# docs_fts_content

c1: EFTA00023397
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023397.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: FinCEN/Bank Letters
Date: Mon, 31 Aug 2020 15:17:45 +0000
Attachments: BNYM_ICIJ_letter.pdf;_BuzzFeed_Email_to_Standard_Chartered.pdf;
Citibank_Comment_Letter.pdf; Deutsche_Bank_letter_FINAL.PDF;
ICIJ_letter_8.20_HSBC.pdf JPMC_ICIJ_Request_for_Comment_JPMorgan_Chasepdf
Letter_from_BBC_Panorama_to_Barclays_Bank_19.08.20.pdf;
Ocean_Bank_Comment_Letterpdf; PNC_ICIJ_Ltr_08-17-20.pdf;
U.S._Century_Bank_Comment_Letter.pdf; Barclays_Comment_Letter_pdf.pdf;
BanescoUSA.com_Mail_-_Fwd__ICIJ_solicitud_de_comentario.pdf;
CIJ_Letter_Banesco_Questions.pdf First_Republic_Bank_Ist_email_from_BuzzFeed_7-
14-2020.pdf;,First_Republic_Bank_2nd_email_from_BuzzFeed_8-17-2020.pdf;
Letter_to_FinCEN_re_SAR_Request_(BuzzFeed)_August_6,_2020.pdf
See attached.
EFTA00023397


c1: EFTA00020986
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020986.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 10777198(1) approved by
N, now awaiting further approval
Date: Mon, 18 Nov 2019 22:37:43 +0000
Importance: Normal
Dear
Final voucher 10777198(1) has been approved by N
how awaiting further approval.
Trip ID: 10777198
Voucher ID: 1
Voucher type: Final
Traveler name
Purpose: R20NYS13144 - Epstein investigation - Witness Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-11-04 - 2019-11-05
Current status: Pending Voucher Approval
Voucher total expenses: 548.87
Estimated trip cost: 985.44
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0010
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00020986


c1: EFTA00021861
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021861.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 1 of 9
Haddon, Morgan and Foreman, P.C
Ty Gee
HADDON
150 East 10th Avenue
MORGAN
Denver, Colorado 80203
FOREMAN
PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
tgee@hmflaw.com
July 29, 2020
Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Reconsideration of the Court's July 23 Ruling
Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP)
Dear Judge Preska:
As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order
and punish its violation. Ms. Maxwell's two deposition transcripts were designated
"Confidential" and subject to the protection of the Protective Order. Both transcripts ended
up in the hands of the government, which used them to bring an indictment against
Ms. Maxwell, charging her with, among other things, perjury in her deposition testimony.
This is a serious violation of the Protective Order, and merits the commencement of contempt
proceedings.
We also write to seek reconsideration of the Court's July 23, 2020 ruling concluding that the
transcripts of Ms. Maxwell's April 2016 deposition and Doe 1's deposition should be unsealed
in their entirety (with the exception of non-party names). We recognize that a reconsideration
motion is an extraordinary request, but we suggest it is appropriate under the circumstances.
There are new facts since Ms. Maxwell lodged her objections to the unsealing of the transcript
of her deposition, and there is a need to correct clear error or prevent manifest injustice
relating to the unsealing of the transcript.
We respectfully request that the Court keep sealed Ms. Maxwell's and Doe 1's deposition
transcripts and any sealed or redacted order or paper that quotes from or discloses information
from the transcripts ("deposition material"). We do not seek unnecessary delay; however, if
the Court denies our request for reconsideration, we do wish to seek relief from the Second
Circuit. Accordingly, in the event the Court denies this reconsideration request, we ask that
the Court stay any unsealing of the deposition material for at least two business days to give us
time to apply to the Second Circuit for a stay of the unsealing order pending appeal. As the
EFTA00021861

=== Page 2 ===
Case 1:15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 2 of 9
Honorable Loretta A. Preska
July 29, 2020
Page 2
courts have recognized, temporary stays of unseal orders are appropriate so that "[t]he genie
is [not] out of the bottle," Gambale v. Deutsche Bank AG, 377 F.3d 133, 144 (2d Cir. 2004),
before the interested parties have an opportunity to seek review of the orders. See, e.g., United
States v. Martoma, No. S1 12 CR 973 PGG, 2014 WL 164181, at *8 (S.D.N.Y. Jan. 9, 2014)
("The Court stays immediate disclosure of these materials to permit Defendant to make
application to the U.S. Court of Appeals for the Second Circuit for a more extended stay.");
Brown v. Maxwell, 929 F.3d 41, 54 (2d. Cir. 2019) (recognizing likelihood of future appeals in
this matter).
1. There are new, intervening and significant facts since briefing closed on the first round
of review of sealed materials. After many months of relentless negative media coverage of
Mr. Epstein and allegations that Ms. Maxwell was involved in his criminal activities, the
government secured an indictment against her. On July 2, one day after Ms. Maxwell filed her
reply in support of her objection to unsealing documents containing references to Does 1 and
2, the government staged a dramatic, forced entry at dawn into her home and arrested her.
EXHIBIT A, at 3.
Immediately after Ms. Maxwell's arrest, Acting U.S. Attorney Audrey Strauss held a press
conference and made numerous comments attacking Ms. Maxwell's credibility and expressing
her opinion of Ms. Maxwell's guilt, e.g., that she was guilty of "I[ying]" in her deposition
"because the truth, as alleged, was almost unspeakable." Id. Plaintiff's counsel piled on,
offering their own opinions about Ms. Maxwell's guilt. For example, Mr. Edwards opined that
Ms. Maxwell was "a main facilitator" of Mr. Epstein's crimes who "started the whole thing."
Id. Ms. McCawley praised the prosecutors: "[They] have done an incredible job and they're
being very meticulous, they want to make sure that the Indictments stick.
They took a lot
of time to be very careful and thoughtful and that gives me a lot of hope that [Ms. Maxwell]
will remain in prison for the remainder of her life
[Ms. Maxwell] was really the central
figure Id. at 6.
Ms. Maxwell's motion for an order barring such extrajudicial comments led Judge Nathan to
admonish "counsel for all involved parties [to] exercise great care to ensure compliance with
this Court's local rules, including Local Criminal Rule 23.1, and the rules of professional
responsibility." EXHIBIT B. She further "warn[ed] counsel and agents for the parties and
counsel for potential witnesses that going forward it will not hesitate to take appropriate action
in the face of violations of any relevant rules." Id. Judge Nathan said she would ensure "strict
compliance" with the rules and "ensure that the Defendant's right to a fair trial will be
safeguarded." Id.
On July 8 the government filed a superseding indictment alleging that Ms. Maxwell "assisted,
facilitated, and contributed" to Mr. Epstein's abuse of minors. The indictment quickly turned
to this civil action, alleging that in 2016 Ms. Maxwell made "efforts to conceal her conduct"
EFTA00021862

