi Sternheim; Jeff Pagliuca; 'Laura Menninger'
Subject: RE: Discovery Requests
Chris,
Following up on this, we have now prepared all of the items you requested in point 6 below for production to you. Our
paralegals have sent a copy of the materials to the MDC for your client. Would you like to provide us with an FTP link for
this production, or would you like us to prepare a CD for you instead?
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00011489

=== Page 2 ===
From:
Sent: Monday, January 25, 2021 3:56 PM
To: 'Christian Everdell'
>;
)
is
(USANYS)
Cc: 'Mark S. Cohen'
>; 'Bobbi Sternheim'
>; 'Jeff Pagliuca'
>; 'Laura Menninger'
Subject: RE: Discovery Requests
Chris,
Following up on point 6 below, our paralegals have re-stamped the materials you identified with a Bates range overlap
and are prepared to reproduce those materials to you. The materials are small enough to produce via your FTP site.
Would you like to send us a link to where you would like those materials uploaded? Alternatively, we can load the
materials to a CD and send it to you.
We are still waiting to hear back from our vendor about the remaining issues you identified in point 6.
Thanks,
Assistant United States Attorney
Southern District of New York
From:
Sent: Sunday, January 17, 2021 10:05 PM
To: Christian Everdell
i
)
i
(USANYS)
Cc: Mark S. Cohen
>; Bobbi Sternheim
>; Jeff Pagliuca
>; 'Laura Menninger'
Subject: RE: Discovery Requests
Chris,
Below please find our responses.
1. As we have recently discussed, Ms. Maxwell now has access to the 4TB drive containing a full set of the discovery
produced to date. It took a significant amount of time to create this copy due to the volume of discovery and
delays on the part of our vendor, who assisted in creating the copy.
2.
As we have recently discussed, Ms. Maxwell now has a drive containing the contents of the CD produced on
November 18, 2020.
EFTA00011490

=== Page 3 ===
3. As I conveyed to you over the phone and in a recent email, the materials produced from the Subject Devices all
contain metadata indicating the "NYC" CART Evidence Number of the device from which each document was
extracted. In our November 18, 2020 discovery letter, we provided you with a chart setting forth which "NYC"
CART Evidence Number corresponds with which Subject Device in our warrants. If you still need a detailed index
of all 1.2 million documents with the specific Subject Device indicated, please let me know, and I will ask one of
our paralegals to compile one.
4. We produced the FBI report bearing Bates number SDNY_GM_02050812-14 in the form in which it was
recovered from one of Epstein's devices. In other words, we did not apply any redactions to that document;
rather, the redactions existed on the document at the time the document was found during the FBI's search of
Epstein's devices. We are not aware of any legal basis for your request for a log of redactions. If you have any
legal authority on that point, we would be happy to consider it. As a courtesy, I will note that our office did not
apply redactions to any material that was identified responsive during the searches of Epstein's devices.
5. We are aware of our discovery obligations, have complied with them, and will continue to comply with them. We
are not aware of any legal basis for your request that we inform you of what, if any, documents have been
withheld or the basis for their withholding. If you have any legal authority on that point, we would be happy to
consider it. As a courtesy, I will note that we have provided you with all records we received from AT&T and all
records we received from David Rodgers. As to your inquiry about the Bates ranges on the Rodgers documents
beginning with Bates number "28", I note that the folder containing the Rodgers subpoena returns in our August
5, 2020 production included two documents. The first (SDNY_GM_00005532-5649) is the document you
referenced in your email inquiry. The second (SDNY_GM_00005650-5676) is 27 pages long, accounting for the
first 27 pages of the production from Rodgers. We produced those two documents in the form in which we
received them.
6. Our paralegals are working on the issues you identified with Bates ranges and metadata load files. I will reach
back out to you once I have an update on the status of those issues.
7. We do not have a more detailed index of the November 9 and November 18 productions beyond what we have
provided to you.
8. We are not aware of any legal basis for your request for copies of grand jury subpoenas. Nor are we aware of any
legal basis for your request that we identify the date range of documents we requested in each subpoena. If you
have any legal authority for those requests, we would be happy to consider it.
9. The court filings that appear to be referenced in the Daily Beast article you sent are an application for a search
warrant and a search warrant filed in the District of New Hampshire. We produced both documents to you in
discovery on August 5, 2020. The DNH judge issued a sealing order in connection with the warrant and
application. As you can see at Bates No. SDNY_GM_00000621, the sealing order automatically expired on
December 30, 2020. Our understanding is that the District of New Hampshire unsealed the filing of its own
accord in conformity with the clear language of that sealing order. Our office took no affirmative steps to unseal
or otherwise release these filings.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00011491

=== Page 4 ===
From: Christian Everdell
Sent: Thursday, January 7, 2021 4:13 PM
To:
is
is
(USANYS)
Cc: Mark S. Cohen
>; Bobbi Sternheim
>; Jeff Pagliuca
>; 'Laura Menninger'
Subject: Discovery Requests
We write to raise a number of discovery issues. Please let us know your position on these issues at your earliest
convenience.
1. In our email correspondence on 11/18/2020, you agreed to create a new hard drive containing the entire discovery
production. We provided you with a 4TB hard drive for that purpose on 11/20/2020. It is very important for Ms.
Maxwell to have this drive as soon as possible to prepare her defense. Do you have an update on when the drive
will be ready?
2. We also informed you that the CD produced on November 18, 2020 did not work on the prison computer at the
MDC (as you know, the laptop provided to Ms. Maxwell does not have a CD drive). Accordingly, we asked you to
include the material on the CD in the new 4TB hard drive. We followed-up with you about this issue on December
30, 2020. Given that the new hard drive is still not ready, we ask that you download the material on the CD onto
a separate thumb drive or hard drive and provide it as quickly as possible to Ms. Maxwell at the MDC so that she
can review the materials this weekend. Alternatively, you can provide an external CD drive to Ms. Maxwell at
the MDC so that she can read the files on the MDC computer. We will provide whatever media device you
require to facilitate this production.
3. Unlike the November 9, 2020 discovery cover letter, the November 18, 2020 discovery cover letter (attached) does
not correlate the Bates numbers to the particular "Subject Device" from which the documents were recovered.
Instead, the cover letter indicates that the documents came from "SDNY_PROD015" or "SDNY_PROD016." We do
not know what those terms refer to. We request that the government produce a list that correlates the Bates
numbers for all of the documents in SDNY_PROD015 and SDNY_PROD016 to the particular devices from which the
documents were recovered.
4. We request that the government provide an unredacted version of the FBI report, dated December 6, 2006,
bearing Bates number SDNY_GM_02050812-14 (attached). We also request that the government produce a log
identifying all of the redacted documents in the discovery and the bases for each of the redactions.
5. There are a few documents that seem to be missing from the discovery. For example, the AT&T documents
(SDNY_GM_00001015-3637) do not seem to include subscriber information for the various phone numbers. Also,
the flight logs produced by David Rodgers begin at Bates number "Rodgers000028," suggesting that
Rodgers000001-000027 were not produced to us. Please produce these documents to us or provide an
explanation why you are not producing them to us. Please confirm whether there are other documents that were
removed from the grand jury subpoena productions that we have not yet identified and the basis for their removal.
6. There are a few Bates number/metadata issues with some of the documents:
a. There is an overlap between the fourth and fifth document productions. The fourth production ends at
SDNY_GM_00328863, the fifth production begins at SDNY_GM_00328070. We propose renumbering the
range from the fifth production (i.e., renumber SDNY_GM_00328070-328863).
EFTA00011492

=== Page 5 ===
b. The metadata load files (*.DAT) for PROD011 had a number of gaps which are detailed in the attached Excel
file. We propose that you send us a new DAT file covering only the missing documents.
C. The metadata load files (*.DAT) for PROD015 had a gap from SDNY_GM_00723971 to SDNY_GM_00723981.
We propose that you send us a new DAT file covering only the missing documents.
7. To the extent that the government has created an index of the documents produced on November 9 and
November 18 that is more detailed than the production cover letters, we request that you provide a copy to the
defense.
8. We request that the government provide copies of the grand jury subpoenas for documents issued by the
government in this case. Also, please identify the date range of documents you requested in each subpoena.
There is one other issue we'd like to raise. An article in the Daily Beast on Monday referenced the search warrant affidavit
for the cell-site simulator used to track Ms. Maxwell's cellphone before her arrest (https://www.thedailybeast.com/how-
the-fbi-tracked-down-ghislaine-maxwell-alleged-madam-of-jeffrey-epstein). The article stated that the affidavit appeared
in a "newly unsealed court filing." I don't recall this affidavit being unsealed or referenced in anything that was filed on
the court docket. Please confirm whether or not the government unsealed this affidavit or any other materials from the
criminal discovery, and whether any discovery materials were released pursuant to FOIA requests.
Regards,
Chris
Christian R Everdell
COHEN & GRESSER LLP
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
GG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
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the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00011493


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=== Page 1 ===
November 4, 2008
VIA FACSIMILE (561) 820-8777
& U.S. MAIL
Ms.
Assistant United States Attorney
Southern District of Florida
West Palm Beach, Florida 33401
Re:
Ethics Inquiry 28386
Dear Ms.
:
I received your request for an advisory ethics opinion dated September 18, 2008. You ask
whether you violated Rule 4-7.4, Rules Regulating The Florida Bar, by complying with your
statutory obligation to contact victims to inform them of the resolution of their matters and by
complying with a court order to advise them that the services of an independent attorney-
representative would be offered to them free of charge.
Unfortunately, I cannot provide the opinion you requested, because you are asking about your
past conduct and legal questions that relate to your obligations under federal statutes and a court
order. Florida Bar ethics attorneys are only authorized to provide opinions regarding an
attorney's own future conduct. We are not authorized to render opinions concerning an
attorney's past conduct or legal questions. See Procedures 2 (a)(1)(B) and 2(a)(1)(D), Florida
Bar Procedures for Ruling on Questions of Ethics (www.floridabar.org).
Although I cannot provide an opinion, I can discuss the relevant rules. Generally speaking, Rule
4-7.4 (a), prohibits an attorney from soliciting clients in person or through an agent, or in writing
without complying with the attorney advertising rules, if the lawyer's primary motive is
pecuniary gain, and states:
(a) Solicitation. Except as provided in subdivision (b) of this rule, a lawyer
shall not solicit professional employment from a prospective client with whom the
lawyer has no family or prior professional relationship, in person or otherwise,
when a significant motive for the lawyer's doing so is the lawyer's pecuniary
gain. A lawyer shall not permit employees or agents of the lawyer to solicit in the
lawyer's behalf. A lawyer shall not enter into an agreement for, charge, or collect
a fee for professional employment obtained in violation of this rule. The term
"solicit" includes contact in person, by telephone, telegraph, or facsimile, or by
EFTA00014011

=== Page 2 ===
Ms.
November 4, 2008
Page 2
other communication directed to a specific recipient and includes (i) any written
form of communication directed to a specific recipient and not meeting the
requirements of subdivision (b) of this rule, and (ii) any electronic mail
communication directed to a specific recipient and not meeting the requirements
of subdivision (c) of rule 4-7.6.
Emphasis added. If your contact with victims is neither motivated by pecuniary gain nor to
assist another lawyer whose significant motive is pecuniary gain, then it is unlikely that your
contact with victims could be characterized as improper solicitation in violation of Rule 4-7.4
(a).
Although your letter does not reference Rule 4-4.2 ("Communication with Person Represented
by Counsel"), this rule prohibits a lawyer from communicating directly with a person the lawyer
knows is represented in a particular matter, and states:
(a) In representing a client, a lawyer shall not communicate about the subject
of the representation with a person the lawyer knows to be represented by another
lawyer in the matter, unless the lawyer has the consent of the other lawyer.
Notwithstanding the foregoing, an attorney may, without such prior consent,
communicate with another's client in order to meet the requirements of any
court rule, statute or contract requiring notice or service of process directly on an
adverse party, in which event the communication shall be strictly restricted to that
required by the court rule, statute or contract, and a copy shall be provided to the
adverse party's attorney.
Emphasis added. It would be prudent for you to comply with this rule by limiting your contact
to the lawyers of represented victims. Whether or not you were required to comply with this rule
in the past, or whether you would be required to comply with it in the future, given your
obligations under the federal statutes and the relevant court order involves legal questions
beyond the scope of an ethics opinion.
Finally, Rule 4-3.4, prohibits a lawyer from deliberately violating a court's order, and states:
A lawyer shall not:
(c) knowingly disobey an obligation under the rules of a tribunal except for an
open refusal based on an assertion that no valid obligation exists;
Emphasis added.
EFTA00014012

=== Page 3 ===
Ms.
November 4, 2008
Page 3
Thus, Rule 4-3.4 (c), requires you to comply with any orders issued by the court. Again, I can
provide no opinion on how to accomplish compliance, because interpretation of the court order
requires legal advice beyond the scope of an ethics opinion.
If you disagree with my denial of your request for an advisory ethics opinion, you have thirty
(30) days to request that the Professional Ethics Committee review the denial. A request for
review must be addressed to Elizabeth Clark Tarbert, Ethics Counsel, at
,
Tallahassee, Florida 32399. The request must be postmarked no later than thirty (30) days from
the date of this letter, not the date of receipt. The request must contain the original inquiry
number and clearly state the issues for review. You may include a written argument explaining
why you believe you should be issued an advisory ethics opinion. Procedures governing your
request for review and committee procedures may be found in Procedures 3(d), 4 and 6, Florida
Bar Procedures for Ruling on Questions of Ethics (available on The Florida Bar's website at
www.floridabar.org). The Professional Ethics Committee meets approximately four times per
year. You will be notified of the committee's decision promptly.
If you have any questions, please call me at
Sincerely,
Gail E. Ferguson
Assistant Ethics Counsel
GEF/gef
28386gef denial
EFTA00014013


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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.
EFTA00014135

=== Page 2 ===
(c)
Before counsel for petitioners show the Agreement to their clients or
discuss the specific terms with them, they must provide a copy of this Order to
petitioners, who must review and acknowledge their receipt of, and agreement to abide
by, the terms of the Order. Counsel for petitioners must promptly 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. Counsel for petitioners must promptly 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
EFTA00014136

=== Page 3 ===
UNITED STATES DISTRICT JUDGE
Copies furnished to:
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:
EFTA00014137


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=== Page 1 ===
From:
To:
(USAFLS)"
Subject: <no subject>
Date: Sun, 29 Jun 2008 22:59:25 +0000
Importance: Normal
Attachments: GRAND_JURY_PRESENTATION_PART_II.docx
EFTA00013875


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=== Page 1 ===
Fro
Subject: Fwd: SAS: Request 21000415 has been approved
Date: Tue, 12 Oct 2021 13:54:27 +0000
Attachments: Witness_Immunity-21000415.pdf
Please see below. We will reach out to victim attorneys today or tomorrow.
Begin forwarded message:
From: OEO Special Approvals System <crm.no-reply@usdoj.gov>
Date: October 12, 2021 at 9:39:04 AM EDT
Subject: SAS: Request 21000415 has been approved
To whom it may concern,
Your Witness Immunity request (21000415), submitted to us on 09/24/2021 has been approved.
Please see attached approval letter for details.
EFTA00011094


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=== Page 1 ===
From:
"
Cc:
Subject: Epstein Update
Date: Wed, 15 May 2019 14:32:05 +0000
Importance: Normal
Attachments: 2019-05-10_JE_status_memo_for_ODAG.finaldocx.pdf
Attached is an update on the progress of the Epstein investigation. Please keep this memo on close hold given the
sensitivity of the matter and our effort remain covert.
Feel free to let us know if you have any questions.
Regards,
EFTA00009936


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=== Page 1 ===
From:
To:
Subject: Fw: Civil suit in NY against Epstein
Date: Thu, 29 Nov 2007 19:38:59 +0000
Importance: Normal
Fyi
Sent from my BlackBerry Wireless Handheld
Original Message
From:
To:
Sent: Thu Nov 29 14:24:17 2007
Subject: Civil suit in NY against Epstein
http://www.abovethelaw.com/2007/11/maximilia_cordero_maybe_not_a.php#fmore
Assistant United States Attorney
Southern District of Florida
99 NE 4th Street
Miami, FL 33132
EFTA00013762


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=== Page 1 ===
From
To
Bee
Subject: SDNY PRESS CLIPPINGS, THURSDAY, JANUARY 14, 2021
Date: Thu, 14 Jan 2021 17:51:08 +0000
Inline-Images: image001 png
OF
SDNY PRESS CLIPPINGS
ENITED
DEPARTMENT
JUSTITIA
TOYOTA SETTLEMENT
Exclusive: Toyota settles U.S. probe into delayed emissions defect reports for $180 million filing I Reuters
U.S News & World Report Money Exclusive: Toyota to Settle U.S. Probe Into Delayed Emissions WASHINGTON (Reuters) Toyota Motor Corp will settle a Justice is set to announce the settlement later on
Thursday. the sources said, that 50 mins ago
CAPITOL RIOTS
New York Daily News MTA worker accused in Capitol riot arrested upstate Will Pepe, a laborer at Metro-North's rail yard in Brewster, is due to appear in White Plains Federal Court on Wednesday morning,
officials said. 1 day ago (nydailynews.com)
Gothamist Metro-North Employee Arrested By FBI In Connection With Attack On Capitol Will Pepe, 31, of Beacon, New York, was taken into custody Tuesday and will make an appearance on an initial complaint
Wednesday in 1 day ago
MATTERS OF INTEREST
The New York Times Trump Impeached for Inciting Insurrection But this time, Senator Mitch McConnell, Republican of Kentucky and the John Katko of New York, Adam Kinzinger of Illinois, Fred Upton of
Michigan, Dan
16 hours ago (nytimes.com)
Variety Ghislaine Maxwell Podcast 'Hunting Ghislaine' Scores Scripted Adaptation by Sony-Backed Eleventh Hour Films A chart-topping true crime podcast about Ghislaine Maxwell from U.K. radio station LBC is
set to be adapted for the small screen. 1 day ago
New York Post NYC cabbie robbed at gunpoint after picking man up from Bronx motel, cops say The livery cab driver, 64, picked the suspect up from the Paradise Motor Inn on Boston Road around 8 p.m. on
Aug. 3 and drove him about 5 Aug 22, 2020 (nypost.com)
New York attorney general suing NYPD over protest response (politico
Deadline DOJ Antitrust Chief Makan Delrahim To Step Down On Jan. 19 Biden, who has nominated Merrick Garland as the next attorney general, has yet to announce a nominee to lead the Antitrust Division.
Subscribe to Deadline 2 hours ago
Acting Attorney General Jeffrey A. Rosen's Video Statement on the Seizure of the U.S. Capitol I OPA I Department of Justice
The New York Times Amid Riot Chaos, Some National Security Leaders Are Absent From View Neither the acting attorney general, Jeffrey A. Rosen, nor the F.B.I. director, Christopher A. Wray, has appeared at
the type of high-profile news conference that 16 hours ago (nytimes.com)
The Hill Marjorie Taylor Greene says she will introduce impeachment articles against Biden I TheHill There is no evidence that Hunter Biden's work influenced U.S. policy. In her Newsmax interview Wednesday,
which aired hours after the House voted to impeach 13 hours ago
EFTA00011037

=== Page 2 ===
Billionaire Guo Wengui wins discovery on cyberattack in Clark Hill malpractice fight I. Reuters
As House votes to impeach him, Trump's focus shifts to brand rehabilitation (nbcnews.
The Hill Yang announces run for New York City mayor I TheHill "I moved to New York City 25 years ago. I came of age, fell in love, and became a father here. Seeing our City the way it is now breaks my heart,"
he added. 5 hours ago
Bloomberg Nikola (NKLA) Faces Daunting Future After Losing GM, BP, Other Partners Clean-energy startup Nikola Corp. had a tough year even by 2020 standards. The once high-flying alternative-fuel vehicle
maker started life as a public 6 hours ago
JD Supra Human Trafficking and Health Care Providers: Legal Health care providers who treat victims of human trafficking are subject to a patchwork of sometimes inconsistent laws regarding their reporting
obligations. 15 hours ago
FBI Washington field office got an F for fighting domestic terrorism from bureau officials (nbcnews.co
SDNY Correctly Protects Preliminary Drafts of Publicly Disseminated Documents 1. McGuireWoods LLP . JDSupra
WRCB-TV NASA scientist pleads guilty to lying about involvement in Now, having admitted his crime, Meyyappan awaits sentencing," acting US Attorney Audrey Strauss said in a statement. Since 2006,
Meyyappan has been chief 10 hours ago
EFTA00011038


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Ghislaine Maxwell 02879-509
Date: Wed, 30 Dec 2020 18:21:52 +0000
I have reached out to MDC legal counsel to discuss the two emails you sent me today regarding Ms. Maxwell's conditions
of confinement. I will reach back out to you once I have had that conversation.
Thank you and Happy New Year,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From:
Sent: Wednesday, December 30, 2020 1:16 PM
To:
Cc:
is
(
is
i
Subject: Ghislaine Maxwell 02879-509
MDC Legal continues to provide inaccurate information.
Contrary to the information provided to you as recited in your email of 12/29-
"MDC legal counsel confirmed that no staff member has ever directed
Ms. Maxwell to remain in a particular location within her isolation cell.
They confirmed that staff understand that no such directions should be given."
last evening (12/29), Ms. Maxwell was instructed by guards not to stand
on either corner of her isolation cell, not to stand to the left or right of the toilet and sink,
and not to stand within 2.5 feet of the door to the cell.
She was told that if she did not comply with this directive, she would receive a disciplinary sanction.
In addition, she is not receiving food designated on the menu.
Further, the discovery disc provided does not work on the MDC computer; and the computer
reports multiple errors indicating it cannot accommodate disc.
Consequently, a replacement disc and/or replacement computer is required.
Please let us know of the status of hard drive containing complete production;
EFTA00013303

=== Page 2 ===
its immediate production could eliminate the disc issue.
Your assistance is appreciated.
New York, NY 10011
Main:
Cell:
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
EFTA00013304


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=== Page 1 ===
November 12, 2021
VTC prep
AUSA
SA
Attorney
Prepared for trial testimony.
was shown following GX and confirmed recognized:
GX-113 - VR
GX-114 - VR
GX-112 - JE
GX-327
GX-110 - Recognizes, believes
GX-12
full name
different/clarifying statements below:
In or around 1998,
believes JE started going to USVI most weekends
recalls that pilots had beepers earlier on to notify of flights, then had cellphones later
on
EFTA00010216


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=== Page 1 ===
Event: Epstein Pre-Meet
Start Date: 2007-12-14 17:15:00 +0000
End Date: 2007-12-14 17:45:00 +0000
Organizer: Acosta, Alex (USAFLS)
Location: Alex's Office
Class: X-PERSONAL
Date Created: 2015-03-27 13:43:26 +0000
Date Modified: 2015-07-22 20:34:48 +0000
Priority: 5
DTSTAMP: 2007-12-13 22:12:41 +0000
Attendee:
EFTA00013475


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=== Page 1 ===
From:
To: "Acosta, Alex (USAFLS)" <AAcosta@usa.doj.gov>,
Bcc:
Subject: FW: Jeffrey Epstein Agreement
Date: Tue, 05 Aug 2008 22:35:12 +0000
Importance: Normal
Attachments: Epstein_Agrmt001.pdf
Hi everyone - - I still haven't heard from Roy, but in the meantime, I have been looking for correspondence that
could be described as an assent to the modification in the December letter.
First, as set forth below, prior to the change of plea, we informed Epstein's counsel that we took the position that
we already have a binding agreement and that nothing further was required. (This was a June 24 e-mail)
Dear Roy and Jack:
I am just writing to re-state that it is the Government's position that we have a signed, binding agreement and
that there is no need for further modification.
Please keep us informed of the date and time of the change of plea and sentencing.
Thank you.
We took the same position in the e-mails that
and I sent to Jay Lefkowitz notifying him of Epstein's need to
promptly perform their obligations following the various DOJ decisions. This was the language we used:
Dear Mr. Lefkowitz:
I understand that the Deputy Attorney General has completed his review of the Epstein matter and has
determined that federal prosecution of Mr. Epstein's case is appropriate.
Accordingly, Mr. Epstein has until the close of business on Monday, June 30, 2008, to comply with the terms and
conditions of the agreement between the United States and Mr. Epstein (as modified by the U.S. Attorney's
December 19th letter to Ms.
), including entry of a guilty plea, sentencing, and surrendering to begin his
sentence of imprisonment.
If you have any questions, please feel free to contact me at the number shown below.
(This was sent on June 23ʳᵈ to Jay and June 24th to Roy.) Following this correspondence, Epstein entered his
guilty plea.
On June 30th, a couple of hours after the change of plea, the agents and I went to Jack Goldberger's office and
met with Jack and Mike Tein. We provided them with the proposed Notification of Identified Victims. On the
first page of that notice, we wrote the following:
In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal
prosecution in favor of this state plea and sentence, subject to certain conditions.
One such condition to which Epstein has agreed is the following:
EFTA00013923

=== Page 2 ===
"Any person, who while a minor, was a victim of a violation of an offense enumerated in
Title 18, United States Code, Section 2255, will have the same rights to proceed under
Section 2255 as she would have had, if Mr. Epstein had been tried federally and
convicted of an enumerated offense. For purposes of implementing this paragraph, the
United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was
prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein.
Any judicial authority interpreting this provision, including any authority determining
which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent
of the parties to place these identified victims in the same position as they would have
been had Mr. Epstein been convicted at trial. No more; no less."
On July 9, 2008, Jack Goldberger wrote me a letter with some objections to the Proposed Notification. Although
he had several requests for changes, he stated: "Rather, a simple one page notification directed only to the
recipient, and limited to the information currently on the first page of your draft memorandum would suffice."
This, to me, is a written assent that the quoted language is, in fact, one of the conditions to which Epstein has
agreed. So, I think that we do have a written, binding agreement comprised of the three documents that, as far as
I know, were filed with the state court with Jack Goldberger's approval. (I am waiting to hear back from the
ASA.)
Here again is what I provided to the State Attorney's Office, for your records.
<<Epstein Agrmt001.pdf>>
I am concerned that we were adamant before Epstein's plea that we had a complete agreement and nothing more
was necessary and now taking the position that we do not have an operative document (or set of documents).
does the Black and Goldberger correspondence described above allay your concerns? Or would you still
like me to raise this issue with Roy whenever he gets back to me?
Thank you, sorry for the lengthy e-mail.
Assistant U.S. Attorney
Phone
Fax
From:
Sent: Tuesday, June 24, 2008 4:05 PM
To: 'Roy BLACK'; 'Jack Goldberger'
Cc:
Subject: Jeffrey Epstein Agreement
Dear Roy and Jack:
I am just writing to re-state that it is the Government's position that we have a signed, binding agreement and
that there is no need for further modification.
EFTA00013924

=== Page 3 ===
Please keep us informed of the date and time of the change of plea and sentencing.
Thank you.
Assistant U.S. Attorney
-
Phone
Fax
EFTA00013925


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=== Page 1 ===
United States V. Ghislaine Maxwell
20 Cr. 330 (AJN)
3500 Material
11/11/2021
3502
Date
Description
Attorney
Produced to Defense
3502-001
2021.02.01
Notes from phone call
2021.04.23
3502-002
2021.02.01
Testimony disclosure
2021.04.23
3502-003
2021.03.03
Notes from phone call
2021.04.23
3502-004
2021.04.09
Interview notes
2021.04.23
3502-005
2021.04.21
Interview notes
2021.04.23
3502-006
Resume
2021.04.23
3502-007
Contract for services
2021.04.23
3502-008
2021.10.21
Notes
2021.10.25
3502-009
2021.10.24
Notes
2021.10.25
3502-010
2006
Article
2021.10.25
3502-011
2009
Article
2021.10.25
3502-012
2010
Article
2021.10.25
3502-013
2014
Article
2021.10.25
3502-014
2015
Article
2021.10.25
3502-015
2015
Article
2021.10.25
3502-016
2015
Article
2021.10.25
3502-017
2016
Article
2021.10.25
3502-018
2017
Article
2021.10.25
3502-019
2018
Article
2021.10.25
3502-020
2018
Article
2021.10.25
3502-021
2019
Article
2021.10.25
3502-022
2020
Article
2021.10.25
3502-023
2021
Article
2021.10.25
3502-024
2021
Article
2021.10.25
3502-025
2021.10.25
Notes
2021.10.25
3502-026
2020
Article
2021.11.06
3502-027
2020
Article
2021.11.06
3502-028
2021.10.29
Notes
2021.11.06
3502-029
2021.10.31
Notes
2021.11.06
3502-030
2021.11.01
Notes
2021.11.06
3502-031
2021.11.02
Notes
2021.11.06
3502-032
2009
Article
2021.11.06
3502-033
2020
Article
2021.11.06
3502-034
2021
Article
2021.11.06
3502-035
2021.11.03
Notes
2021.11.06
3502-036
2021.11.04
Notes
2021.11.06
3502-037
2021.11.07
Notes
2021.11.09
3502-038
2021.11.08
Notes
2021.11.09
3502-039
2021.11.09
Notes
2021.11.09
3503
Date
Description
Attorney
Produced to Defense
3503-001
Curriculum vitae
2021.09.15
3503-002
31E-NY-3027571
2021.10.11
3503-003
2021.08.25
Notes
2021.10.11
3503-004
2019.08.09
Email
2021.10.11
3503-005
2019.08.20
Email
2021.10.11
3503-006
2019.08.23
Email
2021.10.11
3503-007
2019.09.04
Email
2021.10.11
3503-008
2019.09.09
Email
2021.10.11
3503-009
2019.09.16
Email
2021.10.11
3503-010
2019.09.30
Email
2021.10.11
3503-011
2019.10.21
Email
2021.10.11
3503-012
2019.11.12
Email
2021.10.11
3503-013
2020.02.10
Email
2021.10.11
3503-014
2020.03.02
Email
2021.10.11
3503-015
2020.03.03
Email
2021.10.11
3503-016
2020.03.04
Email
2021.10.11
3503-017
Attachment to email
2021.10.11
3503-018
2020.03.18
Email
2021.10.11
3503-019
2020.03.31
Email
2021.10.11
3503-020
2020.04.07
Email
2021.10.11
3503-021
2020.05.12
Email
2021.10.11
3503-022
2020.05.14
Email
2021.10.11
3503-023
Attachment to email
2021.10.11
3503-024
2020.05.29
Email
2021.10.11
3503-025
Attachment to email
2021.10.11
3503-026
2020.06.17
Email
2021.10.11
3503-027
2020.06.17
Email
2021.10.11
3503-028
2020.06.19
Email
2021.10.11
3503-029
2020.06.19
Email
2021.10.11
3503-030
2020.06.20
Email
2021.10.11
3503-031
2020.06.23
Email
2021.10.11
3503-032
Attachment to email
2021.10.11
3503-033
2020.07.07
Email
2021.10.11
3503-034
2020.07.07
Email
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
1
EFTA00010025

=== Page 2 ===
3503-035
2020.07.13
Email
2021.10.11
3503-036
Attachment to email
2021.10.11
3503-037
2020.07.13
Email
2021.10.11
3503-038
Attachment to email
2021.10.11
3503-039
2020.07.13
Email
2021.10.11
3503-040
Attachment to email
2021.10.11
3503-041
2020.07.13
Email
2021.10.11
3503-042
2020.07.14
Email
2021.10.11
3503-043
2020.07.14
Email
2021.10.11
3503-044
2020.07.14
Email
2021.10.11
3503-045
2020.07.15
Email
2021.10.11
3503-046
2020.07.15
Email
2021.10.11
3503-047
2020.07.20
Email
2021.10.11
3503-048
Attachment to email
2021.10.11
3503-049
2020.07.20
Email
2021.10.11
3503-050
2020.07.21
Email
2021.10.11
3503-051
2020.07.22
Email
2021.10.11
3503-052
2020.07.23
Email
2021.10.11
3503-053
Attachment to email
2021.10.11
3503-054
2020.07.23
Email
2021.10.11
3503-055
Attachment to email
2021.10.11
3503-056
2020.07.24
Email
2021.10.11
3503-057
Attachment to email
2021.10.11
3503-058
2020.07.24
Email
2021.10.11
3503-059
2020.07.26
Email
2021.10.11
3503-060
2020.07.27
Email
2021.10.11
3503-061
2020.07.27
Email
2021.10.11
3503-062
2020.07.27
Email
2021.10.11
3503-063
2020.07.28
Email
2021.10.11
3503-064
2020.07.28
Email
2021.10.11
3503-065
2020.08.03
Email
2021.10.11
3503-066
2020.08.04
Email
2021.10.11
3503-067
Attachment to email
2021.10.11
3503-068
2020.08.04
Email
2021.10.11
3503-069
2020.08.19
Email
2021.10.11
3503-070
2020.10.02
Email
2021.10.11
3503-071
Attachment to email
2021.10.11
3503-072
Attachment to email
2021.10.11
3503-073
2020.10.05
Email
2021.10.11
3503-074
2020.10.08
Email
2021.10.11
3503-075
2020.10.08
Email
2021.10.11
3503-076
2020.10.09
Email
2021.10.11
3503-077
2020.10.09
Email
2021.10.11
3503-078
2020.10.12
Email
2021.10.11
3503-079
2020.10.13
Email
2021.10.11
3503-080
2020.10.14
Email
2021.10.11
3503-081
2020.10.15
Email
2021.10.11
3503-082
2020.10.15
Email
2021.10.11
3503-083
2020.10.16
Email
2021.10.11
3503-084
2020.10.16
Email
2021.10.11
3503-085
2020.10.19
Email
2021.10.11
3503-086
2020.10.19
Email
2021.10.11
3503-087
2020.10.20
Email
2021.10.11
3503-088
2020.10.21
Email
2021.10.11
3503-089
2020.10.21
Email
2021.10.11
3503-090
2020.10.23
Email
2021.10.11
3503-091
2020.10.26
Email
2021.10.11
3503-092
Attachment to email
2021.10.11
3503-093
2020.10.26
Email
2021.10.11
3503-094
Attachment to email
2021.10.11
3503-095
2020.10.26
Email
2021.10.11
3503-096
Attachment to email
2021.10.11
3503-097
2020.10.26
Email
2021.10.11
3503-098
Attachment to email
2021.10.11
3503-099
Attachment to email
2021.10.11
3503-100
Attachment to email
2021.10.11
3503-101
Attachment to email
2021.10.11
3503-102
2020.10.26
Email
2021.10.11
3503-103
Attachment to email
2021.10.11
3503-104
Attachment to email
2021.10.11
3503-105
2020.10.27
Email
2021.10.11
3503-106
2020.10.27
Email
2021.10.11
3503-107
2020.10.29
Email
2021.10.11
3503-108
2021.04.30
Email
2021.10.11
3504
Date
Description
Attorney
Produced to Defense
3504-001
2003.10.05
Palm Beach Police Report
2021.10.11
3504-002
2003.10.05
Palm Beach Police Report
2021.10.11
3504-003
2005.11.09
Palm Beach Police Report
2021.10.11
3504-004
2005.11.10
Palm Beach Police Report
2021.10.11
3504-005
2005.11.10
PBPD recording
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
2
EFTA00010026

=== Page 3 ===
3504-006
2005.11.10
Letter
2021.10.11
3504-007
2005.11.17
Driver information
2021.10.11
3504-008
2005.11.21
Palm Beach Police Report
2021.10.11
3504-009
2005.11.21
sworn statement
2021.10.11
3504-010
2005.11.21
sworn statement
2021.10.11
3504-011
2005.11.21
sworn statement
2021.10.11
3504-012
2006.05.01
Palm Beach Police Report
2021.10.11
3504-013
2006.05.01
Palm Beach Police Report
2021.10.11
3504-014
2006.05.01
Palm Beach Police Report
2021.10.11
3504-015
2006.08.26
Palm Beach Police Report
2021.10.11
3504-016
2006.10.20
Memorandum
2021.10.11
3504-017
2006.12.04
Driver information
2021.10.11
3504-018
2006.12.04
Criminal history check
2021.10.11
3504-019
2007.02.01
Letter
2021.10.11
3504-020
2007.12.11
Letter
2021.10.11
3504-021
2009.09.08
Deposition, Volume I
2021.10.11
3504-022
2009.09.08
Deposition, Volume II
2021.10.11
3504-023
2016.06.01
Deposition Exhibit 1
2021.10.11
3504-024
2016.06.01
Deposition Exhibit 2
2021.10.11
3504-025
2016.06.01
Deposition Exhibit 3
2021.10.11
3504-026
2016.06.01
Deposition Exhibit 4
2021.10.11
3504-027
2016.06.01
Deposition Exhibit 5
2021.10.11
3504-028
2016.06.01
Deposition Exhibit 6
2021.10.11
3504-029
2016.06.01
Deposition Exhibit 7
2021.10.11
3504-030
2016.06.01
Deposition transcript
2021.10.11
3504-031
2016.09.15
Sworn Affidavit
2021.10.11
3504-032
2019.07.13
Interview 302
2021.10.11
3504-033
2019.07.13
Notes
2021.10.11
3504-034
2020.02.19
Interview 302
2021.10.11
3504-035
2020.02.19
Notes
2021.10.11
3504-036
2020.06.28
Grand jury transcript
2021.10.11
3504-037
2020.09.28
Notes
2021.10.11
3504-038
2021.03.29
Grand jury transcript
2021.10.11
3504-039
2021.06.08
Notes
2021.10.11
3504-040
2021.06.24
Notes
2021.10.11
3504-041
2021.07.14
Notes
2021.10.11
3504-042
Criminal history check
2021.10.11
3504-043
Criminal history check
2021.10.11
3504-044
2021.11.11
Notes
2021.11.11
3505
Date
Description
Attorney
Produced to Defense
3505-001
2006.12.14
Driver information
2021.10.11
3505-002
2007.05.08
Transcript
2021.10.11
3505-003
2007.06.07
Letter
2021.10.11
3505-004
2007.07.03
Driver information
2021.10.11
3505-005
2007.08.07
Interview 302
2021.10.11
3505-006
2007.08.07
Notes
2021.10.11
3505-007
2007.08.07
Property receipt
2021.10.11
3505-008
2007.08.28
Declaration
2021.10.11
3505-009
2007.09.07
Driver information
2021.10.11
3505-010
2007.09.07
Criminal history check
2021.10.11
3505-011
2007.09.07
Driver information
2021.10.11
3505-012
2007.09.07
Criminal history check
2021.10.11
3505-013
2007.09.07
Criminal history check
2021.10.11
3505-014
2007.09.07
Search records
2021.10.11
3505-015
2007.09.07
Criminal history check
2021.10.11
3505-016
2007.09.07
Criminal history check
2021.10.11
3505-017
2008.01.10
Letter
2021.10.11
3505-018
2008.03.18
Transcript
2021.10.11
3505-019
2008.06.19
Starr submission to DAG
2021.10.11
3505-020
2008.06.30
Letter
2021.10.11
3505-021
2008.07.10
Letter
2021.10.11
3505-022
2008.07.10
Letter
2021.10.11
3505-023
2008.09.02
Letter
2021.10.11
3505-024
2008.12.05
Letter
2021.10.11
3505-025
2009.02.09
Complaint
2021.10.11
3505-026
2009.02.13
Plaintiff response
2021.10.11
3505-027
2009.03.23
Plaintiff notice
2021.10.11
3505-028
2009.06.17
Letter
2021.10.11
3505-029
2009.06.17
Letter
2021.10.11
3505-030
2009.08.13
Transcript
2021.10.11
3505-031
2009.08.31
Transcript
2021.10.11
3505-032
2009.08.31
Summary report
2021.10.11
3505-033
2009.09.10
Medical records
2021.10.11
3505-034
2009.10.20
Questionaire
2021.10.11
3505-035
2009.10.21
Transcript
2021.10.11
3505-036
2009.10.21
Medical examination
2021.10.11
3505-037
2009.10.24
Notes
2021.10.11
3505-038
2009.11.06
Plaintiff's Notice
2021.10.11
3505-039
2009.11.09
Medical records
2021.10.11
3505-040
2009.11.13
Medical report
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
3
EFTA00010027

=== Page 4 ===
3505-041
2009.12.02
Plaintiff's Notice
2021.10.11
3505-042
2009.12.03
Response
2021.10.11
3505-043
2009.12.04
Deposition
2021.10.11
3505-044
2009.12.04
Deposition
2021.10.11
3505-045
2009.12.04
Deposition Exhibit
2021.10.11
3505-046
2009.12.04
Deposition Exhibit
2021.10.11
3505-047
2009.12.04
Deposition Exhibit
2021.10.11
3505-048
2009.12.09
Notes
2021.10.11
3505-049
2009.12.18
Settlement Resolution Notice
2021.10.11
3505-050
2010.10.14
Arrest report
2021.10.11
3505-051
2011.03.12
FBI Report
2021.10.11
3505-052
2011.03.12
FBI Report
2021.10.11
3505-053
2011.04.20
Arrest report
2021.10.11
3505-054
2011.11.16
Arrest report
2021.10.11
3505-055
2012.02.28
Arrest report
2021.10.11
3505-056
2012.09.30
Arrest report
2021.10.11
3505-057
2013.03.07
Arrest report
2021.10.11
3505-058
2014.02.26
Transcript
2021.10.11
3505-059
2019.03.19
Interview 302
2021.10.11
3505-060
2019.03.19
Notes
2021.10.11
3505-061
2019.07.23
Email
2021.10.11
3505-062
2019.08.07
Email
2021.10.11
3505-063
2019.08.23
Email
2021.10.11
3505-064
2020.02.25
Email
2021.10.11
3505-065
2020.03.10
Email
2021.10.11
3505-066
2020.07.07
Email
2021.10.11
3505-067
2020.07.16
Email
2021.10.11
3505-068
2020.07.17
Interview 302
2021.10.11
3505-069
2020.07.17
Notes
2021.10.11
3505-070
2020.07.17
Email
2021.10.11
3505-071
Attachment to email
2021.10.11
3505-072
Attachment to email
2021.10.11
3505-073
2020.08.11
Notes
2021.10.11
3505-074
2020.08.11
Interview 302
2021.10.11
3505-075
2020.08.11
Notes
2021.10.11
3505-076
2021.01.19
Interview 302
2021.10.11
3505-077
2021.01.19
Notes
2021.10.11
3505-078
2021.01.20
Criminal history check
2021.10.11
3505-079
2021.01.20
Interview 302
2021.10.11
3505-080
2021.01.20
Notes
2021.10.11
3505-081
2021.01.21
Interview 302
2021.10.11
3505-082
2021.01.21
Notes
2021.10.11
3505-083
2021.01.21
Exhibit to notes
2021.10.11
3505-084
2021.01.28
Email
2021.10.11
3505-085
2021.03.29
Grand Jury presentation
2021.10.11
3505-086
2021.03.29
Transcript
2021.10.11
3505-087
2021.04.18
Email
2021.10.11
3505-088
2021.06.07
Notes
2021.10.11
3505-089
2021.06.09
Notes
2021.10.11
3505-090
2021.06.23
Notes
2021.10.11
3505-091
2021.06.24
Notes
2021.10.11
3505-092
2021.07.13
Notes
2021.10.11
3505-093
2021.08.16
Notes
2021.10.11
3505-094
2021.08.19
Email
2021.10.11
3505-095
2021.08.19
Text message
2021.10.11
3505-096
2021.08.19
Text message
2021.10.11
3505-097
2021.08.26
Notes
2021.10.11
3505-098
Notes
2021.10.11
3505-099
Notes
2021.10.11
3505-100
Answers to Interrogatories
2021.10.11
3505-101
Criminal history check
2021.10.11
3505-102
Criminal history check
2021.10.11
3505-103
Plaintiff's Response
2021.10.11
3505-104
Plaintiff's Notice
2021.10.11
3505-105
Photographs
2021.10.11
3505-106
Answers to Interrogatories
2021.10.11
3505-107
Criminal history check
2021.10.11
3505-108
2021.10.27
Notes
2021.11.06
3505-109
2021.10.15
Voicemail
2021.11.06
3506
Date
Description
Attorney
Produced to Defense
3505-001
2009.11.06
Deposition transcript
2021.10.11
3505-002
2021.06.23
Interview 302
2021.10.11
3505-003
2021.06.23
Exhibit to notes
2021.10.11
3505-004
2021.06.23
Notes
2021.10.11
3505-005
2021.07.13
Notes
2021.10.11
3505-006
2021.07.15
Notes
2021.10.11
3505-007
2021.08.24
Text messages
2021.10.11
3505-008
2021.08.24
Text messages
2021.10.11
3505-009
2021.08.27
Notes
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
4
EFTA00010028