=== Page 3 ===
Case 1:15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 3 of 9
Honorable Loretta A. Preska
July 29, 2020
Page 3
by "repeatedly provid[ing] false and perjurious statements" in deposition testimony.
EXHIBIT C 9 8.
Quoting verbatim from Ms. Maxwell's April 2016 deposition transcript, the indictment alleges
Ms. Maxwell gave false testimony (a) when she testified "I don't know what you're talking
about" in response to a question whether Mr. Epstein "ha[d] a scheme to recruit underage
girls for sexual massages [i]f you know"; and (b) when she testified, "I'm not aware of
anybody that I interacted with [other than plaintiff] who was 17 at this point.' Id. 9 21. None
of these questions and answers was used in the summary judgment papers or released by the
Second Circuit. The transcript containing this testimony is sealed.
2. The Court should commence proceedings to vindicate the government and plaintiff's
violation of the Protective Order. Only two parties-plaintiff and Ms. Maxwell-and their
counsel had proper access to the transcripts of Ms. Maxwell's deposition. The transcripts,
which were designated "Confidential," were the subject of the Protective Order strictly
limiting the persons to whom the parties may disclose "Confidential" -designated documents.
For example, the parties could only disclose such documents to "attorneys actively working
on this case" and "persons regularly employed or associated with the attorneys who are
working on this case." Doc.62, quoted in Doc.1071 at 3. This language was negotiated by the
parties to specifically exclude an exception for investigations by law enforcement.
On February 26, 2016, counsel for plaintiff proposed protective order language that would
have allowed for a "law enforcement" exception: Paragraph I(a)4 of plaintiff's draft proposed
that: "CONFIDENTIAL information shall not be disclosed or used for any purpose except the
preparation and trial of this case and any related matter, including but not limited to,
investigations by law enforcement." See Exhibit D at 3. This language was rejected by Ms.
Maxwell because of her concerns that plaintiff and her lawyers were acting as either express or
de facto agents of the Government. The language agreed upon, and made an Order of this
Court specifically excluded an exception for law enforcement. Had the language not been
made an order of the Court, Ms. Maxwell would have proceeded in a different fashion. She
relied on this language and the protection afforded to her by this Court under established
Second Circuit law.
In its Order dated July 1, 2020, the Court said it was "troubled" to learn that plaintiff's
successor counsel, Cooper & Kirk, had received from plaintiff's former counsel, Boies Schiller
Flexner, various discovery materials that were subject to the Protective Order. Doc.1071 at 4.
The Court rejected Cooper & Kirk's suggestion that it properly was a recipient of the material:
[W]hatever Cooper & Kirk's intentions in requesting and obtaining the
Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly
provides that (1) discovery materials designated CONFIDENTIAL cannot be
EFTA00021863

=== Page 4 ===
Case 1:15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 4 of 9
Honorable Loretta A. Preska
July 29, 2020
Page 4
disclosed or used outside of the Maxwell action and (2) that properly designated
discovery materials may only be disclosed to specific groups of individuals,
including attorneys "actively working on" the Maxwell litigation.
Doc.1071 at 4-5 (emphasis supplied)
Five things are plain. One, as the indictment and superseding indictment establish, the
government has a copy of the transcripts from Ms. Maxwell's April and July 2016 depositions,
both of which were designated "Confidential." Two, the government had no ability legally to
obtain the deposition transcripts. In Martindell v. International Telephone and Telegraph Corp.,
594 F.2d 291, 293 (2d Cir. 1979), cited with approval in In re Teligent, Inc., 640 F.3d 53, 58 (2d
Cir. 2011), the government moved in a civil action to which it was not a party for access to
transcripts of depositions twelve witnesses, including some of the civil defendants. The
government said it was investigating possible violations of federal criminal laws, including
perjury, subornation of perjury, obstruction of justice and conspiracy. The government:
speculated that the pretrial deposition testimony might be relevant to its
investigation into matters similar to those that had been the subject of the
Martindell action and might be useful in appraising the credibility, accuracy and
completeness of testimony given by witnesses in the Government's
investigation or might provide additional information of use to the
Government. The Government, moreover, feared that unless it could obtain
the deposition transcripts, it would be unable to secure statements from the
witnesses because they would claim their Fifth Amendment rights in any
investigative interviews by the Government.
594 F.2d at 293. The district court denied the government's request, holding that "the
deposition testimony had been given in reliance upon the protective order, thus rendering
unnecessary invocation by the witnesses of their Fifth Amendment rights, that the requested
turnover would raise constitutional issues, and that principles of fairness mandated
enforcement of the protective order." Id. The Second Circuit affirmed:
In the present case the deponents testified in reliance upon the Rule 26(c)
protective order, absent which they may have refused to testify.
[T]he
witnesses were entitled to rely upon the terms of a concededly valid protective
order and Judge Conner did not abuse his discretion in refusing to vacate or
modify that order.
Id. at 296-97.
Three, the government did not obtain a copy of the deposition transcripts from Ms. Maxwell
or her counsel. Four, following plaintiff's counsel's admitted violation of the Protective Order
EFTA00021864