=== Page 5 ===
3505-010
Criminal history check
2021.10.11
3505-011
Criminal history check
2021.10.11
3505-012
Criminal history check
2021.10.11
3505-013
Criminal history check
2021.10.11
3505-014
Text messages
2021.10.11
3507
Date
Description
Attorney
Produced to Defense
3507-001
2006.01.11
Memorandum
2021.10.11
3507-002
2006.07.13
Palm Beach Police Report
2021.10.11
3507-003
2006.12.04
Criminal history check
2021.10.11
3507-004
2007.01.11
Interview 302
2021.10.11
3507-005
2007.01.19
Memorandum
2021.10.11
3507-006
2007.02.02
Interview 302
2021.10.11
3507-007
2007.02.02
Notes
2021.10.11
3507-008
2007.02.02
Exhibit to notes
2021.10.11
3507-009
2007.05.22
Transcript
2021.10.11
3507-010
2007.07.30
Declaration
2021.10.11
3507-011
2010.02.16
Transcript
2021.10.11
3507-012
2021.09.27
Interview 302
2021.10.11
3507-013
2021.09.27
Notes
2021.10.11
3507-014
Criminal history check
2021.10.11
3507-015
Criminal history check
2021.10.11
3507-016
Notes
2021.11.06
3507-017
2021.10.19
Interview 302
2021.11.11
3508
Date
Description
Attorney
Produced to Defense
3508-001
2021.09.02
Interview 302
2021.10.11
3508-002
2021.09.02
Notes
2021.10.11
3508-003
2021.10.18
Notes
2021.10.25
3509
Date
Description
Attorney
Produced to Defense
3509-001
2019.09.19
Interview 302
2021.10.11
3509-002
2019.09.19
Notes
2021.10.11
3509-003
2019.11.14
Interview 302
2021.10.11
3509-004
2019.11.14
Notes
2021.10.11
3509-005
2019.12.17
Interview 302
2021.10.11
3509-006
2019.12.17
Notes
2021.10.11
3509-007
2020.01.17
Complaint
2021.10.11
3509-008
2020.02.27
Interview 302
2021.10.11
3509-009
2020.02.27
Notes
2021.10.11
3509-010
2020.03.20
Email
2021.10.11
3509-011
2020.04.03
Notes
2021.10.11
3509-012
2020.06.03
Email
2021.10.11
3509-013
2020.06.08
Email
2021.10.11
3509-014
2020.06.08
Email
2021.10.11
3509-015
2020.06.26
Email
2021.10.11
3509-016
2020.06.28
Transcript
2021.10.11
3509-017
2020.07.12
Email
2021.10.11
3509-018
2020.08.03
Email
2021.10.11
3509-019
2020.08.03
Email
2021.10.11
3509-020
2021.03.23
Interview 302
2021.10.11
3509-021
2021.03.23
Notes
2021.10.11
3509-022
2021.08.17
Notes
2021.10.11
3509-023
2021.09.02
Interview 302
2021.10.11
3509-024
2021.09.02
Notes
2021.10.11
3509-025
2021.09.14
Notes
2021.10.11
3509-026
2021.10.21
Notes
2021.10.11
3509-027
Text messages
2021.10.11
3509-028
2021.10.13
Notes
2021.10.25
3509-029
2021.10.14
Notes
2021.10.25
3509-030
2021.08.18
Email
2021.11.06
3509-031
2021.10.27
Documentation of services
2021.11.06
3509-032
2021.11.01
Notes
2021.11.06
3509-033
2021.11.03
Notes
2021.11.06
3509-034
Notes
2021.11.06
3509-035
Notes
2021.11.06
3510
Date
Description
Attorney
Produced to Defense
3510-001
2020.01.14
Interview 302
2021.10.11
3510-002
2020.01.14
Notes
2021.10.11
3510-003
2020.06.28
Grand jury transcript
2021.10.11
3510-004
2021.05.03
Notes
2021.10.11
3510-005
2021.08.30
Interview 302
2021.10.11
3510-006
2021.08.30
Notes
2021.10.11
3510-007
2021.08.31
Interview 302
2021.10.11
3510-008
2021.08.31
Notes
2021.10.11
3510-009
2021.09.01
Text messages
2021.10.11
3510-010
Text messages
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
5
EFTA00010029

=== Page 6 ===
3510-011
Text messages
2021.10.11
3510-012
2021.11.02
Notes
2021.11.11
3510-013
2021.11.02
302
2021.11.11
3511
Date
Description
Attorney
Produced to Defense
3511-001
2021.07.30
Email
2021.10.11
3511-002
2021.08.05
Email
2021.10.11
3511-003
Attachment to email
2021.10.11
3512
Date
Description
Attorney
Produced to Defense
3512-001
2003.10.15
Palm Beach Police Report
2021.10.11
3512-002
Palm Beach Police Report
2021.10.11
3512-003
Palm Beach Police Report
2021.10.11
3512-004
2021.05.19
Notes
2021.10.11
3512-005
2021.06.08
Notes
2021.10.11
3512-006
2021.07.13
Notes
2021.10.11
3512-007
2021.11.09
Notes
2021.11.11
3513
Date
Description
Attorney
Produced to Defense
3513-001
1995.11.07
Letter
2021.10.11
3513-002
2019.08.27
Interview 302
2021.10.11
3513-003
2019.08.27
Notes
2021.10.11
3513-004
2019.08.27
Transcript
2021.10.11
3513-005
2019.09.19
Interview 302
2021.10.11
3513-006
2019.09.19
Notes
2021.10.11
3513-007
2019.09.20
Email
2021.10.11
3513-008
2019.10.03
FBI Report
2021.10.11
3513-009
2019.12.15
Interview 302
2021.10.11
3513-010
2019.12.15
Notes
2021.10.11
3513-011
2019.12.15
Exhibit to Notes
2021.10.11
3513-012
2019.12.15
Exhibit to Notes
2021.10.11
3513-013
2019.12.15
Exhibit to Notes
2021.10.11
3513-014
2019.12.15
Exhibit to Notes
2021.10.11
3513-015
2019.12.15
Exhibit to Notes
2021.10.11
3513-016
2019.12.15
Exhibit to Notes
2021.10.11
3513-017
2019.12.15
Exhibit to Notes
2021.10.11
3513-018
2019.12.15
Exhibit to Notes
2021.10.11
3513-019
2019.12.15
Exhibit to Notes
2021.10.11
3513-020
2019.12.15
Exhibit to Notes
2021.10.11
3513-021
2019.12.15
Exhibit to Notes
2021.10.11
3513-022
2019.12.27
Email
2021.10.11
3513-023
2019.12.28
Email
2021.10.11
3513-024
2020.06.28
Transcript
2021.10.11
3513-025
2020.07.13
Letter
2021.10.11
3513-026
2020.07.14
Email
2021.10.11
3513-027
2020.07.14
Transcript
2021.10.11
3513-028
2020.12.15
Email
2021.10.11
3513-029
2021.03.29
Transcript
2021.10.11
3513-030
2021.06.30
Criminal history report
2021.10.11
3513-031
2021.07.27
Interview 302
2021.10.11
3513-032
2021.07.27
Notes
2021.10.11
3513-033
2021.07.28
Notes
2021.10.11
3513-034
2021.07.29
Notes
2021.10.11
3513-035
2021.08.24
Notes
2021.10.11
3513-036
2021.08.24
Email
2021.10.11
3513-037
2021.09.01
Interview 302
2021.10.11
3513-038
2021.09.01
Notes
2021.10.11
3513-039
2021.09.01
Exhibit to Notes
2021.10.11
3513-040
2021.09.02
Notes
2021.10.11
3513-041
2021.09.02
Interview 302
2021.10.11
3513-042
2021.09.02
Exhibit to Notes
2021.10.11
3513-043
2021.09.02
Exhibit to Notes
2021.10.11
3513-044
2021.09.02
Exhibit to Notes
2021.10.11
3513-045
2021.09.03
Notes
2021.10.11
3513-046
2021.10.06
Criminal history report
2021.10.11
3513-047
NYS ovs Application
2021.10.11
3513-048
NYS ovs Application
2021.10.11
3513-049
NYS ovs Application
2021.10.11
3513-050
Text messages
2021.10.11
3513-051
Text messages
2021.10.11
3513-052
Text messages
2021.10.11
3513-053
2019.09.05
Email
2021.10.25
3513-054
Attachment to email
2021.10.25
3513-055
2019.10.03
Email
2021.10.25
3513-056
2019.10.03
Email
2021.10.25
3513-057
2019.10.04
Email
2021.10.25
3513-058
2019.10.15
Email
2021.10.25
3513-059
2021.10.24
Notes
2021.10.25
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
6
EFTA00010030

=== Page 7 ===
3513-060
2021.10.27
Documentation of services
2021.11.06
3514
Date
Description
Attorney
Produced to Defense
3514-001
2006.11.15
Interview 302
2021.10.11
3514-002
2006.11.15
Notes
2021.10.11
3514-003
2007.07.30
Declaration
2021.10.11
3514-004
2019.07.15
Transcript
2021.10.11
3514-005
2019.08.27
Transcript
2021.10.11
3514-006
2019.09.28
Interview 302
2021.10.11
3514-007
2019.09.28
Notes
2021.10.11
3514-008
2019.09.29
Email
2021.10.11
3514-009
2019.09.29
Email
2021.10.11
3514-010
2019.10.28
Email
2021.10.11
3514-011
2019.11.12
Complaint
2021.10.11
3514-012
2020.05.09
Notes
2021.10.11
3514-013
2020.06.28
Transcript
2021.10.11
3514-014
2020.07.14
Transcript
2021.10.11
3514-015
2020.12.15
Email
2021.10.11
3514-016
2020.12.15
Letter
2021.10.11
3514-017
2021.03.29
Transcript
2021.10.11
3514-018
2021.05.11
FBI Report
2021.10.11
3514-019
2021.06.29
FBI Report
2021.10.11
3514-020
2021.06.29
FBI Report
2021.10.11
3514-021
2021.06.30
Criminal history report
2021.10.11
3514-022
2021.06.30
Criminal history report
2021.10.11
3514-023
2021.07.26
Interview 302
2021.10.11
3514-024
2021.07.26
Notes
2021.10.11
3514-025
2021.07.29
Notes
2021.10.11
3514-026
2021.09.17
Interview 302
2021.10.11
3514-027
2021.09.17
Notes
2021.10.11
3514-028
2021.09.17
Exhibit to notes
2021.10.11
3514-029
2021.09.17
Exhibit to notes
2021.10.11
3514-030
2021.09.18
Notes
2021.10.11
3514-031
Photographs
2021.10.11
3514-032
Photographs
2021.10.11
3514-033
Photographs
2021.10.11
3514-034
Photographs
2021.10.11
3514-035
Photographs
2021.10.11
3514-036
Photographs
2021.10.11
3514-037
Photographs
2021.10.11
3514-038
Photographs
2021.10.11
3514-039
Photographs
2021.10.11
3514-040
2019.10.15
Email
2021.10.11
3514-041
Photograph
2021.10.11
3514-042
2008.03.17
Search Warrant
2021.10.11
3514-043
2008.03.17
Search Warrant
2021.10.11
3514-044
2021.11.05
Notes
2021.11.11
3515
Date
Description
Attorney
Produced to Defense
3515-001
2020.08.24
Interview 302
2021.10.11
3515-002
2020.08.24
Notes
2021.10.11
3515-003
2021.05.06
Notes
2021.10.11
3515-004
Text messages
2021.10.11
3515-005
Text messages
2021.10.11
3515-006
Text messages
2021.10.11
3515-007
2021.11.03
Notes
2021.11.06
3516
Date
Description
Attorney
Produced to Defense
3516-001
2020.12.18
Interview 302
2021.10.11
3516-002
2021.01.13
Interview 302
2021.10.11
3516-003
2021.01.13
Notes
2021.10.11
3516-004
2021.03.29
Transcript
2021.10.11
3516-005
2021.06.07
Notes
2021.10.11
3516-006
2021.06.22
Notes
2021.10.11
3516-007
2021.07.12
Notes
2021.10.11
3516-008
2021.07.16
Email
2021.10.11
3516-009
2021.07.16
Email
2021.10.11
3516-010
Criminal history report
2021.10.11
3516-011
Criminal history report
2021.10.11
3516-012
Criminal history report
2021.10.11
3516-013
Criminal history report
2021.10.11
3516-014
Search records
2021.10.11
3516-015
Criminal history report
2021.10.11
3517
Date
Description
Attorney
Produced to Defense
3517-001
2006.08.17
Criminal history report
2021.10.11
3517-002
2006.08.17
Interview 302
2021.10.11
3517-003
2006.08.17
Exhibit to 302
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
7
EFTA00010031

=== Page 8 ===
3517-004
2021.06.30
Interview 302
2021.10.11
3517-005
2021.06.30
Notes
2021.10.11
3517-006
2021.06.30
Exhibit to notes
2021.10.11
3517-007
2021.07.14
Notes
2021.10.11
3517-008
Text messages
2021.10.11
3517-009
Notes
2021.10.11
3517-010
2021.11.03
Notes
2021.11.06
3518
Date
Description
Attorney
Produced to Defense
3518-001
2019.09.16
Notes
2021.10.11
3518-002
2021.09.24
Notes
2021.10.11
3518-003
2021.09.27
Notes
2021.10.11
3518-004
2021.09.27
Email
2021.10.11
3518-005
Attachment to Email
2021.10.11
3518-006
Attachment to Email
2021.10.11
3518-007
Attachment to Email
2021.10.11
3518-008
Attachment to Email
2021.10.11
3518-009
Attachment to Email
2021.10.11
3518-010
Voicemail
2021.10.11
3518-011
Voicemail
2021.10.11
3519
Date
Description
Attorney
Produced to Defense
3519-001
2021.04.26
Notes
2021.10.11
3519-002
Criminal history check
2021.10.11
3520
Date
Description
Attorney
Produced to Defense
3520-001
2019.07.06
FBI 302
2021.10.11
3520-002
2019.07.06
Text message
2021.10.11
3520-003
2019.07.06
Text message
2021.10.11
3520-004
2019.07.06
Text message
2021.10.11
3520-005
2019.07.11
FBI 302
2021.10.11
3520-006
2019.07.11
FBI 302
2021.10.11
3520-007
2019.07.12
FBI 302
2021.10.11
3520-008
2019.07.15
Email
2021.10.11
3520-009
2019.07.15
Email
2021.10.11
3520-010
2019.07.31
FBI 302
2021.10.11
3520-011
2019.08.02
FBI 302
2021.10.11
3520-012
2019.08.02
Email
2021.10.11
3520-013
2019.08.13
Notes and email
2021.10.11
3520-014
2019.09.17
Email
2021.10.11
3520-015
2020.05.22
Email
2021.10.11
3520-016
2021.04.29
Notes
2021.10.11
3520-017
2021.06.10
Email
2021.10.11
3520-018
Notes
2021.10.11
3520-019
2021.11.02
Notes
2021.11.06
3521
Date
Description
Attorney
Produced to Defense
3521-001
2021.01.29
FBI 302
2021.10.11
3521-002
2021.01.29
Notes
2021.10.11
3521-003
2021.11.02
Notes
2021.11.06
3521-004
2021.11.02
Notes
2021.11.06
3522
Date
Description
Attorney
Produced to Defense
3522-001
2003.10.05
Palm Beach Police Department report
2021.10.11
3522-002
2005.09.23
Palm Beach Police Department report
2021.10.11
3522-003
2005.11.07
Palm Beach Police Department report
2021.10.11
3522-004
2006.09.29
Grand Jury records
2021.10.11
3522-005
2021.05.09
Email
2021.10.11
3522-006
2021.05.20
Notes
2021.10.11
3522-007
2021.06.08
Notes
2021.10.11
3522-008
2021.07.15
Notes
2021.10.11
3522-009
Voicemail
2021.10.11
3522-010
2021.11.08
Notes
2021.11.11
3523
Date
Description
Attorney
Produced to Defense
3523-001
2006.01.27
T-Mobile records
2021.10.11
3523-002
2006.01.30
Driver information
2021.10.11
3523-003
2006.02.13
Palm Beach Police Department report
2021.10.11
3523-004
2006.08.15
FBI 302
2021.10.11
3523-005
2006.08.15
Notes
2021.10.11
3523-006
2016.06.03
Deposition transcript
2021.10.11
3523-007
2016.06.03
Deposition exhibit
2021.10.11
3523-008
2016.06.03
Deposition exhibit
2021.10.11
3523-009
2016.06.03
Deposition exhibit
2021.10.11
3523-010
2016.06.03
Deposition exhibit
2021.10.11
3523-011
2016.06.03
Deposition exhibit
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
8
EFTA00010032

=== Page 9 ===
3523-012
2016.06.03
Deposition exhibit
2021.10.11
3523-013
2016.06.03
Deposition exhibit
2021.10.11
3523-014
2016.06.03
Deposition exhibit
2021.10.11
3523-015
2016.06.03
Deposition exhibit
2021.10.11
3523-016
2019.07.06
FBI 302
2021.10.11
3523-017
2020.02.07
Proffer agreement
2021.10.11
3523-018
2020.02.07
FBI 302
2021.10.11
3523-019
2020.02.07
Notes
2021.10.11
3523-020
2020.06.28
Grand jury transcript
2021.10.11
3523-021
2020.07.17
Declaration
2021.10.11
3523-022
2021.03.29
Grand jury transcript
2021.10.11
3523-023
2021.07.30
Notes
2021.10.11
3523-024
2021.08.17
Notes
2021.10.11
3523-025
2021.08.18
Notes
2021.10.11
3523-026
Flight logs
2021.10.11
3523-027
Flight logs
2021.10.11
3523-028
Notes
2021.10.11
3523-029
Notes
2021.10.11
3524
Date
Description
Attorney
Produced to Defense
3524-001
2006.08.01
Records search
2021.10.11
3524-002
2006.12.04
Records search
2021.10.11
3524-003
2007.01.23
W2
2021.10.11
3524-004
2007.02.14
Letter
2021.10.11
3524-005
2007.05.23
Employment records
2021.10.11
3524-006
2010.03.15
Deposition transcript
2021.10.11
3524-007
2019.07.06
FBI 302
2021.10.11
3524-008
2019.07.09
Notes
2021.10.11
3524-009
2019.07.12
FBI 302
2021.10.11
3524-010
2019.07.12
Notes
2021.10.11
3524-011
2019.09.10
FBI 302
2021.10.11
3524-012
2019.09.10
Notes
2021.10.11
3524-013
2021.05.14
FBI 302
2021.10.11
3524-014
2021.05.14
Notes
2021.10.11
3524-015
2021.05.14
Proffer agreement
2021.10.11
3524-016
2021.08.20
FBI 302
2021.10.11
3524-017
2021.08.20
Notes
2021.10.11
3524-018
2021.09.30
Notes
2021.10.11
3524-019
2021.10.01
Proffer agreement
2021.10.11
3524-020
2021.10.01
Notes
2021.10.11
3524-021
Criminal history check
2021.10.11
3524-022
Criminal history check
2021.10.11
3524-023
2007.08.31
Letter
2021.10.11
3524-024
2021.10.27
Notes
2021.11.06
3524-025
2021.11.05
Proffer agreement
2021.11.11
3524-026
2021.11.05
Notes
2021.11.11
3525
Date
Description
Attorney
Produced to Defense
3525-001
2021.09.21
Notes
2021.10.11
3525-002
2021.09.21
Email
2021.10.11
3525-003
2021.09.21
Voicemail
2021.10.11
3526
Date
Description
Attorney
Produced to Defense
3526-001
2021.09.22
Notes
2021.10.11
3526-002
2021.09.22
Notes
2021.10.11
3527
Date
Description
Attorney
Produced to Defense
3527-001
2006.11.27
FBI 302
2021.10.11
3527-002
2006.11.27
W2
2021.10.11
3527-003
2009.10.15
Deposition transcript
2021.10.11
3527-004
2019.07.09
FBI 302
2021.10.11
3527-005
2020.10.07
FBI 302
2021.10.11
3527-006
2020.10.07
Notes
2021.10.11
3527-007
2020.10.07
Exhibit for proffer
2021.10.11
3527-008
2020.10.07
Proffer agreement
2021.10.11
3527-009
2020.11.12
FBI 302
2021.10.11
3527-010
2020.11.12
Notes
2021.10.11
3527-011
2020.11.12
Proffer agreement
2021.10.11
3527-012
2021.08.04
Notes
2021.10.11
3527-013
2021.08.16
Notes
2021.10.11
3527-014
2020.08.17
Notes
2021.10.11
3527-015
Various notes
2021.10.11
3527-016
2021.11.09
Notes
2021.11.11
3528
Date
Description
Attorney
Produced to Defense
3528-001
2021.11.01
Notes
2021.11.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
9
EFTA00010033


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=== Page 1 ===
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
On Oct 12, 2021, at 10:02 PM,
wrote:
Good evening,
The Government filed the letter on ECF this evening. In what format would the Court like a copy of the materials?
Respectfully,
From: Nathan NYSD Chambers
Sent: Tuesday, October 12, 2021 5:32 PM
To:
Cc:
Subject: Re: US V. Maxwell, 20 Cr. 330 (AJN) - Joint Proposed Juror Questionnaire and Voir Dire
Counsel:
Consistent with the Court's Individual Rules, if one or both sides are requesting sealing, the letter making that
request must be docketed on ECF unless counsel is also seeking, with explanation and justification, to file the
letter under seal.
The Court would also like a copy of the Jencks Act material and exhibits.
Sincerely,
EFTA00011113

=== Page 2 ===
Chambers of the Hon. Alison J. Nathan
From:
Sent: Monday, October 11, 2021 7:53 PM
To: Nathan NYSD Chambers
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Joint Proposed Juror Questionnaire and Voir Dire
CAUTION - EXTERNAL:
Good evening,
Attached please find the parties' joint proposed juror questionnaire and voir dire. Per the attached letter, the parties
respectfully request that the Court accept the joint proposed juror questionnaire and voir dire under seal.
In addition, the Government has produced Jencks Act material and exhibits to the defense today. If the Court would like
a copy, we would be happy to provide it.
Respectfully submitted,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
EFTA00011114


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=== Page 1 ===
STATE OF FLORIDA
:
IN THE
L DIVISION OF THE CIRCUIT
COURT
FTEENTH JUDICIAL CIRCUIT,
vs.
IN AND FOR PALM BEACH COUNTY, FLORIDA
Jeffey Epsten
/
CASE NUMBER(S):
PLEA IN THE CIRCUIT COURT
1. DEFENDANT:
I am the defendant in the above-mentioned matter(s), and I am represented by the attorney indicated below. I
understand I have the right to be represented by an attorney at all stages of the proceeding until the case is terminated,
and if I cannot afford an attorney, one will be appointed free of charge.
A
]
2. DEFENDANT:
I understand I have the right to a speedy and public trial either by jury or by court. I hereby waive and give up this
right.
9
3. DEFENDANT:
I understand I have the right to be confronted by the witnesses against me and to cross examine them by myself or
through my attorney. I hereby give up these rights.
[h]
4. DEFENDANT:
I understand I have the right to testify on my own behalf, but I cannot be compelled to be a witness against myself
and may remain silent if I so choose. I hereby give up these rights.
]
5. DEFENDANT:
I understand I have the right to call witnesses to testify in my behalf and to invoke the compulsory process of the
Court to subpoena those witnesses. I hereby give up these rights.
]
6. DEFENDANT:
I understand I have the right to appeal all matters relating to the charge(s) and, unless I plea Guilty or No Contest,
specifically reserving my right to appeal, I will give up such right of appeal.
7. DEFENDANT:
I understand that if I am not a United States Citizen, my plea may subject me to deportation pursuant to the laws and
regulations governing the United States Immigration and Naturalization Service: and, this Court has no jurisdiction
(authority) in such matters.
8. DEFENDANT:
I have not received any promises from anyone, including my attorney, concerning eligibility for any form of early
release authorized by law and further no promises have been made to me as to the actual amount of time that I will
serve under the sentence to be imposed. Further, I understand that this plea may be used to enhance future criminal
penalties in any court system, even if adjudication of guilt is withheld.
[
]
9. DEFENDANT:
I offer my plea freely and voluntarily and of my own accord, with full understanding of all matters set forth in the
pleadings and this waiver.
]
10.DEFENDANT:
I have personally placed my initials in each bracket above, and I understand each and every one of the rights outlined
above. I hereby waive and give up each of them in order to enter my plea to the within charge(s). I understand that
even though the Court may approve the agreement of sentence, the Court is not bound by the agreement, the Court
may withdraw its approval at any time before pronouncing judgment, in which case I shall be able to withdraw my
plea should I desire to do so.
11. DEFENDANT:
Choose one:
If applicable, I choose a program which is or may be spiritually based.
If applicable, I choose a program which is NOT spiritually based.
If applicable, I have no preference if the program is or may be spiritually based.
6/30/06
DEFENDANT
DATE
DEFENDANT'S ATTORNEY ONLY:
I am attorney of record. I have explained each of the above rights to the defendant and have explored the facts with him/her and studied his/her
possible defenses to the charge(s). I concur with his/her decision to waive the rights and to enter this plea. I further stipulate that this document
may be received by the Court as evidence of defendant's intelligent waiver of these rights and that it shall be filed by the Clerk as permanent record
of that waiver.
M Goldberge
6/30/04
ATTORNEY FOR THE DEFENDANT
DATE
Page 1 of
Original - Clerk 03/25/2015 Green State Attorney Yellow Defense Attorney 14 of 114 Pink Defendant Goldenrod Public Records.Request No.: 16-268 Form 002
Form Circuit 1 (rev 8/2000)
EFTA00010495


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
08-8068-LRJ
IN RE:
SEARCH WARRANT APPLICATION
/
MOTION TO FILE DOCUMENTS UNDER SEAL
The United States of America, by and through the undersigned Assistant United States Attorney, hereby
moves to seal its Application for Search Warrant for the following reasons:
1. The attached documents contain information relating to an ongoing grand jury investigation; thus,
pursuant to Fed. R. Crim. P. 6(e)(6), all records and orders related to the grand-jury proceedings must be kept
under seal to the extent and as long as necessary to prevent the unauthorized disclosure of a matter occurring
before the grand jury.
2. Public disclosure of this matter would jeopardize the criminal investigation, notify potential subjects
and/or targets and undermine the public interest and the function of the grand jury.
WHEREFORE, the United States respectfully requests that the aforementioned documents be sealed.
Respectfully submitted,
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
By:
Assistant United States Attorney
West Palm Beach, FL 33401
Telephone:
Facsimile:
EFTA00014063


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=== Page 1 ===
From:
To: "Jack Goldberger"
Cc:
Subject: Victim Notification in Epstein
Date: Tue, 08 Jul 2008 18:06:29 +0000
Importance: Normal
Attachments: 080708_Goldberger_Ltr_re_Victim_Notification.pdf
Dear Mr. Goldberger:
Please review the attached letter.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
EFTA00013556


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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
rev. 2019.11.19
EFTA00010022

=== Page 2 ===
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
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
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
EFTA00010023


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: Letter
Date: Fri, 02 Oct 2020 16:02:53 +0000
Attachments: 2020.10.1 Letter to Government re Discovery.PDF;
2020.09.21_Letter_to_Government_re_Discovery_and_Prison_Conditions.PDF
Inline-Images: image005.jpg; image006.jpg
We wanted to let you know we received the attached letter on discovery from Maxwell's counsel last night. (I also
reattached their prior letter on discovery and prison conditions.)
expects to send you a draft response on
Monday. We were hoping to chat with you about this and the
Do you have time today before 1 pm or after 3
pm?
Thanks,
From:
Sent: Thursday, October 01, 2020 11:11 PM
To:
Subject: Letter
Please see the attached letter.
Regards,
COHEN & GRESSER LLP
New York
Seoul
Paris
Washington DC
London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
EFTA00013220

=== Page 2 ===
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00013221


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=== Page 1 ===
ENT
U.S. Department of Justice
United States Attorney
Southern District of Florida
500 S. Australian Ave, Ste 400
West Palm Beach, FL 33401
Facsimile:
August 26, 2008
DELIVERY BY ELECTRONIC MAIL
Jay P. Lefkowitz, Esq.
Kirkland & Ellis LLP
Citigroup Center
153 East 53rd Street
New York, New York 10022-4675
Roy Black, Esq.
Black Srebnick Kornspan & Stumpf P.A.
201 S. Biscayne Blvd, Suite 1300
Miami, FL 33131
Re:
Jeffrey Epstein
Dear Jay and Roy:
Thank you for your letter of August 22nd. I write to follow up on some of the points
that you raised.
The list of thirty-two victims that was provided to Mr. Goldberger via certified mail
on July 10, 2008 is the final list. As I mentioned, copies of the notification letters to each
victim will be carbon-copied to an attorney for Mr. Epstein and Mr. Josefsberg. I asked you
to advise me whether Mr. Goldberger should continue to be listed as the contact person for
the civil litigation in the amended victim notification letters and whether he should receive
the carbon copies of those letters as they are sent.
I also asked you to provide me with written confirmation of your agreement to pay Mr.
Josefsberg's fees. Please provide that confirmation to Mr. Josefsberg so that he can begin
his representation, and provide me with a copy for my file.
I have conferred with the lead AUSA in the case of Jane Doe 1 and 2 V. United States,
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JAY P. LEFKOWITZ, ESQ.
ROY BLACK, EsQ.
AUGUST 26, 2008
PAGE 2 OF 2
and he agrees that, based upon the discussion with Judge Marra during the hearing on the
plaintiffs' motion, a notification of the judge's ruling is required. I will, however, change
the language slightly to direct the victims to discuss the matter with Mr. Josefsberg.
With regard to your concerns with my "open-ended description of Mr. Epstein's
responsibilities regarding civil restitution," I agree that the resolution of civil damages claims
is as stated in paragraphs 7 and 8 of the Agreement and Addendum. That is why the
language in the notification is taken verbatim from paragraphs 7, 8, and 7C of the Agreement
and Addendum, except that the victim's name is used in place of "identified individual." As
I mentioned in my earlier letter, if you have any proposed substantive changes, please provide
them to me.
Mr. Goldberger and Mr. Tein explicitly approved the language in my earlier victim
notification letter, even though they apparently were taking the position that the December
19, 2007 letter was not part of the Agreement, so that misinformation was provided to the
victims with the approval of Mr. Epstein's attorneys.
With regard to your sixth and seventh points, I reiterate that it is the Office's position
that the Agreement and Addendum speak for themselves. Let me also reiterate that, while
the Office does not intend to involve itself in any civil negotiations or litigation, if it comes
to our attention that Mr. Epstein has breached the terms of the Agreement, the Office intends
to enforce its right pursuant to the Agreement.
I would appreciate a prompt response to the question regarding which of Mr. Epstein's
attorneys should be named in and receive copies of the notification letters, as well as
documentation of your commitment to paying Mr. Josefsberg's fees so that I may begin
distributing the revised victim notifications on Wednesday morning.
Sincerely,
R. Alexander Acosta
United States Attorney,
By:
Assistant United States Attorney
cc:
Chief, Northern Division
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From:
To:
Cc:
Subject: Epstein items
Date: Tue, 18 Dec 2007 13:40:28 +0000
Importance: Normal
Hi all - Just wanted to let you know that I sent a box to
with all of the correspondence, including some
of the correspondence related to the negotiation of the agreement, and a box of evidence to
I wrote "Urgent" on the box for
so hopefully the mailroom will bring it right up.
Assistant U.S. Attorney
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From:
"
)"
To:
Bcc:
"
)"
Subject: RE: Letter concerning Epstein and the Palm Beach Daily News
Date: Wed, 17 Sep 2008 17:19:48 +0000
Importance: Normal
Thank you,
Assistant U.S. Attorney
Phone
Fax
From: Jack Goldberger [mailto:
Sent: Wednesday, September 17, 2008 12:59 PM
To:
)
Cc: Jay Lefkowitz;
;
)
Subject: Re: Letter concerning Epstein and the Palm Beach Daily News
We will deal with the state. To answer your? The addendum has been filed
Sent from my iPhone
On Sep 17, 2008, at 12:15 PM,
"
)"
wrote:
Gentlemen: Please review the attached letter. Thank you.
<<Lefkowitz 080917.pdf>>
Assistant U.S. Attorney
<Lefkowitz 080917.pdf>
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From:
To:
Bec:
Subject: MySpace Contact
Date: Wed, 03 Sep 2008 16:23:28 +0000
Importance: Normal
Hi
Here is the MySpace page info:
Dear
:
I am writing on behalf of
the Assistant U.S. Attorney in West Palm Beach who prosecuted the
Jeffrey Epstein case. She needs to provide you with information regarding the resolution of the case, including
the name and contact information of an attorney who can advise you and represent you for free in connection
with any civil claim you want to make against Mr Enstein Can you please provide her with a telephone number
and an e-mail address? She can be reached at
Thank you.
Assistant U.S. Attorney
Phone
Fax
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From: Brendan White
To:
(USAFLS)"
Subject: Re: Grand Jury Appearance
Date: Thu, 26 Jun 2008 15:26:21 +0000
Importance: Normal
Thanks.
Original Message
From:
(USAFLS)
To: Brendan White
Sent: Thursday, June 26, 2008 10:55 AM
Subject: RE: Grand Jury Appearance
Dear Mr. White:
If Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be
withdrawn. At this point, I have not received confirmation that the change of plea is going to occur, nor have I
received information confirming that the plea will be in conformance with our agreement. As such, at this
time, I still intend to present Ms.
testimony to the grand jury on Tuesday. With respect to the
immunity question, I refer you to my e-mail of June 23rd, which is shown below.
If the situation changes, I will contact you.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
From: Brendan White [mailto:brendan@whiwhi.com]
Sent: Thursday, June 26, 2008 10:38 AM
To:
(USAFLS)
Subject: Re: Grand Jury Appearance
Dear Ms.
:
I understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in
Florida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been
executed. Since this would seem to obviate any need for Ms.
to testify, please let me know what is going on
with respect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered immunity?
Thanks.
Brendan White
Original Message
From:
(USAFLS)
To: Brendan White
Sent: Monday, June 23, 2008 2:09 PM
Subject: RE: Grand Jury Appearance
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=== Page 2 ===
Dear Mr. White:
Please feel free to make your own travel arrangements, but if you would like Ms.
travel costs to be
reimbursed, they must be made through the government's approved agency on the approved carriers.
Regarding the immunity, at this point, without a written proffer from you regarding the substance of her
anticipated testimony, I believe that the more prudent course will be to question Ms.
to determine the
limits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide
me with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to
criminal liability, then I can make the motion ahead of time. Your written statement would be treated as an
attorney statement made in the course of confidential plea discussions and related negotiations, and would be
governed by Fed. R. Crim. P. 11(f) and Fed. R. Evid. 410.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
From: Brendan White [mailto:
Sent: Monday, June 23, 2008 1:45 PM
To:
(USAFLS)
Cc:
(USAFLS)
Subject: Re: Grand Jury Appearance
We will be there, and I will make the travel arrangements. I am assuming that this will be done in connection with an
order of immunity. Please let me know if that is correct so I can advise Ms.
Thanks.
Brendan White
Original Message
From:
(USAFLS)
To: Brendan White
Cc:
(USAFLS)
Sent: Monday, June 23, 2008 11:27 AM
Subject: Grand Jury Appearance
Dear Mr. White:
Ms.
will need to appear before the grand jury on July 1st to give testimony. Please contact my
assistant,
, at
, ext.
,
to make travel arrangements. I expect that Ms.
testimony will begin either in the late morning or early afternoon, but she should be available for
the whole day.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
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II I Fax
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=== Page 1 ===
Exhibit P
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Statement of
1. I,
, am a forensic accountant and private investigator, and the
owner of
-
I received a BA in Economics from
Lehman College in 1973 and an advanced degree in Personal Financial Planning
from Lehman College in 1997. I have been a Certified Fraud Examiner (CFE)
since receiving that designation in 1997.
2. Prior to entering the private sector, I was a Special Agent with the Internal
Revenue Service, Criminal Investigation Division (IRS-CID) from 1973 until
my retirement in 1998. As a Special Agent, I worked on numerous financial
fraud investigations, including several with the U.S. Attorney's Office for the
Southern District of New York. In addition, during the last five years of my
employment with the IRS, I received the designation of Cross-Designation
Authority from the FBI while being a member of the joint task force with the
FBI and the NYPD whose responsibilities were to investigate the federal
money laundering statutes on a national and international scale.
3. I have over forty years of experience in complex financial fraud
investigations, including: income tax violations, white collar crime, and
securities fraud. I also have extensive field experience in the tracing of assets
and reviewing books and records to recognize, identify, and trace suspicious
1
EFTA00011169

=== Page 3 ===
financial activity. I have also conducted numerous forensic investigative
audits.
4. I have been hired by federal and state law enforcement agencies on numerous
occasions to serve as a forensic accountant/investigator for corporate
monitorships and other compliance programs. For example, I was a member
of the World Trade Center Integrity Compliance Program administered by the
New York City Department of Investigation. My responsibilities included
preventing and detecting wasteful or abusive practices by contractors at the
World Trade Center site. My work consisted of reviewing the books and
records, including workers payroll records and invoices, and detailing any
fraud discovered in final summary reports.
5. For this engagement, I was hired by Cohen & Gresser LLP to conduct an
independent review of a Financial Condition Report prepared by Macalvins
Accountants summarizing the financial condition and assets of Ghislaine
Maxwell for the time period 2015-2020. I was asked to verify the accuracy of
the representations contained in the Independent Accountants' Commentary
and the accompanying Statement of Financial Condition including related
Excel schedules documenting the findings.
6. I reviewed the Independent Accountants' Commentary, the Statement of
Financial Condition, and the Excel schedules. To complete my review, I was
given access to all of the underlying documents relied upon by Macalvins to
prepare the Financial Condition Report, and I reviewed these underlying
documents to the extent necessary to verify the representations in the
2
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=== Page 4 ===
Financial Condition Report. I also posed questions to the Macalvins
accountants and requested additional documents that I required to confirm the
amounts listed in the Financial Condition Report and accompanying
schedules. At all times, I was given complete access to the relevant
documents and allowed to ask any questions I thought pertinent to my
analysis.
Conclusion
7. Based on my review, I believe that the Financial Condition Report represents
a complete and accurate summary of the assets held by Ms. Maxwell and her
husband, as well as assets that were, or are currently, held in trust for the
benefit of Ms. Maxwell, for the time period from 2015-2020.
3
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From:
To:
Cc:
Subject: RE: Epstein investigation documents
Date: Fri, 17 May 2019 23:18:20 +0000
That's great, talk to your then.
SSA
FBI New York
On May 17, 2019 6:10 PM,
wrote:
That's perfect, thanks - we'll plan to call you Monday afternoon, say, 2:00, but let us know if there's a different time you
prefer and we'll make it work. Have a good weekend, and talk soon.
thanks again,
From:
Sent: Friday, May 17, 2019 15:08
To:
Cc:
Subject: RE: Epstein investigation documents
Sure, let's talk next week, I'm out on Tuesday and likely Friday. Any other time works
SSA
Squad C-20
VCAC/Human Trafficking
FBI New York
From:
Sent: Friday, May 17, 2019 1:19 PM
To:
Cc:
Subject: RE: Epstein investigation documents
Hi
and I are the AUSAs working with
on the Epstein investigation, and we wanted to briefly be in
touch because
mentioned there's some concern about having our office manage documents with a vendor (for
scanning, cataloguing, and indexing), and she said it would be helpful for us to provide some examples of cases where
that has been done in the past. We have a number of examples, and we're hoping to quickly chat with you about the
most productive way to get that info to you-is there a good time for us to give you a call sometime early next week?
We're happy to work around your schedule, and we really appreciate the help.
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=== Page 2 ===
Thanks very much, and talk soon,
Assistant U.S. Attorney
Southern District of New York
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From:
To:
Subject: Fwd: EPSTEIN, Jeffrey, reg. no. 76318-054
Date: Sat, 10 Aug 2019 18:18:14 +0000
Attachments: mltC634.pdf; ATT00001.htm
FYI
Sent from my iPhone
Begin forwarded message:
From
Date: August 10, 2019 at 1:56:23 PM EDT
To:
Cc:
Subject: EPSTEIN, Jeffrey, reg. no. 76318-054
Good afternoon,
Enclosed please find official notification from Warden
regarding Mr. Epstein's passing. As the
investigation is ongoing, we have no further details at this time. We will continue to keep you updated as more
information is available.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
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KIRKLAND & ELLIS LLP
AND AFFILIATED PARTNERSHIPS
Los Angeles, California 90017
Kenneth W. Starr
To Call Writer Directly:
Facsimile:
www.kirkland.com
Dir. Fax:
June 19, 2008
Esq.
Principal Associate Deputy Attorney General
Office of the Deputy Attorney General
United States Department of Justice
Dear Mr.
I again want to thank you for this opportunity to explain why we believe that a federal
prosecution of Jeffrey Epstein is unwarranted. I appreciate your having informed us that you
already have our May 19 and May 27 communications to the Deputy Attorney General, as well
as our prior written submissions to CEOS and to the Southern District of Florida.
In light of the significant volume of our prior submissions and to facilitate your review,
we have drafted four supplemental submissions that will provide a roadmap for your
investigation of this matter. Given the bulk of these documents and their appended supporting
attachments, you will receive this packet by messenger tomorrow. A brief description of each of
the four submissions follows. First, I have included a succinct summary of the facts, law and
policy issues at hand. This document sets forth a basic overview of the issues and summarizes
our principal contentions as to why federal prosecution of this matter is neither appropriate nor
warranted.
The three other submissions include: a summary of the irregularities and misconduct that
occurred during the federal investigation; a letter from former CEOS attorney
that responds to CEOS's assessment of its limited review of Mr. Epstein's case; and a point-by-
point rebuttal to First Assistant United States Attorney
recent letter which we
believe contains factual inaccuracies typical of our correspondence from the United States
Attorney's Office in Miami (the "USAO"). Also, for your reference, the package you receive
tomorrow will contain a binder including all documentation to which we refer in our
submissions. Finally, we will be providing a detailed checklist of each submission or substantive
communication to the USAO. Our intention is that you have copies of each such document to
enhance your review. If there are any that you have not received from the USAO or CEOS,
please advise and we will fedex them to you without delay.
Chicago
Hong Kong
London
Munich
New York
San Francisco
Washington, D.C.
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=== Page 2 ===
KIRKLAND & ELLIS LLP
Esq.
June 19, 2008
Page 2
As you are likely aware, the Department's prior review of this matter was incomplete
and, by its own admission, not "de novo." See Tab 38, May 15, 2008 Letter from A. Oosterbaan.
Without considering the Non Prosecution Agreement that left this matter to be resolved in the
State or any of the misconduct, CEOS reviewers, tasked with reviewing some of their own
previously expressed opinions, assessed only whether the United States Attorney would "abuse
[his] discretion" if he pursued this case. While we appreciate CEOS's willingness to examine
these limited issues, its conclusion that a prosecution would not be an "abuse of discretion" rings
particularly hollow in light of CEOS's admirably candid concessions that we have raised
"compelling" objections and that a prosecution on these facts would require "novel" applications
of federal law. Indeed, even a brief review of CEOS's own mission statement reveals how
inapposite a federal prosecution is to the facts in this case.
Importantly, we note that the CEOS review was conducted prior to the Supreme Court's
very recent decisions in Santos and Cuellar, which we believe-illuminating as they do the
Court's interpretive methodology when it comes to federal criminal law-powerfully
demonstrate the substantive vulnerability of the USAO's unprecedented employment of three
federal laws. That Office's interpretation would never pass muster under the Supreme Court's
recent pronouncements and should not be countenanced. That is all the more true under the
circumstances where the duly appointed U.S. Attorney opined that, in effect, the "unitary"
Executive Branch was driving this prosecution. We now know that is not so.
What I respectfully request, and what I hope you will provide, is a truly "de novo"
review-that is, an independent assessment of whether federal prosecution of Mr. Epstein is both
necessary and warranted in view of the legal and evidentiary hurdles that have been identified,
the existence of a State felony plea and sentence that have been advocated by the State Attorney
for Palm Beach County, and the many issues of prosecutorial misconduct and overzealousness
that have permeated the investigation. I also request that you provide us with the opportunity
during your review to meet with you in person to answer any questions you may have and to
elucidate some of the issues in our submission.
We believe that an independent review will confirm our strong belief that federal
prosecutors would be required to stretch the plain meaning of each element of the enumerated
statutes, and then to combine these distorted elements in a tenuous chain, in order to convict Mr.
Epstein. Indeed, just this week (and after two years of federal involvement in this matter),
Assistant United States Attorney
re-initiated the federal grand jury investigation-in
direct contravention of the parties' Non Prosecution Agreement-and issued yet another
subpoena seeking evidence in this case. See Tab 19, Subpoena to
In the
subpoena, AUSA
directs
to appear on July 1, 2008 to give testimony
and produce documents to FGJ 07-103 West Palm Beach. The attachment to the subpoena seeks
documents such as photographs, emails, telephone billing information, and contact information
that relate to Mr. Epstein as well as specific other people who received protection from federal
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KIRKLAND & ELLIS LLP
Esq.
June 19, 2008
Page 3
prosecution as a result of Mr. Epstein's having entered into the September 24, 2007 Non
Prosecution Agreement with the USAO.
Notably, the Non Prosecution Agreement contains the following agreed condition:
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.
See Tab 21, September 24, 2007 Non Prosecution Agreement. It also guarantees that persons
identified in the Grand Jury subpoena such as
, and
and others will not be prosecuted. The new Grand Jury subpoena clearly violates the Non-
Prosecution Agreement. Although Mr. Epstein has exercised his rights to appeal to the
Department of Justice with the full consent and knowledge of the USAO, he has not breached the
Agreement. The re-commencing of the Grand Jury is in violation of the Agreement.
But further, the new investigation, which features a wide-ranging, fishing-expedition type
to search in New York does nothing to satisfy the very essential elements of federal statutes that
are lacking despite the intensity of an over two-year investigation in the Palm Beach area.
Absent evidence of Internet luring, inducements while using the phone, travel for the purpose,
fraud or coercion, the subject of the New York investigation is as lacking in the essential basis
for converting a state case into a federal case as is the remainder of the Florida investigation.
The reaching out to New York to fill the void emanating from the failures of the Florida
investigation compellingly demonstrates the misuse of federal resources in an overzealous, over-
personalized, selective and extraordinary attempt to expand federal law to where it is has never
gone. This last-ditch attempt by Ms.
reinforces our belief that the USAO does not have
facts that, without distortion, would justify a prosecution of Mr. Epstein.
In view of the prosecution's often-verbalized desire to punish Mr. Epstein, we believe
that the prosecution summary suffers from critical inaccuracies and aggregates the expected
testimony of witnesses so as to reach a conclusion of guilt. Our contention is reinforced by the
fact that key prosecution witnesses have provided evidence and testimony that directly
undermines the prosecution's misleading and inaccurate summary of its case. Indeed, we now
have received statements from three of the principal accusers-
(through a state
criminal deposition),
(through a federal FBI-USAO sworn and transcribed
interview), and
(through a defense-generated sworn transcribed interview).
Each of these witnesses categorically denies each essential element that the prosecution will have
to prove in order to convert this quintessential state-law case into a federal matter.
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KIRKLAND & ELLIS LLP
Esq.
June 19, 2008
Page 4
It thus is especially troubling that the USAO has not provided us with the transcript of
Ms.
S federal interview, nor the substance of the interviews with Ms.
or Ms.
nor any information generated by interviews with any of the approximately 40 alleged
witnesses that the prosecution claims it has identified. Because the information provided by
these women goes directly to the question of Mr. Epstein's guilt or innocence, it is classic Brady
information. We understand that the U.S. Attorney might not want to disclose impeachment
information about their witnesses prior to a charge or during plea negotiations. But we firmly
believe that when the Government possesses information that goes directly to a target's factual
guilt or innocence, the target should be informed about such heartland exculpatory evidence.
Most importantly, aside from whether the Department believes Brady obligates
disclosure to a target of a federal investigation prior to the target's formal accusation, no such
limit should apply to a Department review. Accordingly, we request that you go beneath the face
of any summary provided to you by the USAO and instead review the actual witness transcripts
and FBI 302s, which are essential for you to be able to make a truly independent assessment of
the strength and wisdom of any federal prosecution.
After careful consideration of the record, and as much as it pains me to say this, I simply
do not believe federal prosecutors would have been involved at all in this matter if not for Mr.
Epstein's personal wealth and publicly-reported ties to former President Bill Clinton. A simple
Internet search on Mr. Epstein reveals myriad articles and news stories about the former
President's personal relationship with Mr. Epstein, including multi-page stories in New York
Magazine and Vanity Fair. Mr. Epstein, in fact, only came to the public's attention a few years
ago when he and the former President traveled for a week to Africa (using Mr. Epstein's
airplane)-a trip that received a great deal of press coverage. I cannot imagine that the USAO
ever would have contemplated a prosecution in this case if Mr. Epstein lacked this type of
notoriety.
That belief has been reinforced by the significant prosecutorial impropriety and
misconduct throughout the course of this matter. While we describe the majority of these
irregularities in another submission, two instances are particularly troubling. First, the USAO
authorized the public disclosure of specific details of the open investigation to the New York
Times-including descriptions of the prosecution's theory of the case and specific terms of a plea
negotiation between the parties. Second, AUSA
attempted to enrich friends and close
acquaintances by bringing them business in connection with this matter. Specifically, she
attempted to appoint a close personal friend of her live-in boyfriend to serve as an attorney-
representative for the women involved in this case.
It also bears mentioning that actions taken by FAUSA
present an appearance of
impropriety that gives us cause for concern. Mr.
's former law partner is currently
pursuing a handful of $50-million lawsuits against Mr. Epstein by some of the masseuses.
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KIRKLAND & ELLIS LLP
Esq.
June 19, 2008
Page 5
Finally, as you know, Mr. Epstein and the USAO entered into an agreement that deferred
prosecution to the State. In this regard, I simply note that the manner in which this agreement
was negotiated contrasts sharply with Mr.
S current representation that "[T]he SDFL
indicated a willingness to defer to the State the length of incarceration " See Tab 1, May 19,
2008 Letter from
p. 2. This statement is simply not true. Contrary to Mr.
S
assertion, federal prosecutors refused to accept what the State believed to be appropriate as to
Mr. Epstein's sentence and instead, insisted that Mr. Epstein be required serve a two-year term of
imprisonment (which they later decreased to 18 months plus one year of house arrest). Federal
prosecutors have not only involved themselves in what is quintessentially a state matter, but their
actions have caused a critical appearance of impropriety that raises doubt as to their motivation
for investigating and prosecuting Mr. Epstein in the first place.
At bottom, we appreciate your willingness to review this matter with a fresh-and
independent-set of eyes. To facilitate your review, I once again request the opportunity to
make an oral presentation to supplement our written submissions, and we will promptly respond
to any inquiries you may have.
Yours sincerely
Kenneth W. Starr
cc:
Deputy Attorney General
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From:
To:
)"
Cc:
Subject: Filing
Date: Wed, 16 Dec 2020 15:48:12 +0000
Attachments:
Statement_in_Opp._to_Bail.pdf
Here is the statement from
Please let me know if you need anything else.
Best,
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 ===
From:
To:
"Acosta, Alex (USAFLS)"
Subject:
Date: Tue, 11 Dec 2007 17:19:37 +0000
Importance: Normal
I have only gotten through page 1. FYI - I called Ms.
attorney (who is paid for by Epstein) and asked
one thing only - Do you still represent Ms.
and do you want me to send the victim notification letter to
you or to her? He asked me to send it to him. He asked what the letter would say and I would not tell him. I
only said that we anticipated sending out the letter in the next week or so.
Assistant U.S. Attorney
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: New drive for Maxwell
Date: Fri, 04 Dec 2020 19:04:28 +0000
Attachments: Ltr_to_Hon_Nathan_12.04.20.pdf
Attached please find the letter to Hon. Nathan.
Best,
Staff Attorney
Department of Justice
Federal Bureau of Prisons
Metropolitan Detention Center Brooklyn
Brooklyn, New York 11232
SENSITIVE/PRIVILEGED COMMUNICATION
The information contained in this electronic message and any and all
accompanying documents constitutes sensitive information. This
information is the property of the U.S. Department of Justice. If you
are not the intended recipient of this information, any disclosures,
copying, distribution, or the taking of any action in reliance on this
information is strictly prohibited. If you received this message in
error, please notify us immediately to make arrangements for its return
to us.
)"
12/4/2020 9:39
AM
Thank you very much.
Original Message
From:
Sent: Friday, December 4, 2020 7:41 AM
To:
Cc:
)
)
EFTA00010211