=== Page 5 ===
Case 1:15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 5 of 9
Honorable Loretta A. Preska
July 29, 2020
Page 5
earlier this month, it is clear now that there has been a second violation of the Protective Order
in a manner consistent with the plaintiff's intent and goals-namely, the prosecution of
Ms. Maxwell and the pursuit of a sentence that would imprison her "for the remainder of her
life," EXHIBIT A, at 3. Five, no one should be permitted to violate this Court's Protective
Order with impunity.
As it did in connection with plaintiff's violation of the Protective Order via her attorneys, the
Court should enter orders to determine the nature and extent of the violation of the Order,
identify those persons who violated the Order, and impose appropriate sanctions. Until this
process is completed, the Court should stay any disclosure of the transcripts of Ms. Maxwell's
deposition and deposition material. We respectfully submit that in the event the Court finds a
violation of the Protective Order, this Court should direct the government to return to the
Court any copies of the deposition transcripts and enter an order to show cause why the
person(s) who violated the Order should not be held in contempt. See, e.g., Blum v. Schlegel,
108 F.3d 1369 (2d Cir. 1997); Hunt v. Enzo Biochem, Inc., 904 F. Supp. 2d 337, 340 (S.D.N.Y.
2012).
3. The indictment provides a compelling reason not to unseal the transcript of
Ms. Maxwell's deposition. That Ms. Maxwell was under criminal investigation, the Court
ruled, "is not entitled to much weight here." Tr. of July 23 Hearing, at 5. The Court said
Ms. Maxwell had not explained how the sealed material could inappropriately influence
potential witnesses or victims. Id. The effect of Ms. Maxwell's indictment, arrest, upcoming
trial and of Judge Nathan's efforts to ensure a fair trial was not discussed in our objections
since none of these things had happened before briefing was closed.
Two cases are instructive. In each the courts indicated that in deciding whether to unseal
materials it was important to give weight to the impact on a criminal defendant's right to a fair
trial. In Nixon v. Warner Communications, Inc., 435 U.S. 589 (1978), a number of media moved
the district court to release audio tapes admitted into evidence in the trial of four of President
Nixon's former advisors. The media intended to copy the tapes for broadcasting and sale to
the public. District Judge Sirica denied the motion, principally on the ground that the rights of
the four defendants, who had been convicted and had filed notices of appeal, would be
prejudiced if they prevailed in their appeals. 435 U.S. at 595, 602 n.14. Judge Sirica noted that
the transcripts of the audio tapes had been released to the public. Id. at 595. The D.C. Circuit
Court of Appeals held Judge Sirica abused his discretion.
The Supreme Court reversed the court of appeals and rejected the media's arguments that
release of the tapes was required under the common law right of access and the First
Amendment. The Court noted apparently with approval that (a) "Judge Sirica's view" that
"the
public's
'right
to
know'
did
not
overcome the need to safeguard the defendants'
rights on appeal," and (b) "Judge Sirica's principal reason for refusing to release the tapes
EFTA00021865

=== Page 6 ===
Case 1:15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 6 of 9
Honorable Loretta A. Preska
July 29, 2020
Page 6
[was] fairness to the defendants, who were appealing their convictions." Id. at 595, 602 n.14.
The Court indicated that the public interest in access to the tapes properly was balanced
against "the duty of the courts," id. at 602, including the duty to ensure fairness to the
defendants, see id. at 602 n.14.
In In re New York Times Co., 828 F.2d 110 (2d Cir. 1987), cited with approval in United States v.
Longueuil, 567 Fed. App'x 13, 16 (2d Cir. 2014), Judge Weinstein denied the media's motion
to unseal papers filed in connection with an unsuccessful defense motion to suppress evidence
obtained by electronic surveillance. He found that "defendants' interest in a fair trial and the
interests of third parties [referenced in] the motion papers justified continued sealing of the
papers." 828 F.2d at 112; see id. at 112 (defendants opposed unsealing on the grounds it would
prejudice their Sixth Amendment right to a fair trial, their privacy rights, and third parties'
privacy rights). The Second Circuit vacated the order in part because "the wholesale sealing"
of the motion papers was "more extensive than necessary to protect defendants' fair trial
rights, their privacy rights, and the third persons' privacy interests. Id. at 116. The court
noted, "now that the jury has been impaneled, defendants' fair trial rights can certainly be
adequately protected by sequestration." Id.
In Nixon and New York Times, the courts properly were concerned about the effect of
unsealing materials notwithstanding that they were core judicial documents-audio tapes
admitted into evidence at the merits trial and motion papers seeking suppression of evidence
which the judge denied. And the courts continued to hold these concerns even after the
defendants had been convicted and had launched appeals (Nixon) and after the petit jury had
been empaneled (New York Times).
The courts have recognized that the right to a fair criminal trial is a compelling interest in
"weighing the interests advanced by the parties in light of the public interests and the duty of
the courts," Nixon, 435 U.S. at 602. See United States v. Cicale, No. 05-CR-60-2 (NGG), 2018
WL 388941, at *3 (E.D.N.Y. Jan. 11, 2018) ("Compelling interests warranting closure of a
courtroom-and, by extension, sealing of court documents- 'may include the defendant's
right to a fair trial (quoting with alterations United States v. Doe, 63 F.3d 121, 128 (2d
Cir. 1995)); United States v. Martoma, No. S1 12 CR 973 PGG, 2014 WL 164181, at *4
(S.D.N.Y. Jan. 9, 2014) ("A court's conclusion that a qualified First Amendment right of
access to certain judicial documents exists does not end the inquiry, however. 'Courts must
balance the right [of access] against other important values, like the Sixth Amendment right of
the accused to a fair trial
and the defendant's
privacy
interests.")
(internal
quotations
omitted; quoting United States v. Rajaratnam, 708 F. Supp. 2d 371, 374-75 (S.D.N.Y. 2010));
Travelers Indem. Co. v. Excalibur Reins. Corp., 3:11-CV-1209 CSH, 2013 WL 4012772, at *3 (D.
Conn. Aug. 5, 2013) ("The public's right to access court documents is not, however, absolute
in that it may be surmounted by a party's showing that sealing will further other substantial
interests, for example, a criminal defendant's right to a fair trial or a third party's privacy
EFTA00021866