=== Page 2 ===
Subject: Re: New drive for Maxwell
Not a problem.
Best,
)"
12/3/2020 5:24
PM
Hi all,
Today our office is sending via FedEx a replacement drive for Ghislaine
Maxwell, which should arrive at the MDC tomorrow. This drive will
replace the drive that Maxwell recently dropped and broke, and the
accompanying cover letters are attached. Would you please make sure
Maxwell is given access to this drive?
Would you please mail the broken drive back to our office? It can be
mailed to the below address:
Paralegal Specialist
U.S. Attorney's Office, SDNY
New York, NY 10007
Thanks very much, as always, for your help.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
<mailto:
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=== Page 1 ===
From:
"
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To:
(USAFLS)"
Subject: epstein
Date: Thu, 26 Jun 2008 13:59:55 +0000
Importance: Normal
Attachments:
; Principal_Submission.pdf
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=== Page 1 ===
Event: Epstein Case
Start Date: 2007-09-07 18:00:00 +0000
End Date: 2007-09-07 19:00:00 +0000
Organizer: Acosta, Alex (USAFLS)
Location: West Palm Beach Office
Class: X-PERSONAL
Date Created: 2015-03-27 13:43:24 +0000
Date Modified: 2015-07-22 20:34:48 +0000
Priority: 5
DTSTAMP: 2007-08-14 19:49:03 +0000
Attendee:
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=== Page 1 ===
From:
To:
Subject: RE: send me dial in
Date: Fri, 23 Apr 2021 14:14:13 +0000
Attachments: 2021.04.19_Scheduling_Order.pdf
Here's the full order with access info.
From:
Sent: Friday, April 23, 2021 8:18 AM
To:
Subject: send me dial in
EFTA00009900


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Date: Wed, 05 Aug 2020 20:34:33 +0000
We have a hard drive with loaded discovery that we need to deliver to Ghislaine Maxwell,
at MDC. Could you
please let us know what the current protocol is for that? Also, it's our understanding that hard drives with discovery
materials for inmates needs to be non-encrypted (and not have a password for access), is that also correct?
We're hoping to get these materials to her tomorrow if at all possible, so we greatly appreciate your help. And I'm
reachable any time at
if it would be helpful to discuss.
thanks,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Subject: Epstein/call in from
Date: Wed, 11 Jun 2008 15:27:38 +0000
Importance: Normal
Attachments: unnamed
When: Friday, June 13, 2008 10:00 AM-10:30 AM (GMT-05:00) Eastern Time (US & Canada).
Where:
fc.
you can participate by phone. Let me know best number, Thanks,
Original Message
From:
To: S
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
I'm available anytime
From:
Sent: Wednesday, June 11, 2008 10:09 AM
To:
EFTA00013969

=== Page 2 ===
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
Co
Subject: Epstein
Would you guys be available Friday morning by telephone to discuss?
EFTA00013970


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=== Page 1 ===
From:
"
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To: "
:
>, "Roy BLACK"
Cc: "
(USAFLS)"
Subject: Hearing with Judge Marra
Date: Thu, 14 Aug 2008 20:21:00 +0000
Importance: Normal
Dear Jay and Roy:
We just finished our hearing with Judge Marra. He has ordered us to make the Agreement available to the
plaintiffs in this case pursuant to a protective order limiting the disclosure to the victims and their counsel only.
He further has ordered that we have to make the agreement available to any other identified victim and her
attorney, so long as they also agree to be bound by the protective order. Judge Marra stated that the plaintiffs can
litigate the issue of further disclosure directly with Mr. Epstein in the context of their civil suits.
When I receive the Court's order and a signed protective order, I will provide them to you.
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:
Subject: Accepted: Meet re: Epstein
Date: Fri, 18 Jan 2019 14:56:35 +0000
Importance: Normal
Attachments: unnamed
EFTA00013443


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=== Page 1 ===
LAW OFFICES
ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
P.O. BOX 3394
GEORGE G. GUTHRIE
CHARLESTON, WEST VIRGINIA 25333-3394
ROBERT B. ALLEN
REBECCA A. BETTS
R. TERRANCE RODGERS
DAVID B. THOMAS
500 LEE STREET, EAST, SUITE 800
JAMES S. ARNOLD
CHARLESTON, WEST VIRGINIA 25301
DAVID J. HARDY
WM. SCOTT WICKLINE
TELEPHONE
PAMELA L. CAMPBELL
(304) 345-7250
PAMELA C. DEEM
FACSIMILE (304) 345-9941
PHILIP J. COMBS
STEPHANIE D. THACKER
BRYANT J. SPANN
WRITER'S DIRECT DIAL
TERESA K. THOMPSON
DEBRA C. PRICE
e-mail:
CHRISTOPHER S. ARNOLD
CHRISTOPHER D. PENCE
PETER G. MARKHAM
ZACKARY B. MAZEY
June 19, 2008
OF COUNSEL
THOMAS E. McHUGH
Mr. John Roth
Senior Associate Deputy Attorney General
Office of the Deputy Attorney General
United States Department of Justice
950 Pennsylvania Avenue, N.W.
Washington, D.C. 20530
Dear Mr. Roth:
I write to offer my reaction to the May 15, 2008 correspondence from the United States
Department of Justice Child Exploitation and Obscenity Section ("CEOS") regarding the federal
investigation of Jeffrey Epstein by the United States Attorney's Office for the Southern District of
Florida ("USAO").¹ I will refrain from recounting Mr. Epstein's arguments in detail here, but,
rather, will highlight salient points responsive to the CEOS letter.
In particular, I write from a background well familiar with child exploitation cases and
victim/witness issues. As the CEOS letter points out (CEOS letter at p. 3), I was a member of
CEOS. In fact, I served as a federal prosecutor for twelve years; five years as an Assistant United
States Attorney for the Southern District of West Virginia, and seven years at CEOS. I began
working as a trial attorney for CEOS in 1999, and was promoted to Deputy Chief for Litigation in
2002, and ultimately to Principal Deputy Chief for the Section in 2004.
As those who have worked with me know, I have a history of working diligently on behalf of
victims of crime. While at the United States Attorney's Office for the Southern District of West
Virginia, I was a part of the prosecution team that prosecuted the first case in the country under the
federal Violence Against Women Act. United States V. Bailey, 112 F.3d 758 (4th Cir.), cert denied,
522 U.S. 896 (1997). The case went to trial and the defendant was sentenced to life in prison. I also
spearheaded the domestic violence and federal criminal child support prosecution efforts for that
office, prosecuting some of the first cases in the country under the federal Child Support Recovery
1 Citations to the May 15, 2008 correspondence will be referenced herein as "CEOS letter at p.
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=== Page 2 ===
ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 2
Act. Later, while at the Department of Justice, I co-authored the Department's Federal Child
Support Prosecution Handbook.
My work at CEOS permitted me to continue my efforts on behalf of vulnerable victims of
crime. While there, for example, I was part of the prosecution team in United States V. Dwight York,
428 F.3d 1325 (11th Cir. 2005), cert denied, 548 U.S. 908 (2006). York was the leader of a pseudo
religious organization, and systematically molested countless children, some as young as six years
old. The case went to trial and York was sentenced to 135 years in prison. As part of that trial team,
I was awarded the Attorney General's Award for Distinguished Service. Additionally, at CEOS I
was one of the architects of the Innocence Lost Initiative, a nationwide initiative designed to combat
child prostitution. For this, I was awarded an Assistant Attorney General's Award for Outstanding
Victim/Witness Service. Likewise, I was awarded a subsequent Assistant Attorney General's Award
for Special Initiative in connection with a nationwide sex tourism prosecution initiative I helped to
develop.
I say all this not for any boastful purpose, but, rather, to make clear that I am fully cognizant
of victim issues, and that I am no pushover in terms of prosecution standards. I am also very well
aware of the good work of CEOS, and the outstanding credentials of those who toil in that office.
With all due respect to CEOS, however (and recognizing that their review of this case was
quite limited), given the facts and circumstances of this investigation, a federal prosecution of Mr.
Epstein simply should not be countenanced. In my view, such prosecution would be counter to the
important mandate of the Department of Justice as emblazoned on its seal, "Qui Pro Domina Justitia
Sequitur," referring to the Attorney General "who prosecutes on behalf of justice."
As you well know, it is fundamental to that mandate that, as the representative of the people
of the United States, the duty of a federal prosecutor is not simply to seek conviction as at any cost,
but, rather, to seek justice. Berger V. United States, 295 U.S. 78, 88 (1935). ("The United States
Attorney is the representative not of an ordinary party to a controversy, but of a sovereignty whose
obligation to govern impartially is as compelling as its obligation to govern at all.") While it is true
that Berger was decided at the post-trial, as opposed to the pre-indictment, stage of the case, the
bedrock principle contained in the above quote should transcend the entire investigation and
prosecution process. Indeed, it is arguably most imperative at the investigation stage, at which point
law enforcement is dealing with a presumptively innocent citizen.
In summary, we understand the allegations against Mr. Epstein to be that Mr. Epstein paid
individuals to find friends and acquaintances, certain of whom were under the age of 18, to provide
topless massages to him at his Palm Beach home in exchange for money. Mr. Epstein's assistants
allegedly scheduled these massages for him over the telephone at the direction of Mr. Epstein,
allegedly including some scheduling calls to underage women. However, the evidence contradicts
these allegations. First, Mr. Epstein did not ask that the masseuses be under the age of 18. To the
contrary, he specifically asked that they be 18 or older. As one witness commented,
said tell
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=== Page 3 ===
ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 3
them you're 18 because if you're not, he won't let you in his house."
Tr. at 38-39.
Second, Mr. Epstein himself did not schedule such appointments. Third, Mr. Epstein would not
know who would be providing a massage at any particular time. Fourth, and importantly, Mr.
Epstein's assistants were not directed to contact underage women, and were not aware of the true
ages of the women they contacted. In fact, more often than not, the masseuses themselves, or the
individuals who introduced the masseuses, made the initial contact. As a result, Mr. Epstein and his
assistants were routinely unaware of the identities of many of these young women before they
arrived.
The allegations further include the assertion that Mr. Epstein engaged in unlawful sexual
conduct with certain underage women who arrived at his house to provide a massage. At times,
during these massages, Mr. Epstein masturbated, engaged in some sexual touching, and a small
number of alleged acts of penetration. However, most of the women who performed massages on
Mr. Epstein were over the age of 18. Many of the young women have sworn under oath that they, in
fact, told Mr. Epstein that they were 18 or older, and that they did so because they knew that if they
were not 18 years old, they would not be allowed into Mr. Epstein's home. In fact, Mr. Epstein has
passed a polygraph examination to this effect relative to the government's primary, and youngest,
alleged victim,
Indeed, many of the women also worked at local massage parlors,
which presumably had a requirement that the masseuse have reached the age of majority. To the
extent there are allegations that Mr. Epstein should have been alerted to certain underage women
based on conversations he allegedly had with them, those conversations would have taken place in
person and at his home, thereby precluding any prior scheduling with knowledge of their true ages.
As explained below, any factual allegations of repeat massages with such persons would lack
necessary elements required for a federal nexus to such conduct.
All of the alleged activity occurred in Mr. Epstein's home in Palm Beach, Florida. Many of
the massages allegedly involved conduct which, even if engaged in, is not proscribed by federal law,
either because the masseuses were of age, or because conduct with underage masseuses only
involved topless massages, massages in undergarments or naked massages. To the extent prohibited
sexual activity occurred, any inducement, enticement, and/or persuasion used would have taken
place during a face-to-face encounter-thus eliminating the possibility for the commission of a
federal crime, which requires the existence of a communication through a facility of interstate
commerce in which the defendant persuades or entices the minor to engage in illegal sexual activity.
Furthermore, any prohibited sexual activity that did occur based on the facts on the record is best left
to the state to address because the facts of this case do not fall comfortably within the federal
domain.
This is a case about purely local activity, involving local actors, and affecting local
interests and thus, should be handled by local authorities. Nonetheless, the USAO has indicated
its intent to prosecute Mr. Epstein for purported violations of 18 U.S.C. §§ 2422, 2423, and
1591. However, as set forth in detail in prior submissions, the facts of this case fall squarely
outside the heartland of those statutes - in fact, in law, and in congressional intent. As their plain
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ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 4
text and history indicate, these statutes were designed to address problems that are truly national
and international in scope: human trafficking in $ 1591; telephone or Internet sexual predation in
§ 2422; and sex tourism in $ 2423. Unlike the alleged conduct at issue here, those problems
unquestionably present multi-jurisdictional obstacles that States and localities cannot confront
effectively on their own. Mr. Epstein's conduct was purely local in nature, and the State of
Florida and Palm Beach County are effectively prosecuting and punishing that conduct.
Although CEOS asserts, "that a prosecution of Mr. Epstein might not look precisely like the
cases that came before it is not dispositive" (CEOS letter at p. 4), the fact is this case does not look
anything like those cases. The facts here do not carry any of the hallmarks that typify an appropriate
federal prosecution for child exploitation as reflected in all such prior federal prosecutions.
Specifically, the facts here do not carry the hallmarks for a sex trafficking or child prostitution
prosecution. Mr. Epstein did not target minors. In fact, the evidence indicates just the opposite.
There was no travel in interstate commerce for the purpose of engaging in illicit sexual activity.
There was no prohibited use of a facility of interstate commerce. There was no commercial for profit
sexual enterprise. There was no force. There was no violence. There was no use of drugs or
alcohol. There was no child pornography.
18 U.S.C. § 1591 is clearly designed to combat organized rings of individuals who engage in
the business of human trafficking, involving both a commercial and coercive component. As
President Bush has noted:
generally speaking, trafficking in persons refers to actions, often including the use of
force, fraud or coercion, to compel someone into a situation in which he or she will
be exploited for sexual purposes, which could include prostitution or pornography, or
for labor without compensation, which could include forced or bonded labor
trafficking in persons is often linked to organized crime, and the profits from
trafficking enterprises help fund other illegal activities. The growth of vast
transnational criminal networks supported in part by trafficking in persons fosters
official corruption and threatens the rule of law. 2
This in no way describes the case here. Yet the USAO has been unwavering in its single
minded focus to stretch the limits of these federal statutes beyond their intended use, and beyond
precedent, in order to prosecute Mr. Epstein. As the CEOS letter acknowledges, the legal theories
the USAO intends to attempt to pursue against Mr. Epstein are "novel," having never before been
sanctioned by federal law. They should not be sanctioned now. As the Supreme Court recently
pronounced, when a statutory term in a criminal statute could support both a narrow or broad
application of the federal criminal law, "the tie must go to the defendant." United States V. Santos,
553 U.S.
and Cuellar V. United States, 553 U.S
(June 2, 2008), Slip Op. at 6.
2 February 25, 2003 Trafficking in Persons National Security Presidential Directive.
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ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 5
A full and fair review of the facts here is critical to this analysis. Yet, it is clear that CEOS
did not conduct such a review. In his recent letter to Jay Lefkowitz, First Assistant United States
Attorney ("FAUSA")
confirmed our understanding that the USAO was to have
"facilitated" an "independent de novo review of the investigation" by the Department. (May 19,
2008 Sloman letter at p. 5). Yet, the CEOS review was not complete, and by its own terms not de
novo.
As CEOS itself noted, "our review of this case is limited both factually and legally. We have
not looked at the entire universe of facts in this case. It is not the role of the Criminal Division to
conduct a complete factual inquiry from scratch." (CEOS letter at p. 1). Indeed, entire subject areas
relevant to the inquiry were not considered at all by CEOS. In essence, CEOS was only in a position
to make the most cursory possible review, an "abuse of discretion" review, without considering the
facts at the necessary level of detail, and without taking into account the many and varied issues of
misconduct we have raised in this case. As the CEOS letter indicates, "we did not review the facts,
circumstances, or terms included in the plea offer nor any allegations that individuals involved in the
investigation engaged in misconduct." (CEOS letter at p. 2). All of this begs the question - if it is
not CEOS' role to "conduct a complete factual inquiry," and CEOS did not consider any of the
allegations of misconduct here, which at the very least have created a strong appearance of
impropriety, and, at worst evidence an intent and effort to unfairly prejudice Mr. Epstein to the
financial benefit of the friends and colleagues of the prosecution team in the USAO, then where and
when can justice ever hope to be served in this case? This is a prosecution burden that cannot, and
should not, be brushed aside.
We contend the limited nature of the CEOS review deeply affected its conclusions. For
example, CEOS most likely did not review original documents, such as transcripts, and instead relied
on the summaries of federal prosecutors and FBI agents, against whom we have raised serious
concerns regarding misconduct. If the summary memos from the USAO are as flawed as other
USAO communications have been, and which we have been able to show are misleading and
inaccurate, the CEOS abuse of discretion review is likely flawed as well. Moreover, although the
USAO expected, and personally promised to us, an independent review, FAUSA
letter also
makes clear that our pivotal legal challenge to the use of 18 U.S.C. $ 2422(b) had already "been
previously raised and thoroughly considered and rejected by
CEOS prior to" the recent CEOS
review. (May 19, 2008 Sloman letter at p. 5). The fact that CEOS had to evaluate its own decision
with respect to some of the allegations against Mr. Epstein prevents its subsequent review and
opinion from being truly independent.
Following this most recent CEOS review "limited both factually and legally," and with no
citation to any case law relative to the statutes in question, CEOS concludes merely, "federal
prosecution in this case would not be improper or inappropriate (CEOS letter at p. 5);" in essence,
that the United States Attorney could bring this case in the exercise of his federal discretion should
he so choose ("we conclude that U.S. Attorney Acosta could properly use his discretion to authorize
prosecution in this case."). (CEOS letter at p. 2). However, CEOS drew the conclusion that the
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ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 6
federal prosecution of Mr. Epstein would not be "improper or inappropriate" absent any review at all
of the misconduct here, and absent a full review of the facts and law. The facts, the law, and the
alleged misconduct are each necessarily inextricably intertwined with the question of whether or not
this is a viable federal prosecution. These imposed limits flawed the review from the outset. In any
event, CEOS concedes that the defense team makes "many compelling arguments." (CEOS letter at
p. 5). In the end, then, one is left with the impression that the CEOS review and opinion, although
concluding that the USAO could push forward at its own discretion, is a much qualified one.
The federal prosecution of Mr. Epstein has been a moving target from the inception. Each
time the allegations, the witnesses or the applicable law is subject to a searching inquiry, we have
found that the allegations have been misrepresented, the law does not apply to the actual facts here,
and the USAO prosecution theory falls apart. Yet, in the face of the voluminous evidence we have
submitted in this regard, while acknowledging that the theories are "novel," and that our arguments
against federal prosecution are "compelling," CEOS concluded, "Mr. Acosta could rightfully
conclude that this federal issue is best resolved by a jury" and that "the USAO has a good faith basis
to fully develop the facts on this issue and brief the law to permit a court to decide whether the law
appropriately reaches such conduct." With all due respect, and recognizing that CEOS may be - and
apparently was - limited in its authority, it should not be the prerogative of the prosecution arm of
the United States government to simply roll the dice, and let the court system just sort it out when
dealing with the life and liberty of a United States citizen. The Department of Justice should not be
so cavalier when labeling someone as a child molester. While it may be within the discretion of the
USAO to do so, it is not in accord with the principles of justice.
Indeed, as noted, just a few weeks ago, the Supreme Court underscored this point in Santos
and Cuellar. The Court made clear that prosecutorial discretion does not provide the USAO cart
blanche to expand criminal statutes as they seek to do here with complete disregard for congressional
intent. The Court rejected speculation as a basis of determining the scope of a criminal statute;
"probability is not a guide which a court, in construing a penal statute, can safely take." Slip op. at 7,
quoting United States V. Wiltberger, 5 Wheat. 76,105 (1820). "We interpret ambiguous criminal
statutes in favor of defendants, not prosecutors." Slip op. at 12.
Based on my experience, I believe that the facts here do not warrant a federal child
exploitation prosecution. At its core, this case is quintessentially a state concern as opposed to
implicating any federal interest. Indeed, the Florida State Attorney's Office ("SAO"), led by the
chief of the Sex Crimes Division, thoroughly investigated this matter, and presented it to the grand
jury. The facts, as opposed to the deeply flawed press reports, were carefully assessed by
experienced State prosecutors who aggressively enforce State criminal laws. Following an extensive
15-month State investigation, Mr. Epstein was indicted by a State grand jury on a single felony count
of solicitation of prostitution.
During the investigation, the State prosecutor exhaustively reviewed the evidence, met face-
to-face with many of the alleged victims, considered their credibility - or lack thereof - and
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ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 7
considered the extent of exculpatory evidence, including a psychosexual evaluation of Mr. Epstein
and a polygraph examination demonstrating that Mr. Epstein genuinely believed at the time of the
alleged conduct that the State's key witness
-
) was over the age of 18. Then, after
months of negotiations, the State reached what it believed was an appropriate resolution of the case.
Importantly, this resolution was consistent with that of cases involving other defendants who had
engaged in similar conduct. Implementation of the State resolution of the case was held in abeyance,
however, due to the unexpected commencement of the successive federal criminal investigation.
While it is true, as CEOS points out, (CEOS letter at p. 3) that many criminal prosecutions
turn on issues of credibility of witnesses, to which many members of the defense team can attest
(having had decades of federal criminal litigation experience among us), this does not serve to divest
the prosecutor of his/her duty to make a searching inquiry of the facts before using the power of
prosecution, and the weight of the United States government, to level serious accusations. CEOS
likewise acknowledges as much, "the prosecutors are in the best position to assess the witnesses'
credibility." (CEOS letter at p. 3).
Since the CEOS letter also singles me out as someone who should be familiar with witness
issues, I feel compelled to note that, of course, I am well aware that it is not uncommon for witnesses
to give conflicting statements. I am also fully aware that the credibility of key government witnesses
may be strongly impacted by the $50 million incentive provided via the civil lawsuits at play, and
encouraged by the government here. 3 I have also read many of the conflicts between witness
testimony and Detective
own rendition of that testimony in his reports and/or search
warrant affidavit. Detective
apparently formed a view early on as to the purported
criminality of Mr. Epstein's conduct regardless of the mountain of evidence to the contrary. For a
prosecutor that has had an opportunity to review the full facts, and to meet with the witnesses,
however, "conflicting statements" cross the line to a "lack of credibility" that simply can not sustain
a prosecution. That is where an appropriate application of prosecutorial discretion must be brought
to bear.
Again, CEOS was not itself in the position to exercise such discretion. By its own admission,
CEOS did not make a full review of the witness statements here, and CEOS certainly did not sit
down across the table and speak to these witnesses. We understand that was apparently not its
perceived role. But, CEOS should recognize that at least one prosecutor in this case - the Chief of
the SAO Sex Crimes Division has done so. Lana Belohlavek not only met with and interviewed
these witnesses during the course of the 15-month state investigation prior to any federal
involvement, but she again sat across the table from many of them in connection with recent civil
3 It is important to note here that this investigation was launched not upon the complaint of any alleged victim, but,
rather, upon the complaint of
father,
and her stepmother.
More
notable still is the fact that
has been convicted of federal bank fraud, and
has a state
conviction for identify fraud. Hardly pillars of credibility. Yet, the USAO did not supply this information to the
defense. Even more telling is the fact that Mr.
filed a $50million lawsuit purportedly on behalf of his
daughter without her authority or knowledge.
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Mr. John Roth
June 19, 2008
Page 8
depositions in this matter. Ms. Belohlavek, and the SAO, is likewise well familiar with the breadth
of the federal investigation, and has integrated that knowledge into the current enhanced state
sentencing recommendation. The SAO remains firm in the position that the proposed state resolution
is a sound one, and that there was no child exploitation here. Notably, however, not once during the
pendency of the federal investigation has the USAO ever reached out to its state prosecutive
counterpart that initiated this investigation in the first place to discuss the issues or to thoroughly
ferret out the facts or the witness credibility issues.
In the eight lines the CEOS letter accords to the topic of witness credibility CEOS asserts,
"there are multiple mutually-corroborating witnesses," (CEOS letter at p. 3). However, the CEOS
letter does not highlight a single one. In contrast, we have put forth numerous "mutually
corroborating" witness statements. Far from supporting a federal prosecution, these statements
instead corroborate that 1) the alleged victims lied to Mr. Epstein about their age; 2) there was no use
of a facility of interstate commerce by Mr. Epstein; 3) there was no inducement or coercion; 4) there
was no commercial enterprise; and 5) there was no illicit sexual conduct.
Indeed, Mr. Epstein took several steps to ensure that no minors entered his home, most
notably, by affirmatively asking the women whether they were actually 18. See e.g.
Tr. At
38-39. That fact - which many of the potential witnesses have confirmed in sworn interviews -
strongly indicates that Mr. Epstein specifically intended to preclude anyone under 18 from giving
him a massage. That fact is confirmed by, among other things,
testimony that "he
likes the girls that are between the ages of like 18 and 20
"
Tr. at 12. In fact, the
evidence bears out that the majority of the women who came to Mr. Epstein's residence to provide a
massage were over 18.
Many of the young women who were aged 16 and 17 visited Mr. Epstein's residence only
once or twice, and the evidence strongly shows that they lied to Mr. Epstein about their age. Two of
these individuals,
and
were 14 and 15 at the time they met Mr.
Epstein. Given that each has brought a civil lawsuit against Mr. Epstein, with Ms.
and her
family seeking $50 million from Mr. Epstein, their testimony against Mr. Epstein is per se suspect.
But, despite their obvious incentive to harm Mr. Epstein, their testimony actually confirms his
innocence. Ms.
, for instance, has testified that Ms.
, who introduced her to Mr.
Epstein, expressly told her to lie to Mr. Epstein about her age.
Q:
And
told you that if you weren't 18 Epstein wouldn't let you into his house,
right?
A:
That's - yes, yes.
Tr. (deposition) at 32.
Q:
You didn't want Mr. Epstein to know that you were lying about your age, right?
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Mr. John Roth
June 19, 2008
Page 9
A:
Correct.
Q:
You didn't want Mr. Epstein to know that you were not 18 yet, right?
A:
Correct.
Tr. (deposition) at 36.
In fact, Ms.
told Mr. Epstein that she was 18 years old, and confirmed this fact with
Palm Beach Police. Id. at 36. Beyond that, Ms.
"swore on her mother's grave" that she
and Mr. Epstein did not engage in sex of any kind.
Tr. (deposition) at 24. She further
repeatedly explained that prior to the time she went to Mr. Epstein's house (she went there only
once), nobody ever tried to coerce her to engage in sexual activity with Mr. Epstein. Not over the
telephone, not over the Internet, not at all.
Tr. (deposition) at 31-32. These are not facts
upon which a federal case can stand.
Ms.
age was also unknown to Mr. Epstein when she went to his home.
, who was introduced to Mr. Epstein by Ms.
, testified in her federal sworn interview
that Ms.
told her to lie to Epstein. See
Tr. at 8 ("she just said make sure you 're 18
because Jeffrey doesn't want any underage girls") (emphasis added). Ms.
testimony
strongly suggests that Ms.
lied to Mr. Epstein about her own age as well. Ms.
also self represented that she worked at a local erotic massage parlor that presumably required a
minimum age.
The conduct of
is likewise illustrative of "mutually corroborating" testimony
which supports the fact that this is not an appropriate federal case. In the same way that Ms.
was referred to Mr. Epstein and brought to his home without having been introduced or
acquainted in any manner, Ms.
was referred by someone else,
, who also told
her to lie to Mr. Epstein about her age, which she did.
Tr. at pp. 8-9).
CEOS seeks to buttress the USAO prosecution by asserting "it is possible to satisfy that
element [proof of specific intent as to the age of the alleged victims] with proof that the defendant
was deliberately ignorant of facts which would suggest that the person was a minor." (CEOS letter
at p. 2). Such assertion is counter to the law and to the facts. Reliance on a deliberate ignorance
standard as to any of the three statutes in issue requires the factual predicate of an intent not to learn
of an incriminating fact. This is the antithesis of the factual context of this case where there is
repeated proof that the minors believed that they had to lie because Mr. Epstein had an actual
practice of attempting to verify age, and would not let them in his house if they were under the age of
18. See United States V. Kennard, 472 F.3d 851, 857-858 (11th Cir. 2006), quoting, United States V.
Puche, 350 F.3d 1137, 1149 (11th Cir. 2003) (An instruction on deliberate ignorance is appropriate
only if it is shown [among other things]
that the defendant purposely contrived to avoid learning
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=== Page 10 ===
ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 10
of all of the facts in order to have a defense in the event of a subsequent prosecution."). Thus, the
facts preclude reliance on the concept of deliberate ignorance as a substitute for proof.
The fact that the search warrant affidavit in this case is rife with mis-statements and
omissions regarding the key element of age is critical. However, CEOS concludes with no apparent
supporting analysis, "despite the numerous factual errors you describe, the U.S. Attorney's Office
could still plausibly argue that the mistakes - whether inadvertent or intentional - were not material
to
the determination (CEOS letter at p. 3). Although, as CEOS notes, there are "numerous"
such misrepresentations, through affirmative statement or intentional omission, a focus on but one of
those misrepresentations highlights that such misrepresentations were, in fact, material. The fact is
that Detective
grossly misrepresented Mr. Epstein's intent as it related to the age of the
women he permitted entry to his residence.
In the search warrant affidavit, Detective
affirmed that
claimed:
[Mr. Epstein] told her the younger the better.
And,
stated she once tried to bring a 23 year old female and Epstein stated that the
female was too old.
What Detective
, no doubt intentionally, omitted was
s further explanation,
which rendered Mr. Epstein's comments innocuous:
A:
Let me put it this way, he - I tried to bring him a woman who was 23 and he didn't
really like it.
Q:
He didn't go for it?
A:
It's not that he didn't go for it. It's just that he didn't care for it. And he likes the
girls that are between the ages of 18 and 20.
-
Statement at 12) (emphasis
added).
Had that critical information, information that turns allegedly illegal conduct into more
innocent conduct, been included, it would have seriously undermined the probable cause for the
search warrant.
Similarly, and equally problematic, Detective
did not include the many statements
demonstrating that, when asked by Mr. Epstein, the women affirmatively misrepresented their ages
as being 18, and/or that Mr. Epstein was not aware of their true ages. Indeed, although Detective
did note that Ms.
told Mr. Epstein that she was 18, he omitted from the affidavit
the key point as to why she lied:
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=== Page 11 ===
ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 11
said tell him you're 18 because if you're not, he won't let you in his house.
So I said I was 18. As I was giving him a massage, he was like how old are you.
And then I was like 18. But I kind of said it really fast because I didn't want to make
it sound like I was lying or anything.
Tr. at 38-39.
Thus, consistent with the guidance provided in Franks V. Delaware, 438 U.S. 154 (1978), the
search warrant affidavit in this case reveals knowing and reckless falsehoods and omitted material
information. This is precisely the type the United States Supreme Court sought to guard against.
The age of the alleged victims, and of Mr. Epstein's intent in that regard, is an element of the
crimes that must be proven in order to sustain a conviction. In particular, $ 2422(b) requires that the
defendant specifically intended to target a minor. See, e.g., United States V. Murrell, 368 F.3d 1286
(11th Cir. 2004) ("[T] prove an attempt the government must first prove that [defendant], using the
internet, acted with a specific intent to persuade, induce, entice, or coerce a minor to engage in
unlawful sex.") (Emphasis added). Section 2422(b) expressly requires that the crime be committed
"knowingly," and that requisite mental element applies as to each element of the crime. United
States V. XCitement Video, Inc., 513 U.S. 64, 68-69 (1994); United States V. Meek, 366 F.3d 705,
718 (9th Cir. 2004); United States V. Root, 296 F.3d 1222, 1227 (11th Cir. 2002); United States V.
Bailey, 228 F.3d 637, 638-639 (6th Cir. 2000). How, then, could the USAO "plausibly argue" that a
misrepresentation about an element of the crime could be viewed as "not material"? If the elements
of the alleged crime are not met, there is no probable cause to sustain the search warrant in the first
instance. If the elements are not met, there is no federal crime. That is material.
Moreover, it is clear from the plaint text of the statute that the statutorily proscribed act
pursuant to 18 U.S.C. 2422(b) is the actual use of a facility of interstate commerce to persuade,
entice, induce, or coerce. "The underlying criminal conduct Congress expressly proscribed in passing
2422(b) is the persuasion, inducement, enticement, or coercion of the minor rather than the sex act
itself. That is, if a person persuaded a minor to engage in sexual conduct (e.g., with himself or a third
party) without then committing any sex act himself, he would nevertheless violate $2422(b)." United
States V. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004). See also, United States V. Bailey, 228 F.3d
637, 639 (6th Cir. 2000) ("Congress has made a clear choice to criminalize persuasion and the
attempt to persuade, not the performance of the sexual acts themselves."). Thus, if there has been
sexual misconduct (which we deny) without the requisite persuasion, there is no violation of this
federal law.
The investigation and testimony in this case makes clear that Mr. Epstein did not use any
facility of interstate commerce to commit any act forbidden by 18 U.S.C. § 2422(b)-to persuade,
induce, entice, coerce-nor did he direct any of his assistants to do so. Indeed, by way of example,
was clear on this point at her deposition during which she repeatedly testified that
nobody-not Mr. Epstein or any of his assistants-ever used the Internet or phone in any way to try
to persuade her to engage in sexual activity with Mr. Epstein.
Tr. (deposition) at 31-32.
Nonetheless, even assuming, arguendo, that persuasion to engage in sexual conduct occurred over
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=== Page 12 ===
ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 12
the telephone (which we deny), it is black letter law that the mens rea must coincide with the actus
reus. Thus, the government must prove that Mr. Epstein has the specific intent to target a known
minor to engage in prohibited sexual activity at the time of the call. We have seen zero evidence of
this. To the extent Mr. Epstein later may have persuaded a particular individual to engage in
unlawful sexual activity during a massage, such persuasion occurred face to face, and can not work
retroactively to render the earlier phone call an offense under the statute.
As to the purported violation of 18 U.S.C. $ 2423 for allegedly traveling in interstate
commerce for the purpose of engaging in illicit sexual activity, CEOS does not deny that Mr. Epstein
was returning to one of his residences when he traveled to Florida. CEOS explicitly stated it "fully
understand[s] our argument" (CEOS letter at p.2) that Mr. Epstein should not be charged under
$ 2423(b) because the dominant purpose for his traveling to Palm Beach was not to engage in illegal
sexual activity, but to simply return to one of his residences. Rather, this is apparently another
"compelling" point of law which may be left to "a court to decide whether the law properly reaches
such conduct." (CEOS letter at p. 2). Notably, implicit in this concession by CEOS is that the law
has never before been so applied, that is, there is no precedent for a court to extend the statute as the
USAO seeks to do here. In fact, the United States Supreme Court prohibited the criminalization of
travel under identical circumstances over a half century ago. See, Mortenson V. United States, 322
U.S. 369, 374 (1944) (intention to engage in proscribed conduct must "exist before the conclusion of
the interstate journey and must be the dominate motive of such interstate movement." (Emphasis
added.)
Beyond an absence of proof regarding the travel element in connection with 18 U.S.C. $2423,
the requisite age requirement for a violation of that statute is important. 18 U.S.C. $2423, by
reference to Chapter 109A (18 U.S.C. §2423(f)(1)), specifically defines a minor for purposes of that
statute as an individual who has not attained the age of 16. If an alleged victim is 16 years of age or
older, a violation of this statute pursuant to 2423(f)(1) can only occur if it can be proven that force,
threat or drugs were involved. See, 18 U.S.C. §§ 2241 et seq. There are no such allegations here. As
a result, in order to find a violation under 18 U.S.C. § 2423, the United States would have to prove
that Mr. Epstein engaged in one of the sexual acts defined at 18 U.S.C. $ 2246(2) with an individual
under the age of 16, and that he formed the intent and dominant purpose to do so prior to the time he
made a return trip to Florida. Again, there is no such evidence here. Ms.
has specifically
testified that 1) she never engaged in sexual activity with Mr. Epstein; 2) she never even met or
talked to Mr. Epstein prior to her arrival at his house; and 3) she lied about her age not only to Mr.
Epstein, but, in fact, to the world on her MySpace page when she said that she was 18 years old. It is,
then, also worth noting in this regard that 18 U.S.C. $2243(c) provides an affirmative defense if
proven by a preponderance of the evidence if Mr. Epstein reasonably believed that Ms.
was
4 In addition to his residence there, Mr. Epstein also has several businesses, and personal matters and contacts to which
he attends in Florida. For example, beginning in 2002, Mr. Epstein visited his mother nearly every weekend in Palm
Beach until she passed away in April, 2004.
5 As previously set forth herein, and as more fully explained in other submissions related to this case, the recent
Supreme Court decisions in Santos and Cuellar make this attempted stretch of the law improper.
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=== Page 13 ===
ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 13
had attained the requisite legal age. Finally, although 18 U.S.C. 2423(f)(2) also defines "illicit
sexual conduct" as any commercial sex act with a person under the age of 18, 18 U.S.C. 23(g)
also provides a specific affirmative defense as to that age element if proven by a preponderance of
the evidence that Mr. Epstein reasonably believed that the young women had attained the requisite
legal age. As we have demonstrated, time and again the women involved lied to Mr. Epstein as to
their true age, representing that they were, in fact, over the age of 18. Many of them also represented
that they worked at local massage parlors, which presumably would have imposed a legal age
requirement.
Lastly, in contrast to 18 U.S.C. $1591, Mr. Epstein's conduct did not involve trafficking of
women or children in the sex industry, and was not part of any phenomenon that, in the aggregate,
had an economic impact on interstate or foreign commerce. Additionally, Mr. Epstein did not
benefit financially from the alleged conduct. Therefore, as the SAO determined, and still believes,
Mr. Epstein was a customer, a "John" for whom prosecutions are best left to the State to address.
Indeed, there is no reported precedent extending federal law to a local "John" who does not violate
the child exploitation statutes. Indeed, CEOS does not point to a single case where federal
prosecutors have used $ 1591 in a case involving facts like these. Instead, every $ 1591 prosecution
has involved national or international sex trafficking and/or for-profit prostitution rings, involving
the knowing use of minors and/or forcible coercion, or forcible rape, physical abuse or intimidation.
These are the elements required by the statute, and they are not met here.
Although CEOS could, perhaps, point to United States V. Evans, 476 F.3d 1176 (11th Cir.
2007) as a case that, standing alone, involved wholly intrastate conduct, the facts of that case are far
different in key respects than this one. The Evans case involved both the commercial and coercive
components that Congress, and administration policy statements intended in 18 U.S.C. $ 1591
prosecutions. Evans, and his co-conspirators (Madison and Yearby) were not "Johns." They
operated a for profit prostitution ring marked by control of, and extreme violence toward, the
victims, who they knew were underage. Indeed, Evans forced one such victim, age 14 years old, to
continue to work even after she had been hospitalized with AIDS. As part of their business, Evans
and his co-conspirators provided the victims with cell phones, hotels, and condoms, and the victims
were forced to give all of their money from this prostitution ring to Evans and his co-conspirators.
None of this type of activity comes close to the facts regarding Mr. Epstein. Finally, but significantly,
the prostitution ring in Evans was not, in fact, entirely intrastate as the companion case of one of the
Evans co-defendants makes clear. See, United States V. Madison, 477 F.3d 1312, 1313-1314 (11th
Cir. 2007) (Jane Doe #2 stated that she traveled to Atlanta, Georgia with Madison to work as a
prostitute).
Thus, courts, including the Eleventh Circuit in Evans, have underscored the point that $ 1591
simply is not intended to cover the kind of alleged conduct at issue here. "Section 1591 does not
criminalize all acts of prostitution (a vice traditionally governed by state regulation). Rather, its
reach is limited to sex trafficking that involves children or is accomplished by force, fraud, or
coercion." United States V. Evans, 476 F.3d at 1179 n. 1; See also United States V. Sims, 171 Fed.
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=== Page 14 ===
ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 14
Appx. 849, 2006 WL 14581 at *3 (11th Cir. 2006) (to establish Sims's guilt on the sex trafficking of
a minor count, the government had to show that Sims benefited financially from Owen's sexual
activity and that Sims knew that (a) force or coercion would be used to cause Owens to engage in a
criminal sex act or (b) that Owens was under the age of 18.) (emphasis added). Again, none of these
factors is present in this case. The Eleventh Circuit's interpretation of the statute makes perfect
sense: were $ 1591 not limited in this fashion, it would threaten to criminalize a host of localized
behavior that has nothing to do with human trafficking, and, thus, is of no valid federal interest.
In sum, to accord discretion to the USAO, albeit without benefit of the requested full de novo
review, to exercise authority to pursue a prosecution which involves a "novel" application of three
federal statutes in the face of numerous "compelling arguments" is not warranted, as it is not
supported by the facts, the law, or justice. Echoing the admonition of the Supreme Court in the
Berger decision, the Comment to Rule 3.8 of the Rules of Professional Conduct (Special
Responsibilities of a Prosecutor), says it best "A prosecutor has the responsibility of a minister of
justice and not simply that of an advocate. This responsibility carries with it specific obligations to
see that a defendant is accorded procedural justice and that guilt is decided upon the basis of
sufficient evidence." This is a responsibility that can not be taken for granted. The government bears
the burden of assuring that it possesses sufficient evidence to prove each element of a crime with
respect to some specific victim before publicly branding Mr. Epstein a child molester. In this case,
however, the USAO has not met its burden for any victim for any of the crimes alleged. It is not
enough to simply gloss over the required proof, and rely on the jury or the court to just sort it all out
in the end. The stakes are too high. As a result, the USAO should not be permitted to pursue an
unfounded federal criminal case against Mr. Epstein under the guise of prosecutorial discretion.
Such prosecution in this case necessarily would appear to be selective to Mr. Epstein. To be
clear, our request that Mr. Epstein should not be prosecuted federally would not permit him to go
completely unpunished, but, rather, would simply place him in the same prosecution position as
others similarly situated. Therefore, we continue to believe that after a complete, de novo, and
independent review, the only appropriate conclusion will be that this case is best left to the state to
resolve.
Very truly yours,
Stephanie Thacker
STEPHANIE D. THACKER
SDT/kdt
Enclosures
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=== Page 1 ===
Event: call with USA of NDGA re: Epstein
Start Date: 2019-03-07 18:00:00 +0000
End Date: 2019-03-07 18:30:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2019-03-05 21:40:46 +0000
Date Modified: 2019-03-05 21:40:46 +0000
Priority: 5
DTSTAMP: 2019-03-05 21:28:44 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
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From:
(USAFLS)"
To:
(USAFLS)"
Subject: Out of Office AutoReply: Emailing:
Supplemental Declaration.wpd re Epstein
Date: Fri, 19 Dec 2008 21:10:45 +0000
Importance: Normal
I will be on annual leave from December 19-30, 2008. If you need to reach me, please call me at
Thanks.
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From:
To:
Subject: Mark Epstein Meeting
Date: Mon, 28 Oct 2019 23:42:13 +0000
Importance: Normal
Attachments: unnamed
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From:
To:
Cc: "Acosta, Alex (USAFLS)"
Subject: RE: Epstein
Date: Fri, 16 Nov 2007 18:31:42 +0000
Importance: Normal
Hi all - The FBI had their meeting with the ASA this morning. She wasn't aware of the December 16th date, and
she said that she could include something in their plea agreement about not being eligible for work release.
When the FBI asked her if she would do that, she said she would have to talk to
She also wouldn't say
whether they would oppose such a petition, if one were filed.
said that because Epstein is going to be
housed at the jail, the Sheriff's Office will determine whether Epstein is eligible for work release, not the Florida
Department of Corrections. I have asked FBI to find out whether "sexual predators" (which will be Epstein's
legal designation) are eligible to participate in work release. I am still reviewing all of the statutes to see whether
there is anything that would bar the judge from granting a petition for work release. As soon as I find an answer,
I will let you know.
ould still like us to do the victim notifications. The State does not have a procedure (like we do
federally) where the Court has to provide a separate room for victims who want to attend judicial proceedings, so
I do not know how many victims will actually want to be present.
As soon as you hear from Judge Davis, can you let me know? It is going to take us a while to track down
everyone, especially with the holiday, and I want to make sure they have been provided adequate notice.
Thank you.
From:
Sent: Thursday. November 15. 2007 6:02 PM
To:
Cc: Acosta, Alex (USAFLS)
Subject: Epstein
informs me that
said that the plea & sentencing will take place on the same
day (December 16th) in order to reduce the media frenzy.
said that Epstein will be
treated as a sex offender regardless of whether he registers or not. He said that "registration"
takes place after Epstein completes his sentence. Therefore, he will be treated like any other sex
offender. The problem is that just like any other sex offender, he can petition the court for work
EFTA00013754