=== Page 7 ===
Case 1:15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 7 of 9
Honorable Loretta A. Preska
July 29, 2020
Page 7
interests."); United States v. McVeigh, 119 F.3d 806, 813 (10th Cir. 1997) (upholding district
court's sealing of discovery materials deemed inadmissible at trial, holding that "disclosure of
such [materials] would play a negative role in the functioning of the criminal process, by
exposing the public generally, as well as potential jurors, to incriminating evidence that the law
has determined may not be used to support a conviction"), cited with approval in United States
v. Avenatti, (S1) 19 CR 373 PGG, 2020 WL 70952, at *3 (S.D.N.Y. Jan. 6, 2020).
Based on these cases, the Court may make specific findings supporting the sealing of
Ms. Maxwell's deposition transcript: The Court may take judicial notice, as Judge Nathan
herself may have, of the widespread negative media publicity and speculation directed at
Mr. Epstein and Ms. Maxwell. See Condit v. Dunne, 317 F. Supp. 2d 344, 358 (S.D.N.Y. 2004).
We attach a compilation of such articles in EXHIBIT E. The Court also may take judicial
notice of Ms. Maxwell's arrest and indictment, and the government's charge against her based
on her answers in a deposition transcript that was subject to this Court's Protective Order.
The unsealing of Ms. Maxwell's deposition transcript would result in substantial negative
media publicity and speculation in an internet world in the same way that Judge Sirica found
release of the audio tapes in Nixon would generate publicity and affect those defendants' right
to a fair trial. And the Court may take judicial notice of Judge Nathan's own concerns about
the need for counsel for the parties and witnesses in the criminal case to comply with Local
Criminal Rule 23.1 to "safeguard" and "protect [Ms. Maxwell's] right to a fair trial by an
impartial jury," EXHIBIT C. The public's right of access to Ms. Maxwell's deposition
transcript is substantially outweighed by the compelling interest in ensuring her right to a fair
trial. Particularly is this true in light of the other countervailing interests discussed in our
objection papers and below.
4. The deposition transcripts obtained by the government and the indictment's perjury
counts place in a new light plaintiff's earlier litigation conduct-suggesting the planned
use of Ms. Maxwell's deposition as a perjury trap. Throughout much of the first year of
this litigation plaintiff through her counsel had represented to the Court and defense counsel
that plaintiff was privy to and participating in an ongoing criminal investigation in which
Ms. Maxwell was a "person of interest." Doc.101 at 2. Toward that end plaintiff withheld
documents responsive to defense discovery requests for any documents relating to such a
criminal investigation; plaintiff asserted such documents were subject to a law enforcement,
"investigative" or public interest "privilege." Id. at 2-3. In response to Ms. Maxwell's motion
to compel the production of documents, plaintiff submitted the "law enforcement materials"
ex parte and in camera to the Court. Doc.128. Ms. Maxwell objected to the submission of the
materials ex parte and in camera. Doc.130. The Court denied the motion to compel. Doc. 264-1.
The materials never have been produced to the defense.
Based on plaintiff's claim of an ongoing investigation, Ms. Maxwell requested, prior to her
deposition, that plaintiff disclose any alleged "on-going criminal investigation by law
EFTA00021867

=== Page 8 ===
Case 1:15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 8 of 9
Honorable Loretta A. Preska
July 29, 2020
Page 8
enforcement" or alternatively to stay this action pending completion of any such investigation.
Doc. In part, Ms. Maxwell needed information concerning any such investigation to
assess "the impact on any 5th Amendment privilege." Id. at 2, 4-5. Judge Sweet denied that
motion. The day before Ms. Maxwell's deposition, the Court ordered that "[a]ny materials
that the plaintiff has with respect to any criminal investigations will be turned over [by
plaintiff] except for any statements made by plaintiff to law enforcement authority." Tr. of
Apr. 21, 2016 at 21. Plaintiff produced no such materials and Ms. Maxwell was deposed the
next day. In reliance on the protective order which included no exception for any law
enforcement need or subpoena and based on plaintiff's failure to disclose any "on-going
criminal investigation," she did not assert the 5th Amendment during that deposition.
This background is given a new context in light of (a) the provision of the sealed transcripts to
the government without court authorization and (b) the indictment and perjury charges lodged
against Ms. Maxwell based upon the transcripts. Under Martindell, decided forty years ago
and still binding precedent in this district, it is settled law that the government may not breach
a protective order to gain access to deposition transcripts in a civil lawsuit. As the Second
Circuit held in that case, the government "may not
simply by picking up the telephone or
writing a letter to the court
insinuate itself into a private civil lawsuit between others. 594
F.2d at 294. The court rejected the government's argument that the district court's
"solicitude for the witnesses' Fifth Amendment" over the government's desire for the
deposition transcripts was an abuse of discretion. It held that "a more significant
counterbalancing factor" is the civil rules' goal of encouraging witnesses to participate in civil
litigation:
Unless a valid Rule 26(c) protective order is to be fully and fairly enforceable,
witnesses relying upon such orders will be inhibited from giving essential
testimony in civil litigation, thus undermining a procedural system that has
been successfully developed over the years for disposition of civil differences.
In short, witnesses might be expected frequently to refuse to testify pursuant to
protective orders if their testimony were to be made available to the
Government for criminal investigatory purposes in disregard of those orders.
594 F.2d at 296. After balancing the interests at stake, the court held that absent improvidence
in issuing the protective order or some extraordinary circumstance or compelling need,
witnesses must be permitted to rely on the protective order's enforceability. Id. The protective
order should not be vacated or modified "to accommodate the Government's desire to inspect
protected testimony for possible use in a criminal investigation, either as evidence or as the
subject of a possible perjury charge." Id. (emphasis supplied).
The procedural history of this litigation culminating in plaintiff's gratuitously attaching the
entire transcripts of both Ms. Maxwell's depositions to court submissions, and leaking or
EFTA00021868

=== Page 9 ===
Case 1:15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 9 of 9
Honorable Loretta A. Preska
July 29, 2020
Page 9
causing someone to leak the transcripts to the government, which then charged Ms. Maxwell
with perjury counts, suggest plaintiff in conjunction with the government sought to
circumvent Martindell: they set a perjury trap for Ms. Maxwell when plaintiff took her
deposition. Ms. Maxwell requests that this Court examine the law enforcement materials
submitted ex parte and in camera in connection with its vindication of the Protective Order. In
the meantime we respectfully submit it is appropriate to maintain the seal over the
depositions.
5. Ms. Maxwell's reliance on the Protective Order is entitled to substantial weight. In its
July 23 ruling the Court did not address a substantial ground Ms. Maxwell asserted in support
of her objection to unsealing her deposition transcript. The first countervailing interest
Ms. Maxwell presented was that she reasonably relied on the Protective Order in disclosing
intimate information about her personal life. Doc.1057 at 4-5. As we pointed out, id. at 5, even
without any evidentiary or other showing from an interested party, the Second Circuit in
Brown v. Maxwell protected from disclosure "deposition responses concerning intimate
matters where the questions were likely only permitted- and the responses only compelled-
because of a strong expectation of continued confidentiality. "929 F.3d 41, 48 n.22 (2d Cir
2019). The Protective Order was entered before Ms. Maxwell's deposition was taken; in fact
plaintiff's counsel explicitly consented to the Order because "I just want [Ms. Maxwell's]
deposition
It is that important to me." Doc.1073 at 8 (quoting Doc.66 at 9). The Court
may make specific findings supporting the sealing of the transcript based on the information
Ms. Maxwell supplied from the court submissions. See id. We incorporate by reference here
the facts asserted and arguments made in the objection and reply in support of this
countervailing interest.
For the foregoing reasons we respectfully request that the Court reconsider its decision to
unseal (1) the transcripts of Ms. Maxwell's and Doe 1's depositions, and (2) court submissions
excerpting from, quoting from or summarizing the contents of the transcripts.
Very truly yours,
>H
Ty Gee
C: Counsel of Record via ECF
EFTA00021869