=== Page 2 ===
release. When
asked
whether he was going to oppose such a petition,
responded that he will if it is in the agreement.
I spoke to Lefkowitz. Lefkowitz confirmed the above understanding. We did not, however,
discuss anything about work release - just that Epstein will be a sex offender and he'll be
treated like any other sex offender.
Lefkowitz confirmed that they will not contact any other victims. He also asked Jack Goldberger
to provide him with any copies of agreements etc. he has with the State. Jay will forward them
to me as soon as he receives them.
Finally, Lefkowitz said that the statement in his letter that he "reserves [the] right to object to
certain aspects of the $2255 provisions of the Agreement" refers to their belief that a lawyer
who files a lawsuit for some of the class may have a direct conflict that may disqualify him/his
firm if he's accepting fees to negotiate the settlement of the other members of the class.
Lefkowitz point out the potential conflict to whoever is selected. My view is that those issues
are between Epstein's lawyers and the victims' lawyers.
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=== Page 1 ===
From: Joe Nascimento
To:
)"
Cc:
(USANYS)"
)"
Subject: Re:
)
- Epstein
Date: Thu, 19 Aug 2021 23:34:30 +0000
Will do.
Thanks for the recommendation!
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 19, 2021, at 5:40 PM,
)
wrote:
Thanks! Could you please both fill out the attached form? There's a mask mandate in federal buildings regardless of
vaccination status (our team is vaccinated), so we'll all be wearing masks tomorrow. I should mention that the water
fountains at our office don't work (a contamination issue), so you may want to bring water bottles.
For places near the office, I like a small coffee shop called Blue Spoon (76 Chambers Street), which has breakfast.
From: Joe Nascimento
Sent: Thursday, August 19, 2021 5:26 PM
To:
Cc:
(USANYS)
is
Subject: Re:
- Epstein
Yes, we are both vaccinated. She has her card, I have a picture of mine. Any recommendations for breakfast in
the morning near your office?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
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=== Page 2 ===
t.
f.
e.
www.crimlawfirm.com
On Aug 19, 2021, at 5:22 PM,
)
wrote:
Hi Joe,
We're sorting out some logistics for tomorrow related to pandemic protocols. Could you please let me know whether
you and your client are vaccinated?
Thanks,
From: Joe Nascimento
Sent: Monday, August 16, 2021 11:18 AM
To:
Cc:
(USANYS)
is
-
Subject: Re:
- Epstein
Good morning,
We are set to be there this Friday. Please let me know what time you want to start and where we should go.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 5, 2021, at 2:49 PM,
)
wrote:
Thanks, that sounds like a plan. Could you please send me the information below for
travel?
EFTA00010588

=== Page 3 ===
Her full name as it appears on her government-issued ID
Her date of birth
Her home address, cellphone number, and email address
Once I have these details, I can pass them along to our witness coordinator, who can reach out to
to make
arrangements.
Thanks,
From: Joe Nascimento
Sent: Thursday, August 5, 2021 1:18 PM
To:
Cc:
(USANYS)
i
Subject: Re:
)
- Epstein
Great, thanks for working around our schedules. Let's reserve Friday 8/20. Hopefully you can fly
up Thursday
night and she can take a late night flight home Friday to give you all day with her.
Let me know what you need from us. If its easier, feel free to communicate directly with
(
)
to
make travel arrangements.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Wednesday, August 4, 2021 at 10:11 PM
To: Joe Nascimento
Cc:
(USANYS)"
)"
Subject: Re:
)
- Epstein
Hi Joe,
I've confirmed with the agents, and either of those days would work for us. Do you have a preference on
scheduling? Happy to work around whatever works best for your travel schedule.
Thanks,
EFTA00010589

=== Page 4 ===
On Aug 3, 2021, at 7:47 PM, Joe Nascimento
wrote:
Hi
,
I spoke with
and she hopes we can schedule the meeting for the 19th or 20th.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 3, 2021, at 10:03 AM, Joe Nascimento
wrote:
Of course, what time works best for you?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 3, 2021, at 10:02 AM,
)
wrote:
Hi Joe,
Hope you're doing well. Are you available for a brief call this afternoon?
Thanks,
EFTA00010590

=== Page 5 ===
From: Joe Nascimento
Sent: Monday, April 26, 2021 9:53 AM
To:
Cc:
(USANYS)
i
Subject: Re:
- Epstein
Perfect, I received the invite with the link. Unfortunately (or fortunately sometimes) WebEx has been a
part a daily part of my life the past year, so we should be OK. See you all then, let me know if you need
anything further from us in the meantime.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S. W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Apr 26, 2021, at 9:31 AM,
)
wrote:
Hi Joe,
Thanks very much. Let's plan for May 14th at 12 p.m., if that works for you. I'll send a WebEx link for the
videoconference shortly. Please let us know if you have any tech issues/questions about WebEx.
Thanks,
From: Joe Nascimento
Sent: Wednesday, April 21, 2021 1:53 PM
To:
Cc:
(USANYS)
is
)
Subject: Re:
)
- Epstein
Good afternoon,
I spoke with
and she can make herself available the following dates:
EFTA00010591

=== Page 6 ===
May 3, 4 (before 2pm), 5, 6, 12, 13 or 14.
She is going to take the day off of work, so no need to do it after-hours (thank you for the offer). Let me know
if you need additional availability.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
<image001.jpg>
From:
)
Date: Friday, April 16, 2021 at 1:31 PM
To: Joe Nascimento
Cc:
(USANYS)
)
Subject: RE:
)
- Epstein
Thanks very much - let's plan for 9:30 a.m. on Monday, if that works for you. Should I just call your desk line,
or would you prefer a different number?
Thanks,
From: Joe Nascimento
Sent: Friday, April 16, 2021 1:00 PM
To:
Cc:
(USANYS)
i
Subject: Re:
)
- Epstein
Hi Allison,
Yes, I'm free Monday morning between 9:30 and 12 or Tuesday between 11-3. If that doesn't work
for you, I can try to move something around. Let me know.
Have a nice weekend,
Joe
Sent from my iPhone
EFTA00010592

=== Page 7 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Apr 16, 2021, at 11:58 AM,
)
wrote:
Hi Joe,
Hope you're doing well. Are you available for a call sometime early next week? Nothing urgent, but we
wanted to talk with you about potentially scheduling an interview (by video conference) with your client for
sometime in early May.
Thanks,
From: Joe Nascimento
Sent: Monday, March 8, 2021 1:54 PM
To:
Cc:
is
Subject: Re:
- Epstein
Yes, 10:30 works for me. Thank you!
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
From:
)
Date: Monday, March 8, 2021 at 1:32 PM
To: Joe Nascimento
Cc:
)
N
EFTA00010593

=== Page 8 ===
Subject: RE:
)
- Epstein
Hi Joe,
Thanks, hope all is well with you. We're free for a call at 10:30 tomorrow morning, would that work for you?
Thanks,
From: Joe Nascimento
Sent: Monday, March 8, 2021 1:24 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
,
I hope you are well. Please let me know if you have 5 min for a quick call.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 2, 2020, at 11:09 AM,
)
wrote:
Hi Joe,
Thanks for reaching out, we were planning to email you. We continue to appreciate your client's
cooperation with our investigation, and her status from our perspective has not changed. We'll be in touch
going forward,
EFTA00010594

=== Page 9 ===
All the best,
From: Joe Nascimento
Sent: Thursday, July 2, 2020 11:07 AM
To:
Cc:
is
Subject: Re:
-
- Epstein
Good morning,
Hope you are all well. Just wanted to check in after seeing the reports of Ghislaine's arrest.
If
you need anything from us, let us know.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Feb 21, 2020, at 3:53 PM,
)
wrote:
Joe,
We very much appreciated that, and we just wanted to let you know that the lack of communication
separate from that discussion shouldn't be interpreted in any way negatively. We'll certainly be in touch
again when we're able.
EFTA00010595

=== Page 10 ===
thanks again,
From: Joe Nascimento
Sent: Wednesday, February 19, 2020 15:03
To:
Cc:
)
is
Subject: Re:
)
- Epstein
We really appreciate this email. I was able to speak with
a few weeks ago and gave the green light
to share
name and information provided with anyone necessary in your investigation. We will
wait to hear from you if you need anything further.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Monday, February 17, 2020 at 3:40 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Joe,
We just wanted to check in very briefly-we had been hopeful that we'd be able to circle back with you
earlier, but our investigation is currently still ongoing, so at the very least we wanted to let you know that
we continue to appreciate both your client's prior assistance and her willingness to assist in the future.
Nothing in our investigation since we were last substantively in touch has changed our view of your
client, and we hope to be able to be in touch with you in the coming weeks with an update. In the
interim, we do continue to view her status as we've previously conveyed, and please let us know if any
issues arise on your end.
thank you,
EFTA00010596

=== Page 11 ===
From:
Sent: Saturday, November 30, 2019 14:42
To: Joe Nascimento
Cc:
>;
Subject: Re:
)
- Epstein
Hi Joe,
Thanks for checking in-
so no issues on our end, but we
appreciate your following up.
Thanks,
Sent from my iPhone
On Nov 30, 2019, at 8:54 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check-in as
Please let us know if you need anything from us.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
EFTA00010597

=== Page 12 ===
On Sep 9, 2019, at 9:47 PM,
)
wrote:
Joe,
We will meet tomorrow at the same place as last time- the Hilton in West Palm Beach, on
Okeechobee Blvd. My cell is
when you arrive. My colleague,
will be joining us, and he can be reached at
Thanks,
Sent from my iPhone
On Sep 4, 2019, at 10:46 PM, Joe Nascimento
wrote:
Yes, we will be there.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 5:32 PM,
)
wrote:
Hi Joe,
Thanks for letting us know. Let's plan to meet on Tuesday. Would 11:30 work?
Thanks,
EFTA00010598

=== Page 13 ===
From: Joe Nascimento
Sent: Wednesday, September 4, 2019 10:13 AM
To:
Cc:
is
Subject: Re:
- Epstein
Good morning,
Yes, we had to hunker down for 2 days but were spared. Thanks. For next week, the 10th,
11th or 13th work best for me. Look forward to hearing from you.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 10:04 AM,
)
wrote:
Hi Joe,
Hope the storm missed you this week, and that you and your client are doing okay.
Our team is working out some scheduling issues today, and we should know more by this
afternoon. I'll plan to reach out then to discuss scheduling, if that's okay.
Thanks,
Sent from my iPhone
On Aug 30, 2019, at 9:52 AM, Joe Nascimento
wrote:
Good morning,
EFTA00010599

=== Page 14 ===
Just wanted to check in to see if you still planned to travel south given the storm.
Current estimates show a landing (somewhere) Tuesday with very bad weather on
Wednesday. Airports might close (which will answer my question), but that's a guess.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 21, 2019, at 2:40 PM,
)
wrote:
Hi Joe,
Thanks very much, we'll plan to see you then. We'll most likely meet at a conference space at
a hotel in West Palm Beach, and l'll let you know closer in time which location.
Thanks,
From: Joe Nascimento
Sent: Monday, August 19, 2019 6:37 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
,
Both the time and date work for us. Let me know the location when you have it
confirmed.
Thanks,
Joe
EFTA00010600

=== Page 15 ===
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 19, 2019, at 11:11 AM,
)
wrote:
Joe,
Following up on scheduling, we were wondering if your client is available for a proffer on
September 4th. We're flexible on timing that day, but we would propose meeting at 12:30
p.m., if that works.
Thanks,
From: Joe Nascimento
Sent: Wednesday, August 7, 2019 4:53 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
I just wanted to follow up re the August 14th meeting. Is it possible to schedule for early
afternoon (anytime after 1)? I have proactive cooperation ongoing in another case involving
multiple jurisdictions, and they are looking to meet the morning of 8/14. I understand if
your schedule is already set, and will work around it.
Thanks,
Joe
EFTA00010601

=== Page 16 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Friday, August 2, 2019 at 3:34 PM
To: Joe Nascimento
Cc:
)"
,
)"
Subject: RE:
) - Epstein
Joe,
Thanks, much appreciated. If possible, it would be helpful to hold August 14th for a
meeting, and we'll follow up to firm up plans as we get closer. If there are any conflicts with
that date, please let us know, we're happy to be flexible.
Thanks,
From: Joe Nascimento
Sent: Thursday, August 1, 2019 8:10 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
I do not have any travel plans during the month of August, nor does
September is
a busy month with two trials set, and I will be traveling out of the country from Sept 17-30,
but I will do everything to be as flexible as possible.
EFTA00010602

=== Page 17 ===
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, August 1, 2019 at 6:10 PM
To: Joe Nascimento
Cc:
)"
,
)"
Subject: RE:
)
- Epstein
Joe,
As we start thinking about scheduling a next meeting with
we were wondering
if you could please let us know if there are any particular weeks that would not work for
you or your client for a meeting in Florida (in particular, we don't want to interfere with
anyone's summer vacation plans).
We will of course be in touch to talk about a next meeting in more detail, but in the first
instance it would be helpful to get a sense of your schedules, for planning purposes.
Thanks,
From: Joe Nascimento
Sent: Wednesday, July 17, 2019 6:25 PM
To:
Cc:
>;
Subject: Re:
- Epstein
Hi Allison,
That works for me. Please call me on my cell
(
). Thanks.
Sent from my iPhone
EFTA00010603

=== Page 18 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 17, 2019, at 5:58 PM,
)
wrote:
Hi Joe,
Following up, we were wondering if you were available for a call to discuss next steps.
We're available on Friday at 2:30, if that works, but let us know if there are other times
that would be more convenient for you.
Thanks,
From: Joe Nascimento
Sent: Saturday, July 13, 2019 12:39 PM
To:
Cc:
is
Subject: Re:
- Epstein
Good afternoon,
It was a pleasure to meet you yesterday. In light of the recent filing and media reports,
As always, feel free to contact me at any time if we can be of further assistance. Look
forward to meeting again.
EFTA00010604

=== Page 19 ===
-Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
=
Date: Thursday, July 11, 2019 at 9:07 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Hi Joe,
We will be at the Hilton in West Palm Beach, at 600 Okeechobee Blvd. Please call me
when you are here, and we will meet you in the lobby.
Thanks,
From: Joe Nascimento
Sent: Thursday, July 11, 2019 9:02 PM
To:
Cc:
is
Subject: Re:
- Epstein
Good evening,
Have you set a location for our meeting tomorrow?
Thanks,
Joe
Sent from my iPhone
EFTA00010605

=== Page 20 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 10, 2019, at 12:03 PM,
)
wrote:
Thank you, we will plan to see you then in West Palm Beach. We are still
coordinating logistics, and we will let you know that morning the address where
we should meet.
Since we will be traveling, please feel free to call my cell if you need to reach us
for any reason:
Thanks,
Sent from my iPhone
On Jul 10, 2019, at 11:39 AM, Joe Nascimento
<mailto:
wrote:
Of course
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-detectors:/2/0>rd<x-
apple-data-detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-
detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-
detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com/>
On Jul 10, 2019, at 11:34 AM,
)
EFTA00010606

=== Page 21 ===
<mailto:
wrote:
Joe,
Would it be possible to meet earlier, perhaps at noon on Friday? Thank you.
Sent from my iPhone
On Jul 9, 2019, at 10:51 PM, Joe Nascimento
<mailto:
<mailto:
wrote:
,
Can we meet Friday, early afternoon (around 1-1:30)? Please send me your
proffer letter.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors:.//2/0>2250 S.W. 3<x-apple-data-detectors.//2/0>rd<x-
apple-data-detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-
detectors://2/0>
<x-apple-data-detectors.//2/0>Miami Florida 33129<x-apple-data-
detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com
<http://www.crimlawfirm.com/>
On Jul 9, 2019, at 4:56 PM,
)
<mailto:
<mailto:
wrote:
Joe,
We ended up slotting in a few things in the interim, but we're still good for 6:30
for sure.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
EFTA00010607

=== Page 22 ===
Sent: Tuesday, July 09, 2019 16:43
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: Re:
)
- Epstein
Hi
,
I got done a little earlier today - do you want to bump up our call time?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors:/2/0>
Avenue<x-apple-data-detectors://2/0>
Miami Florida 3129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com>
<http://www.crimlawfirm.com/>
On Jul 9, 2019, at 10:02 AM, Joe Nascimento
<mailto:
<mailto:
wrote:
Hi
,
Are you still free for a call?
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com
<http://www.crimlawfirm.com
From:
)"
<mailto:
EFTA00010608

=== Page 23 ===
<mailto:
Date: Sunday, July 7, 2019 at 10:19 PM
To: Joe Nascimento
<mailto:
<mailto:
Cc:
)"
<mailto:
<mailto:
)"
<mailto:
<mailto:
Subject: RE:
)
- Epstein
Joe,
Sure, thanks - and yes, quite the weekend. If it's alright with you, let's do 10:00
a.m. on Tuesday - you can reach us at
,
or we can also call you then
if that's easier, whatever you prefer.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Sunday, July 07, 2019 18:51
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: Re:
)
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you.
Let's set a time for Tuesday morning (the earlier the better for me). Let me know
what works for you.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. <x-apple-data-detectors://2/0>rd<x-apple-data-detectors://20>
Avenue<x-apple-data-detectors.//2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
EFTA00010609

=== Page 24 ===
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com
<http://www.crimlawfirm.com/>
On Jul 7, 2019, at 4:04 PM,
)
<mailto:
<mailto:
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak
with you. I expect our schedules may be somewhat unpredictable tomorrow;
would it work to set a time to talk on Tuesday? We can schedule it for before you
meet with
,
if that's helpful. Or if you'd like to talk sooner, we could
schedule a time later today, or check in tomorrow about a possible afternoon
discussion. Please let us know what you prefer, and we look forward to being in
touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
<mailto:
<mailto:
Sent: Saturday, July 06, 2019 22:55
To:
<mailto:
<mailto:
Subject:
)
- Epstein
Begin forwarded message:
From:
<mailto:
<mailto:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
<mailto:
<mailto:
i
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
Subject:
)
- Epstein
EFTA00010610

=== Page 25 ===
My former partner, Alan Ross, represented
prior to his passing in 2018. Agent
served
with a grand jury
subpoena earlier today, and as Alan's former partner and FL Bar appointed
inventory attorney, she has contacted me. Unfortunately, I am unable to meet with
her until Tuesday, but I would appreciate a few minutes of your time at your
convenience as I am getting up to speed. Please let me know what day/time is
best for you.
Look forward to speaking with you.
Best,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. <x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0>
Avenue<x-apple-data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com>
<http://www.crimlawfirm.com/>
<SDNY COVID-19 Visitor Screening Form 05 04 21.pdf>
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=== Page 1 ===
From:
)"
To
(USANYS)"
Subject: travel request
Date: Sun, 14 Nov 2021 21:02:48 +0000
Attachments: Fact_Witness_Travel_Request_(trial).docx
Hi
Attached is a travel request for a trial witness - he's one of the people we discussed on Friday. He requested if possible
that he stay on a higher floor of a hotel, since he's a
and may need to
remotely while he's here.
Thanks!
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:
=
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To: "
(USAFLS)"
i
(USAFLS)"
Subject: epstein - did u hear anything?
Date: Thu, 02 Aug 2007 13:08:04 +0000
Importance: Normal
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=== Page 1 ===
From:
To:
Cc: "Biase, Nicholas (USANYS)" <Nicholas.Biase@usdoj.gov>, "Margolin, James (USANYS)
[Contractor]" <James.Margolin@usdoj.gov>,
)"
Subject: Re: JE case
Date: Fri, 15 Nov 2019 19:42:15 +0000
Thanks!
Sent from my iPhone
On Nov 15, 2019, at 2:33 PM,
wrote:
Hi
Sure, I'm copying Nick Biase and Jim Margolin from our press office on this email. Thanks.
From:
Sent: Friday, November 15, 2019 2:28 PM
To:
Subject: JE case
Good afternoon,
Could you please provide me with the name and contact information for your press official in charge of handling matters
related to Epstein. I would like to connect them with our Director of Public Affairs, Aja Worthy-Davis, who is responding
to press inquiries for us.
Thanks for your help.
Sincerely,
City of New York
Office of Chief Medical Examiner
520 First Avenue
New York, NY 10016
Web: www.nyc.gov/ocme
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein victims
Date: Tue, 16 Apr 2019 20:18:27 +0000
Importance: Normal
2:00 works for me - I'll send a calendar.
From:
Sent: Tuesday, April 16, 2019 16:12
To:
Cc:
Subject: RE: Epstein victims
Either of those times work for me, thanks.
From:
Sent: Tuesday, April 16, 2019 4:10 PM
To:
Cc:
Subject: RE: Epstein victims
Sure - how is tomorrow at 10 or, alternatively, 2?
From:
Sent: Tuesday, April 16, 2019 4:07 PM
To:
Cc:
Subject: RE: Epstein victims
I think it's probably easier to discuss in real time rather than email, unless you prefer otherwise, but the short answer is
that we keyed in on these individuals as well as another 3-5 or so, for substantially similar reasons as you've identified.
Want to chat about these individuals sometime today or tomorrow?
From:
Sent: Tuesday, April 16, 2019 16:06
To:
Cc:
Subject: Epstein victims
In my earlier review of some of the old Epstein 302s and grand jury testimony, I identified the below names as potentially
significant victim witnesses for various reasons - some being the age, some being conduct that went well beyond
massages, etc. Can you tell me which if any we have attempted to engage and, for those we have not, thoughts on
whether to?
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Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
t.
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=== Page 1 ===
From:
To:
Bcc:
Subject: RE: SDFL - Epstein
Date: Tue, 03 Jun 2008 18:54:38 +0000
Importance: Normal
Yes, please. Thank you!
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
From:
Sent: Tuesday, June 03, 2008 2:54 PM
To:
Subject: FW: SDFL - Epstein
I was also going to send you a hard copy, with fancy tabs. Do you still want?
From:
Sent: Tuesday, June 03, 2008 12:53 PM
To:
Cc:
Subject: SDFL - Epstein
« File: Epstein Itr Ofc of DAG 06 03 08.pdf >> Sent on behalf of First Assistant U.S. Attorney
SDFL. Original signed letter with attachments to follow via Fed Ex.
Staff Assistant
U.S. Attorney's Office
S.D. of Florida
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 1 of 24
ORIGINAL
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA
:
SUPERSEDING INDICTMENT
:
- V. -
:
S2 20 Cr. 330 (AJN)
:
GHISLAINE MAXWELL,
:
:
Defendant.
:
:
X
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
OVERVIEW
1.
The charges set forth herein stem from the role
of GHISLAINE MAXWELL, the defendant, in the sexual exploitation
and abuse of multiple minor girls by Jeffrey Epstein. In
particular, from at least in or about 1994, up to and including
at least in or about 2004, MAXWELL assisted, facilitated, and
contributed to Jeffrey Epstein's abuse of minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were as young as 14 years old when they were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 18.
2. As a part and in furtherance of their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 2 of 24
Epstein's residences in different states, which MAXWELL knew and
intended would result in their grooming for and subjection to
sexual abuse. Moreover, in an effort to conceal her crimes,
MAXWELL repeatedly lied when questioned about her conduct,
including in relation to some of the minor victims described
herein, when providing testimony under oath in 2016.
FACTUAL BACKGROUND
3.
During the time periods charged in this
Indictment, GHISLAINE MAXWELL, the defendant, had a personal and
professional relationship with Jeffrey Epstein and was among his
closest associates. In particular, between in or about 1994 and
in or about 1997, MAXWELL was in an intimate relationship with
Epstein. Additionally, between in or about 1994 and in or about
2004, MAXWELL was paid by Epstein to manage his various
properties.
4. Beginning in at least 1994, GHISLAINE MAXWELL,
the defendant, enticed and groomed multiple minor girls to
engage in sex acts with Jeffrey Epstein, through a variety of
means and methods, including but not limited to the following:
a.
MAXWELL first attempted to befriend some of
Epstein's minor victims prior to their abuse, including by
asking the victims about their lives, their schools, and their
families. MAXWELL and Epstein would spend time building
friendships with minor victims by, for example, taking minor
2
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 3 of 24
victims to the movies or shopping. Some of these outings would
involve MAXWELL and Epstein spending time together with a minor
victim, while some would involve MAXWELL or Epstein spending
time alone with a minor victim.
b.
Having developed a rapport with a victim,
MAXWELL would try to normalize sexual abuse for a minor victim
by, among other things, discussing sexual topics, undressing in
front of the victim, being present when a minor victim was
undressed, and/or being present for sex acts involving the minor
victim and Epstein.
C.
MAXWELL'S presence during minor victims'
interactions with Epstein, including interactions where the
minor victim was undressed or that involved sex acts with
Epstein, helped put the victims at ease because an adult woman
was present. For example, in some instances, MAXWELL would
massage Epstein in front of a minor victim. In other instances,
MAXWELL encouraged minor victims to provide massages to Epstein,
including sexualized massages during which a minor victim would
be fully or partially nude. Many of those massages resulted in
Epstein sexually abusing the minor victims.
d. In addition, Epstein offered to help some
minor victims by paying for travel and/or educational
opportunities, and MAXWELL encouraged certain victims to accept
Epstein's assistance. As a result, victims were made to feel
3
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 4 of 24
indebted and believed that MAXWELL and Epstein were trying to
help them.
e. Through this process, MAXWELL and Epstein
enticed victims to engage in sexual activity with Epstein. In
some instances, MAXWELL was present for and participated in the
sexual abuse of minor victims. Some such incidents occurred in
the context of massages, which developed into sexual encounters.
5. Between approximately in or about 1994 and in or
about 2004, GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims by, among other
things, inducing and enticing, and aiding and abetting the
inducement and enticement of, multiple minor victims. Victims
were groomed and/or abused at multiple locations, including the
following:
a. A multi-story private residence on the Upper
East Side of Manhattan, New York owned by Epstein (the "New York
Residence").
b.
An estate in Palm Beach, Florida owned by
Epstein (the "Palm Beach Residence").
C. A ranch in Santa Fe, New Mexico owned by
Epstein (the "New Mexico Residence").
d.
MAXWELL's personal residence in London,
England.
4
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 5 of 24
6.
Additionally, beginning at least in or about
2001, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein
enticed and recruited, and caused to be enticed and recruited,
minor girls to visit Epstein's Palm Beach Residence to engage in
sex acts with Epstein, after which Epstein, MAXWELL, or another
employee of Epstein's would give the victims hundreds of dollars
in cash. Epstein and MAXWELL encouraged one or more of those
victims to travel with Epstein with the intention that the
victim engage in sex acts with Epstein. Moreover, and in order
to maintain and increase his supply of victims, Epstein,
MAXWELL, and other Epstein employees also paid certain victims
to recruit additional girls to be similarly abused by Epstein.
In this way, Epstein and MAXWELL created a network of underage
victims for him to sexually exploit.
7.
Between at least in or about 2001 and in or about
2004, GHISLAINE MAXWELL, the defendant, and Epstein encouraged
and enticed one or more minor victims to engage in paid sex acts
with Epstein through a variety of means and methods, including
but not limited to the following:
a.
Epstein's employees, including, at times,
MAXWELL, would call a victim to schedule an appointment for the
victim to massage Epstein at his Palm Beach Residence. MAXWELL
placed at least some of those calls while with Epstein in
5
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Manhattan, New York. Epstein would often travel from New York
to Florida, where he would then have the scheduled appointments.
b. When a victim initially arrived at the Palm
Beach Residence, she would be greeted by an employee of
Epstein's, including, at times, MAXWELL. The victim would then
be escorted to a room with a massage table. Once inside, the
victim would provide a nude or semi-nude massage for EPSTEIN,
who would himself typically be naked. During these encounters,
EPSTEIN would escalate the nature and scope of the physical
contact to include sex acts such as groping and direct and
indirect contact with the victim's genitals. EPSTEIN would also
typically masturbate during these encounters, ask the victim to
touch him while he masturbated, and touch the victim's genitals
with his hands or with sex toys.
C. In connection with each sexual encounter,
Epstein or one of his employees or associates, including, at
times, MAXWELL, paid the victim in cash. Each victim was
typically paid hundreds of dollars for each encounter.
8. GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims knowing that he had a
sexual preference for underage girls and that he intended to
engage in sexual activity with those victims. Epstein's
resulting abuse of minor victims included, among other things,
touching a victim's breast, touching a victim's genitals,
6
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 7 of 24
placing a sex toy such as a vibrator on a victim's genitals,
directing a victim to touch Epstein while he masturbated, and
directing a victim to touch Epstein's genitals.
MAXWELL AND EPSTEIN'S VICTIMS
9.
Among the victims induced or enticed by GHISLAINE
MAXWELL, the defendant, were minor victims identified herein as
Minor Victim-1, Minor Victim-2, Minor Victim-3, and Minor
Victim-4. In particular, and during time periods relevant to
this Indictment, MAXWELL engaged in the following acts, among
others, with respect to minor victims:
a.
MAXWELL met Minor Victim-1 when Minor
Victim-1 was approximately 14 years old. MAXWELL subsequently
interacted with Minor Victim-1 on multiple occasions at
Epstein's residences, knowing that Minor Victim-1 was under the
age of 18 at the time. During these interactions, which took
place between approximately 1994 and 1997, MAXWELL groomed Minor
Victim-1 to engage in sexual acts with Epstein through multiple
means. First, MAXWELL and Epstein attempted to befriend Minor
Victim-1, taking her to the movies and on shopping trips.
MAXWELL also asked Minor Victim-1 about school, her classes, her
family, and other aspects of her life. MAXWELL then sought to
normalize inappropriate and abusive conduct by, among other
things, undressing in front of Minor Victim-1 and being present
when Minor Victim-1 undressed in front of Epstein. Within the
7
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 8 of 24
first year after MAXWELL and Epstein met Minor Victim-1, Epstein
began sexually abusing Minor Victim-1. MAXWELL was present for
and involved in some of this abuse. In particular, MAXWELL
involved Minor Victim-1 in group sexualized massages of Epstein.
During those group sexualized massages, MAXWELL and/or Minor
Victim-1 would engage in sex acts with Epstein. Epstein and
MAXWELL both encouraged Minor Victim-1 to travel to Epstein's
residences in both New York and Florida. As a result, Minor
Victim-1 was sexually abused by Epstein in both New York and
Florida. Minor Victim-1 was enticed to travel across state
lines for the purpose of sexual encounters with Epstein, and
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-1 after Minor-Victim-1 traveled to Epstein's
properties, including in the context of a sexualized massage.
b. MAXWELL interacted with Minor Victim-2 on at
least one occasion in or about 1996 at Epstein's residence in
New Mexico when Minor Victim-2 was under the age of 18. Minor
Victim-2 had flown into New Mexico from out of state at
Epstein's invitation for the purpose of being groomed for and/or
subjected to acts of sexual abuse. MAXWELL knew that Minor
Victim-2 was under the age of 18 at the time. While in New
Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and
MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed
Minor Victim-2's school, classes, and family with Minor Victim-
8
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=== Page 9 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 9 of 24
2. In New Mexico, MAXWELL began her efforts to groom Minor
Victim-2 for abuse by Epstein by, among other things, providing
an unsolicited massage to Minor Victim-2, during which Minor
Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to
massage Epstein.
C. MAXWELL groomed and befriended Minor
Victim-3 in London, England between approximately 1994 and 1995,
including during a period of time in which MAXWELL knew that
Minor Victim-3 was under the age of 18. Among other things,
MAXWELL discussed Minor Victim-3's life and family with Minor
Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and
arranged for multiple interactions between Minor Victim-3 and
Epstein. During those interactions, MAXWELL encouraged Minor
Victim-3 to massage Epstein, knowing that Epstein would engage
in sex acts with Minor Victim-3 during those massages. Minor
Victim-3 provided Epstein with the requested massages, and
during those massages, Epstein sexually abused Minor Victim-3.
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-3 on multiple occasions, including at times when
Minor Victim-3 was under the age of 18, including in the context
of a sexualized massage.
d. Minor Victim-4 was recruited to provide
Epstein with sexualized massages for which Minor Victim-4 was
paid by Epstein and/or one of his associates, including, at
9
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times, MAXWELL, at the Palm Beach Residence beginning in or
around 2001. MAXWELL met Minor Victim-4 at Epstein's Palm Beach
Residence when Minor Victim-4 was approximately 14 years old.
MAXWELL subsequently interacted with Minor Victim-4 on multiple
occasions at Epstein's Palm Beach Residence, knowing that Minor
Victim-4 was under the age of 18 at the time. During these
interactions, which took place between approximately 2001 and
2004, MAXWELL groomed Minor Victim-4 to engage in sexual acts
with Epstein through multiple means. For example, MAXWELL asked
Minor Victim-4 about her family and other aspects of her life.
MAXWELL also sought to normalize inappropriate and abusive
conduct by, among other things, discussing sexual topics in
front of Minor Victim-4 and being present when Minor Victim-4
was nude in the massage room of the Palm Beach Residence. On
multiple occasions between approximately 2001 and 2004, Minor
Victim-4 provided nude massages to Epstein at the Palm Beach
Residence, during which Epstein engaged in multiple sex acts
with Minor Victim-4. Epstein's employees, including at times
MAXWELL, called Minor Victim-4, including from New York, to
schedule appointments for Minor Victim-4 to massage Epstein.
After each massage, Epstein or one of his employees, including
at times MAXWELL, paid Minor Victim-4 hundreds of dollars in
cash. At some point during this period, both Epstein and
MAXWELL invited Minor Victim-4 to travel with Epstein and
10
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 11 of 24
offered to assist Minor Victim-4 with obtaining a passport for
purposes of such travel, but Minor Victim-4 declined the
invitation. On multiple occasions between approximately 2001
and 2004, Epstein's employees, including at times MAXWELL, sent
Minor Victim-4 gifts, including lingerie, from an address in
Manhattan, New York to Minor Victim-4's residence in Florida.
Epstein and MAXWELL each also encouraged Minor Victim-4 to
recruit other young females to provide sexualized massages to
Epstein. In response, Minor Victim-4 brought multiple females,
including girls under the age of 18, to provide sexualized
massages for Epstein at the Palm Beach Residence. On such
occasions, both Minor Victim-4 and the girl she brought were
paid hundreds of dollars in cash.
MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT
10. In or around 2016, in the context of a deposition
as part of civil litigation, GHISLAINE MAXWELL, the defendant,
repeatedly provided false and perjurious statements, under oath,
regarding, among other subjects, her role in facilitating the
abuse of minor victims by Jeffrey Epstein, including some of the
specific events and acts of abuse detailed above.
STATUTORY ALLEGATIONS
11. From at least in or about 1994, up to and
including in or about 2004, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
11
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 12 of 24
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, enticement, in violation of Title 18, United States Code,
Section 2422.
12. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did knowingly persuade, induce,
entice, and coerce one and more individuals to travel in
interstate and foreign commerce, to engage in sexual activity
for which a person can be charged with a criminal offense, in
violation of Title 18, United States Code, Section 2422.
Overt Acts
13. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with Epstein
and Minor Victim-1 in New York and Florida.
b.
In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
12
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 13 of 24
New York Residence, in violation of New York Penal Law, Section
130.55.
C. In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d. Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
e. Between in or about 2001 and in or about
2002, when Minor Victim-4 was under the age of 18, MAXWELL and
Epstein invited Minor Victim-4 to travel from Florida to a place
outside of Florida with Epstein.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Enticement of a Minor to Travel to Engage in Illegal Sex Acts)
The Grand Jury further charges:
14. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
15. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
13
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 14 of 24
persuade, induce, entice, and coerce an individual to travel in
interstate and foreign commerce to engage in sexual activity for
which a person can be charged with a criminal offense, and
attempted to do the same, and aided and abetted the same, to
wit, MAXWELL persuaded, induced, enticed, and coerced Minor
Victim-1 to travel from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2422 and 2.)
COUNT THREE
(Conspiracy to Transport Minors with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
16. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
17. From at least in or about 1994, up to and
including in or about 2004, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, transportation of minors, in violation of Title 18, United
States Code, Section 2423 (a).
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=== Page 15 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 15 of 24
18. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did, knowingly transport an
individual who had not attained the age of 18 years in
interstate and foreign commerce, with intent that the individual
engage in sexual activity for which a person can be charged with
a criminal offense, in violation of Title 18, United States
Code, Section 2423 (a).
Overt Acts
19. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with EPSTEIN
and Minor Victim-1 in New York and Florida.
b. In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
New York Residence, in violation of New York Penal Law, Section
130.55.
C. In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 16 of 24
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d.
Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
e.
Between in or about 2001 and in or about
2002, when Minor Victim-4 was under the age of 18, MAXWELL and
Epstein invited Minor Victim-4 to travel from Florida to a place
outside of Florida with Epstein.
(Title 18, United States Code, Section 371.)
COUNT FOUR
(Transportation of a Minor with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
20. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
21. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
transport an individual who had not attained the age of 18 years
in interstate and foreign commerce, with the intent that the
individual engage in sexual activity for which a person can be
charged with a criminal offense, and attempted to do so, and
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aided and abetted the same, to wit, MAXWELL arranged for Minor
Victim-1 to be transported from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2423 (a) and 2.)
COUNT FIVE
(Sex Trafficking Conspiracy)
The Grand Jury further charges:
22. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
23. From at least in or about 2001, up to and
including in or about 2004, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, sex trafficking of minors, in violation of Title 18, United
States Code, Section 1591 (a) and (b).
24. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did, in and affecting interstate
and foreign commerce, recruit, entice, harbor, transport,
provide, and obtain, by any means a person, and to benefit,
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financially and by receiving anything of value, from
participation in a venture which has engaged in any such act,
knowing that the person had not attained the age of 18 years and
would be caused to engage in a commercial sex act, in violation
of Title 18, United States Code, Sections 1591 (a) and (b) (2).
Overt Acts
25. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a.
Between in or about 2001 and in or about
2004, Epstein and MAXWELL recruited Minor Victim-4 to engage in
sex acts with EPSTEIN at the Palm Beach Residence, after which
Epstein and, at times, MAXWELL provided Minor Victim-4 with
hundreds of dollars in cash for each encounter. Minor Victim-4
truthfully told both Epstein and MAXWELL her age.
b.
Between in or about 2001 and in or about
2004, Epstein and MAXWELL both encouraged and enticed Minor
Victim-4 to recruit other girls to engage in paid sex acts with
Epstein, which she did.
C. Between in or about 2001 and in or about
2004, Epstein's employees, including at times MAXWELL, sent
Minor Victim-4 gifts, including lingerie, from an address in the
Southern District of New York to Minor Victim-4's residence in
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Florida. For example, on one occasion in or about October of
2002, Epstein caused a package to be sent by Federal Express
from an address in Manhattan to Minor Victim-4 in Florida.
d. On multiple occasions between in or about
2001 and in or about 2004, Epstein, MAXWELL, or one of Epstein's
other employees called Minor Victim-4 to schedule an appointment
for Minor Victim-4 to massage Epstein. For example, in or about
April of 2004 and May of 2004 another employee of Epstein's
called Minor Victim-4 to schedule such appointments.
(Title 18, United States Code, Section 371.)
COUNT SIX
(Sex Trafficking of a Minor)
The Grand Jury further charges:
26. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
27. From at least in or about 2001, up to and
including in or about 2004, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, willfully and
knowingly, in and affecting interstate and foreign commerce, did
recruit, entice, harbor, transport, provide, and obtain 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, and did aid and abet the same, to wit, MAXWELL recruited,
enticed, harbored, transported, provided, and obtained
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individuals who were less than 18 years old, including but not
limited to Minor Victim-4, as described above, and who were then
caused to engage in at least one commercial sex act with Jeffrey
Epstein, and aided and abetted the same.
(Title 18, United States Code, Section 1591 (a),
(b) (2), and 2.)
COUNT SEVEN
(Perjury)
The Grand Jury further charges:
28. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
29. On or about April 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7433, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q.
Did Jeffrey Epstein have a scheme to recruit
underage girls for sexual massages? If you know.
A.
I don't know what you' re talking about.
Q.
List all the people under the age of 18 that you
interacted with at any of Jeffrey's properties?
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 21 of 24
:
A.
I'm not aware of anybody that I interacted with,
other than obviously [the plaintiff] who was 17
at this point.
(Title 18, United States Code, Section 1623.)
COUNT EIGHT
(Perjury)
The Grand Jury further charges:
30. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
31. On or about July 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7433, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q:
Were you aware of the presence of sex toys or
devices used in sexual activities in Mr.
Epstein's Palm Beach house?
A:
No, not that I recall.
Q.
Do you know whether Mr. Epstein possessed sex
toys or devices used in sexual activities?
A. No.
Q.
Other than yourself and the blond and brunette
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=== Page 22 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 22 of 24
:
:
that you have identified as having been involved
in three-way sexual activities, with whom did Mr.
Epstein have sexual activities?
A.
I wasn't aware that he was having sexual
activities with anyone when I was with him other
than myself.
a
I want to be sure that I'm clear. Is it your
testimony that in the 1990s and 2000s, you were
not aware that Mr. Epstein was having sexual
activities with anyone other than yourself and
the blond and brunette on those few occasions
when they were involved with you?
A.
That is my testimony, that is correct.
Q.
Is it your testimony that you' ve never given
anybody a massage?
A.
I have not given anyone a massage.
a
You never gave Mr. Epstein a massage, is that
your testimony?
A.
That is my testimony.
a
You never gave [Minor Victim-2] a massage is your
testimony?
A.
I never gave [Minor Victim-2] a massage.
(Title 18, United States Code, Section 1623.)
FORFEITURE ALLEGATIONS
32. As a result of committing the offense alleged in
Count Six of this Indictment, GHISLAINE MAXWELL, the defendant,
shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 1594 (c) (1), any property, real and
personal, that was used or intended to be used to commit or to
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=== Page 23 ===
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facilitate the commission of the offense alleged in Count Six,
and any property, real or personal, constituting or derived from
any proceeds obtained, directly or indirectly, as a result of
the offense alleged in Count Six, or any property traceable to
such property.
Substitute Asset Provision
33. If any of the above-described forfeitable
property, as a result of any act or omission of the defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a
third person;
(c) has been placed beyond the jurisdiction of the Court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot
be subdivided without difficulty;
it is the intent of the United States, pursuant to 21 U.S.C.
$ 853 (p) and 28 U.S.C. $ 2461 (c), to seek forfeiture of any
other property of the defendant up to the value of the above
forfeitable property.
(Title 18, United States Code, Section 1594; Title 21,
United States Code, Section 853; and
Title 28, United States Code, Section 2461.)
Veltor/Gile
FOREPERSON
badrey AUDREY STRAUSS Street
United States Attorney
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=== Page 24 ===
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Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
GHISLAINE MAXWELL,
Defendant.
SUPERSEDING INDICTMENT
S2 20 Cr. 330 (AJN)
(18 U.S.C. §§ 371, 1591, 1623, 2422,
2423 (a), and 2)
AUDREY STRAUSS
United States Attorney
Vilton Foreperson Gib
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