c1: EFTA00021413
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021413.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Christian Everdell
To:
)"
"Mark S. Cohen"
Cc:
Subject: RE: SDNY investigation (re: Epstein)
Date: Tue, 16 Jul 2019 17:37:36 +0000
Hi
-
I just tried your desk. Do we have a time this afternoon when you can meet? Let us know as soon as you can because
Mark will be in court soon and will not have his phone.
Also, would you mind asking the CSOs to allow us to bring our phones into the building? Let me know if that's a problem.
Thanks,
Chris
From:
Sent: Monday, July 15, 2019 7:57 PM
To: Christian Everdell; Mark S. Cohen
Cc:
)
Subject: RE: SDNY investigation (re: Epstein)
Chris, Mark,
Following up on my very brief conversation with Chris earlier this afternoon, and the voicemail you left earlier, thanks for
getting in touch regarding your representation of Ms. Maxwell. I understand you'll be in our neighborhood tomorrow
afternoon; we can make ourselves available to meet, but will that have been enough time for you to speak with your
client? Let us know what you think would be best to proceed, and we'll figure out next steps.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00021413


c1: EFTA00023346
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023346.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 10621156(1) prepared by a travel arranger is pending your review
Date: Tue, 24 Sep 2019 06:24:01 +0000
Importance: Normal
Dear
Final voucher 10621156(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 10621156
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R19NYST3832 - U.S. V. Epstein (2018R0618) - Victim Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-09-09 - 2019-09-10
Current status: Pending Voucher Approval
Voucher total expenses: 723.06
Estimated trip cost: 910.73
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0012
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00023346


c1: EFTA00021072
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021072.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Call re Epstein
Start Date: 2020-01-23 20:00:00 +0000
End Date: 2020-01-23 20:30:00 +0000
Organizer: The Bloom Firm <marcelino@thebloomfirm.com>
Location: 818-405-0476
Attendee: teri@thebloomfirm.com <teri@thebloomfirm.com>; colleen@thebloomfirm.com
<colleen@thebloomfirm.com>;
>;
>;
>; The
Bloom Firm <marcelino@thebloomfirm.com>
Date Created: 2020-01-22 21:44:51 +0000
Url: https://www.uberconference.com/thebloomfirm
Your UberConference information is below.
Join the call: https://www.uberconference.com/thebloomfirm
Optional dial-in number: 818-405-0476
No PIN needed.
International Access Numbers: https://www.uberconference.com/international
EFTA00021072


c1: EFTA00023080
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023080.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
)"
)"
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS) 1"
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Date: Thu, 31 Dec 2020 19:09:17 +0000
Attachments: 2020.12.31 Best Decl Re Rivera (v.2).docx;
2020.12.31_Letter_on_Rivera_and_Maxwell_discovery_and_counsel_access_(v.3).docx
Apologies - I looked at this as soon as you sent it, but apparently my outlook was frozen and it was hanging in
cyberspace. I thought it looked good, although there were some typos which I fixed. I also had a couple of
questions/comments in one of the declarations (attached).
From:
(USANYS)
Sent: Thursday, December 31, 2020 12:19 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
)
is
-
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Hi
:
Please see our proposed letter, which I understand you would like to review, as well as
declarations from associate wardens at the MDC and MCC. The GC and PC chiefs have signed off on
these drafts.
With apologies for the time sensitivity, our contacts at MCC/MDC have asked to leave early today
(before 1/1:30), and have asked us to finalize the declarations as soon as possible.
Best,
From:
(USANYS)
Sent: Wednesday, December 30, 2020 4:24 PM
To:
(USANYS)
i
(USANYS)
is
(USANYS)
>;
(USANYS)
is
)
is
)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
EFTA00023080

=== Page 2 ===
V.
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
,
who is the Associate Warden at the MCC. There's a possibility that there will be a very
short declaration from someone at the MDC to discuss the specific accommodations for Maxwell. I am
working through that with
From:
(USANYS)
Sent: Wednesday, December 30, 2020 2:45 PM
To:
(USANYS)
is
(USANYS)
i
(USANYS)
is
(USANYS)
i
)
>;
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Thanks. Who is signing the declaration for BOP?
From:
(USANYS)
Sent: Wednesday, December 30, 2020 2:40 PM
To:
(USANYS)
>;
(USANYS)
>;
(USANYS)
>;
(USANYS)
i
)
is
y
(USANYS)
Cc:
(USANYS)
is
(USANYS)
^
>;
(USANYS)
is
(USANYS)
^
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
:
We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to
explain that the discovery and counsel access accommodations that have been provided to Maxwell
and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of
their lawyers, and their individual housing circumstances. On all of these factors, there are several
important differences, including:
-
The Maxwell case has multiple times more discovery than the Rivera case. Hence, the need for
such expanded discovery access is greater in the Maxwell case.
-
At the MDC, Maxwell has a unique housing situation, as she is in protective custody outside the
general population. She therefore has sole access to a room to use a computer and phone for
approximately 13 hours a day. Rivera, by contrast, is housed in the general population.
-
There are approximately 80 other inmates at the MCC in Rivera's unit that use the same VTC
room for court appearances, probation interviews, and attorney meetings. By contrast, Maxwell
shares access to the MDC VTC room with substantially fewer inmates. The MDC can therefore
provide 15 hours of VTC meetings with her attorneys without compromising access for other
MDC inmates. The same is not true for Rivera at the MCC.
Going forward, even though Rivera's counsel have asked (and the Court has ordered) that Rivera
receive three hours of laptop access each day, the MCC is now leaving the laptop with him all day long,
and only takes it back at night to charge it. Therefore, the MCC is now providing the same amount of
electronic discovery access to Rivera that Maxwell receives at the MDC.
EFTA00023081

=== Page 3 ===
As for providing Rivera with up to 15 hours of VTC access, we will explain that doing so will
compromise access for other inmates. If defense counsel expresses a need for additional time, the
MCC will continue to find ways to accommodate those requests as best as they can.
Please let me know if you have any questions or would like to discuss this further.
Best,
From:
(USANYS)
Sent: Monday, December 21, 2020 4:42 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
is
)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Thanks,
Can you keep me posted on what we think will be the substance of the draft declaration when you know
(that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences between MCC
and MDC, as well as specific differences in their housing situations?
From:
(USANYS)
Sent: Monday, December 21, 2020 4:35 PM
To:
(USANYS)
i
(USANYS)
is
(USANYS)
i
(USANYS)
is
)
is
)
i
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
All:
I wanted to bring to your attention a recent issue that's surfaced in United States v. Rivera et al., a sex
trafficking case pending before Judge Engelmayer. As I'll describe in more detail below, Judge
Engelmayer has asked us to submit a declaration from the BOP explaining why the discovery and
counsel access accommodations provided to Ghislaine Maxwell (detained at the MDC outside the
general population) cannot be extended to Justin Rivera (detained at the MCC in the general
population).
Justin Rivera was charged in February 2019 with sex trafficking conspiracy. He's been detained at the
MCC since April 2019 on consent (he's also serving a state sentence). His trial, which was originally
scheduled for April 2019, is expected to start on February 16, 2020. In July 2020, he had new counsel
appointed, citing an irreconcilable breakdown with his former counsel.
Since this fall, Judge Engelmayer has become increasingly frustrated with the MCC's treatment of
Rivera. In particular, he's cited their failure to provide Rivera with adequate accommodations to
EFTA00023082

=== Page 4 ===
review discovery and meet with his lawyers, who refuse to visit Rivera at the MCC for personal health
concerns. We have two court orders in place to address these issues: (1) a laptop order, which requires
the MCC to provide Rivera access to a laptop for three hours per day; and (2) a videoconference order,
which requires the MCC to make available four hours of videoconferencing each week, in addition to
any telephone or videoconference calls obtained through the Federal Defenders.
At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time Rivera
has for videoconferences and electronic discovery review is insufficient for trial preparation, although
defense counsel has stated that they may request more time in the future. However, in a letter last
night and during a court conference this morning (transcript attached), defense counsel cited the
accommodations that the MDC has provided to Maxwell, describing them as "strikingly different and
far superior" to those afforded to Rivera. Defense counsel further suggested that Rivera was being
treated differently on account of his race, gender and class. Judge Engelmayer stated that the
disparity in access "jumped off the page" and that the optics were "terrible," and asked us to explain
the rationale for the differing treatment. After conferring with
and
before
our conference, we explained our understanding that the disparity comes down to the fact that
Maxwell and Rivera have very different housing situations, with Maxwell's situation being more
amenable to greater access to electronic discovery review and legal visits.
Judge Engelmayer asked us to submit a declaration, from an appropriate person at the BOP,
explaining in more detail why the accommodations provided to Maxwell cannot be extended to Rivera.
Based on the recent bail opposition in the Maxwell case, I believe the differences in counsel/discovery
access are as follows:
Accommodation
Maxwell
Rivera
Review of electronic
13 hours per day/7 days per
3 hours per day/7 days per
discovery (NB: each
week (91 hours total)
week (21 hours total)
defendant has laptop access)
Counsel visits (by video)
3 hours per day/5 days per
Four hours per week (plus an
week (15 hours total)
additional two hours
scheduled through the
Federal Defenders) (6 hours
total)
Weekend legal calls
As needed
Not available
The declaration is due by December 31. Because Judge Engelmayer's request implicates at least two
criminal cases, and potentially the ongoing civil litigation with the MCC, we wanted to make sure that
you were all aware of this issue. We are also happy to set up a call to discuss this further. In the
meantime, we are working with
to identify the appropriate declarant and draft an
explanation for the Court.
Best,
Assistant United States Attorney
United States Attorney's Office for the Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00023083

=== Page 5 ===
Tel:
EFTA00023084


c1: EFTA00022167
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022167.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Steptoe
STEPTOE & JOHNSON LLP
Michael C. Miller
direct
fax
1114 Avenue of the Americas
New York, NY 10036
212 506 3900 main
www.steptoe.com
August 23, 2019
Via Electronic Mail
Legal Department
Metropolitan Correctional Center
Re:
United States v. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.)
Dear
This letter is respectfully submitted pursuant to United States ex rel. Touhy v.
Regan, 340 U.S. 462 (1951), and the associated regulations, 28 C.F.R. §§ 16.21-16.26.
We are defense counsel of record for Jeffrey Epstein, Reg No. 76318-054, who
was previously incarcerated at the Metropolitan Correction Center in New York, New
York (the "MCC") while awaiting trial on federal charges in the above-captioned case.
Attached hereto is a subpoena, issued under Rule 17(c) of the Federal Rules of
Criminal Procedure, seeking any and all medical or mental health records relating to
Mr. Epstein. The requested records are necessary to counsel's investigation of the
circumstances of Mr. Epstein's death.
Please provide the requested records by 5:30 p.m., August 26, 2019.
Thank you in advance for your assistance in this matter.
EFTA00022167

=== Page 2 ===
August 23, 2019
Page 2
Sincerely,
Michael C. Miller
Steptoe & Johnson LLP
1114 Avenue of the Americas
New York, NY 10036
Martin G. Weinberg
Martin G. Weinberg, P.C.
20 Park Plaza, Suite 1000
Boston, MA 02116
EFTA00022168


c1: EFTA00023219
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023219.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: GM bail application
Date: Wed, 09 Dec 2020 00:36:49 +0000
Attachments: Memorandum_re_Second_Bail_Application_Final.PDF
Chiefs,
Attached is Maxwell's memorandum in support of her renewed bail application. She attached a number of exhibits, which
are too large to send in a single email. I've saved the full submission with exhibits and with the defense's proposed
redacted versions of its filings on the share here:
Let me know if you would like me to email any of the other parts of the submission to you.
Thanks,
EFTA00023219


c1: EFTA00022038
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022038.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: signature card
Date: Wed, 23 Jun 2021 14:42:07 +0000
Attachments: October_1999_FTC_Stmt.pdf
Attached is the FTC October 1999 account statement. The $18,300,000 transfer to Maxwell is shown on bates number
36868. On that same page, a deposit of $18,300,000 is made sourced from the sale of JP Morgan Institutional Prime
Money Market Fund.
If you have any questions, please contact me.
Best
From:
Sent: Wednesday, June 23, 2021 10:14 AM
To:
Subject: [EXTERNAL EMAIL] - FW: signature card
Thanks for sending. For this account, could you please send us the account statements surrounding the 10/19/99 transfer
to Maxwell that we discussed? It would be helpful to understand what the source is of the funds for the transfer. In
addition, could you please let me know the bates range for the account documents for this account? I'm having difficulty
locating them in the production. If you're able to flag any other KYC documents in the file, that would be extremely
helpful.
Thanks,
From:
Sent: Wednesday, June 23, 2021 10:04 AM
To:
Cc:
Subject: RE: signature card
EFTA00022038

=== Page 2 ===
Attached are the account documents for the Financial Trust Company. In the production, I did not see a signature card for
these accounts. However, there is a J.P. Morgan Entity Resolution form which schedules authorized signers (bates # 1934).
If you have any questions, please contact me.
Best
From:
Sent: Tuesday, June 22, 2021 3:14 PM
To:
Subject: [EXTERNAL EMAIL] - signature card
Hi Mark,
When you have a moment, could you please send me the signature card for the JP Morgan account ending in 5001? It's
the Financial Trust Co. account. I wasn't able to easily locate it in the production, so wanted to check with you.
Thanks!
Assistant United States Attorney
Southern District of New York
EFTA00022039


c1: EFTA00022488
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022488.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
(USANYS)"
Subject: It's AT&T!
Date: Wed, 28 Apr 2021 00:19:14 +0000
Attachments: 2004-05-
05_AT&T_WIRELESS MONTHLY _STATEMENT_REGARDING_JEFFREY_E_EPSTEI
N_PHONE_NUMBER
pdf
Hey
Following up on our call just now, I have corrected my prior misrecollection - the records reflecting calls from
to
are from AT&T, not Cingular. I've attached the relevant AT&T records for your reference. The specific calls to
are on April 23, 2004 and May 2, 2004 and are located on pages 9 and12 of the attached records.
number at that time was
,
and it appears in the "Number Called" column for entries on those two dates.
I've updated the order of proofer to reflect that we need an AT&T custodian (instead of Cingular/T-Mobile).
Thanks!
EFTA00022488


c1: EFTA00022616
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022616.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true
and correct to the best of my knowledge and belief.
Executed this 5 day of August 2020.
Counsel to the Acting United States Attorney
United States Attorney's Office for the
Southern District of New York
13
EFTA00022616


c1: EFTA00023437
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023437.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
Cc:
)"
)"
)"
Subject: RE: FAA Question
Date: Wed, 29 Sep 2021 14:53:03 +0000
Great, thank you!
From:
Sent: Wednesday, September 29, 2021 10:51 AM
To:
is
Cc:
is
(
is
Subject: RE: FAA Question
Hi
We have produced all FAA records. Most of the password-locked files were duplicates of the certified files, so we just
produced the certified ones. Only a few of the remaining password-locked files were not duplicates, so I ended up
printing, scanning, and stamping them, and including them with that production. So, overall, we are all set, and all the
records were produced. Thanks for checking in!
From:
Sent: Wednesday, September 29, 2021 10:48 AM
To:
y.
Cc:
is
i
Subject: RE: FAA Question
Hi
Just checking in on this thread. Are there still FAA records that we can't unlock and haven't produced? If so, we should
just include them in the next production and stamp them whatever way we can.
Thanks,
From:
Sent: Friday, September 10, 2021 4:33 PM
To:
is
i
Cc:
is
(
-
is
Subject: RE: FAA Question
EFTA00023437

=== Page 2 ===
Hi
It appears that external mail size constraints are preventing me from sending you the files that are password-protected.
The file names are below:
188TH-Airworthiness
188TH-Registration
550GP-Registration
N550GP was N212JE was N415LM registration
N550GP was N212JE was N415LM registration
N722JE registration
When attempting to edit the PDFs - which all appear to be registration files - we are prompted to enter passwords. These
are not the complete set of password-protected documents, but these are the documents that we need to be able to
print/edit as soon as possible.
I'm more than happy to answer any questions you may have for me. Thanks very much for any and all help you can
provide us!
Paralegal Specialist
U.S. Attorney's Office
SDNY
New York, NY 10007
From:
Sent: Friday, September 10, 2021 4:04 PM
To:
Cc:
is
Subject: RE: FAA Question
Hi!
Can you let me know which files were password protected?
I don't believe I password protected any of them.
Thank you,
Special Agent
Federal Aviation Administration
Law Enforcement Assistance Program
Atlanta, GA
EFTA00023438

=== Page 3 ===
From:
Sent: Friday, September 10, 2021 12:19 PM
To:
Cc:
in
)
V.
is
Subject: RE: FAA Question
Hi
Thank you very much for this information and for the quick turnaround. We really appreciate it.
Do you happen to know the password on the PDF documents you sent us? We'd like to stamp them for discovery
purposes, but they are password-protected.
We're still reviewing your email and these documents, but will certainly be back in touch if we have follow up questions.
Thanks,
From:
Sent: Tuesday, August 24, 2021 8:21 AM
To:
Cc:
is
is
)
Subject: RE: FAA Question
2007 Gulfstream GV-SP (G550), serial number 5173 was assigned tail number N415LM in March 2017 and was registered
to
Chevron USA Inc., Oakland, CA. Per a bill of sale dated March 29, 2017, Chevron USA Inc sold Gulfstream N415LM to;
Plan D LLC
St. Thomas, U.S. Virgins Islands
The registrant was Lawrence VISOSKI, he signed as Manager
I believe he is Lawrence Paul VISOSKI Jr.
he is a pilot
I don't see EPSTEIN's name on any of the FAA paperwork.
There is open source reporting that VISOSKI was a pilot for EPSTEIN.
It looks like Insured Aircraft Title Service in Oklahoma handled the transaction.
https://insuredaircraft.com/
Per the Plan D LLC, statement in support of registering aircraft that was submitted to the FAA, Jeffrey E. EPSTEIN was a
member
and VISOSKI was the manager. Further, Plan D LLC was established in 2012 in the U.S. Virgin Islands.
Per a request to the FAA dated August 07, 2017 from VISOSKI, they requested to change the tail number from N415LM to
N212JE.
In January 2018 they changed the tail number to N212JE. VISOSKI provided phone number
and e-mail:
On August 14, 2019 I was told that N212JE was owned by Jeffrey Epstein and was in a hangar at the Cobb County airport
(KRYY) in Kennesaw, Georgia.
EFTA00023439

=== Page 4 ===
Flight plans indicated N212JE operated on July 07, 2019 from Paris, France to Teterboro, NJ then on July 11, 2019 it
operated from
Teterboro, NJ to Brunswick, GA (KBQK).
Per a bill of sale dated December 22, 2020, Lawrence VISOSKI on behalf of Plan D LLC "sold" N212JE to Six G Aviation LLC
who "sold" it the same day
to N550GP LLC in Ontario, CA. N212JE was registered on February 24, 2021 to N550GP and
signed as
manager of Frontier JV LLC, its member.
in March 2021, they changed the tail number to N550GP and it's still registered as N550GP to N550GP LLC.
It looks like Insured Aircraft Title Service in Oklahoma handled this transaction also.
https://insuredaircraft.com/
I attached a picture of N212JE.
1969 Boeing 727, serial number 20115, N505LS was sold on January 19, 2001 by Real Estate Exchange Inc., Portland, OR
to JEGE Inc.
New York, NY 10022. The signature on the aircraft registration application is
not legible
but they listed their title as President. They changed the tail number to N908JE in April 2001. On the 2013 re-registration
application for N908JE,
Darren K. INDYKE, Vice President signed as Vice President of JEGE Inc.
They were the registered owner of N908JE from 2001 until October 05, 2019 when the registration was cancelled.
The aircraft was on the Part 125 certificate of JEGE Inc. and the CEO was Jeffrey EPSTEIN,
West Palm Beach, FL 33406 Phone
N908JE was certificated for passenger operations only (not cargo).
N908JE has a business configuration with a kitchen and bedroom and has approximately 25 seats in the aircraft and they
aren't economy seats.
It was used for private business not charter flights.
https://www.aircraft.com/aircraft/1237885/n908je-boeing-727-100
N908JE might be in Brunswick, Georgia (BQK). If you need confirmation of its location please advise.
I think Insured Aircraft Title Service in Oklahoma handled the transaction.
https://insuredaircraft.com/
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
In 1994, a 1974 Gulfstream G-1159B, serial number 151, N979GA was sold by Gulfstream to
Hyperion Air Inc., Wilmington, Delaware.
signed as the Chief Pilot and Jeffrey EPSTEIN signed as
President.
The signature of EPSTEIN looks similar to the signature on the N505JS that became N909JE documents.
In May 1994 they changed the tail number to N909JE. In 1999 and 2013 we see Darren K. INDYKE name on documents on
behalf of
Hyperion Air Inc. In November 2013 they sold N909JE to Starbridge Landing Inc., Dover, Delaware
).
The aircraft was deregistered on December 02, 2014 for export to Venezuela.
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxx
In March 2012, a 2001 Bell 430 helicopter, serial number 49078, N901RL was registered to Hyperion Air Inc.,
EFTA00023440

=== Page 5 ===
Wilmington, Delaware. Darren INDYKE signed the registration application as Corporate Secretary. In June 2012 they
changed the
tail number to N331JE. In August 2013 they transferred N331JE to Hyperion Air LLC,
St.
Thomas, U.S. Virgin Islands.
The same players in the Inc and LLC are on the FAA registration paperwork Darren INDYKE and Lawrence VISOSKI.
In November 2019 they provide phone number
In May 2020 they sold helicopter N331JE to CMG Aircraft Leasing Inc., Miami, FL (broker), who sold it the same day to QIR
Air Resources LLC,
Salt Lake City, Utah. In July 2020 they changed the tail number to N430D.
No other aircraft registered to or indexed to Hyperion Inc or LLC, and none to Ossa Properties Inc.
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
On May 30, 2013, 1988 Gulfstream G-IV, serial number 1085, tail number N423TT was registered to;
JEGE, LLC
St. Thomas, U.S. Virgin Islands 00802
The registrant was Lawrence VISOSKI, he signed as Manager
In July 2013 they (Lawrence VISOSKI) changed the tail number to N212JE. In August 2017, they (Lawrence VISOSKI)
changed the tail number to N120JE.
According to the JEGE LLC, statement in support of registering aircraft submitted to the FAA in 2013, JEGE LLC was
established in St. Thomas, U.S. Virgin Islands
on October 19, 2012 and the members were Jeffrey EPSTEIN and Lawrence VISOSKI.
In June 2019, an Aircraft Security Agreement for $2,800,000.00 on N120JE was filed with the FAA reflecting JEGE Inc.,
Powder Springs, GA 30127
as assignor and
New Bern, NC 28562 as secured party.
According to the JEGE LLC, statement in support of registering aircraft submitted to the FAA in 2019, JEGE LLC was
established in St. Thomas, U.S. Virgin Islands
on October 19, 2012 and the members were Aviation Development Group LLC and the manager was Thomas H. Huff.
He is Thomas Harrison HUFF
Ika/Powder Springs, GA
He's a pilot and has been involved in aviation at the Cobb County airport (RYY), in Kennesaw, GA for many years.
He is of interest to DEA S/A
in Atlanta, GA
The aircraft is still registered to JEGE LLC, St. Thomas, U.S. Virgin Islands.
I suspect HUFF bought JEGE LLC which included the aircraft.
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxx
On December 30, 2008, Sikosrksy Aircraft helicopter, S-76C-2, serial number 760750, tail number N750A was sold to;
Air Ghislaine Inc
Wilmington, Delaware 19803
The registrant was Larry VISOSKI, he signed as Director of Aviation
On February 11, 2010, Air Ghislaine Inc changed their name to Shmitka Air Inc.
In March 2010, Air Ghislaine Inc changed the tail number from N750A to N722JE. On the 8050-64 the signature is not
legibile but it looks
similar to the signature of Lawrence VISOSKI. He signed as Director of Operations for Shmitka Air Inc., f/k/a Air Ghislaine
Inc.
EFTA00023441

=== Page 6 ===
On August 25, 2010, N722JE was registered to Freedom Air International Inc.,
Wilmington,
Delaware 19803
The registrant was Darren K. INDYKE, he signed as Vice President
According to a bill of sale dated July 26, 2011, Freedom Air International (Darren K. INDYKE) sold N722JE to ASI Wings LLC,
Hartford, CT
On June 13, 2019, ASI Wings LLC sold N722JE to Hyperion Air LLC,
St. Thomas, U.S. Virgin
Islands
The registrant was Lawrence P. VISOSKI Jr., he signed as Manager
Per a bill of sale dated May 13, 2021, Hyperion Air LLC (Larry VISOSKI) sold N722JE to Industrial Integrity Solutions Inc.,
Ontario, CA
signed as CFO.
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
On January 29, 2000, Air Ghislaine Inc, Wichita, KS purchased 6.25% in a Beech 400A jet, serial number RK-260, tail
number N787TA.
On May 01, 2009, Air Ghislaine Inc., sold their 6.25% to Flight Options LLC in Richmond Heights, Ohio.
signed the bill of sale as
Executive Vice President of Flight Options LLC, acting as attorney-in-fact for Air Ghislaine Inc.
(this aircraft is currently assigned tail number N727KB)
Flight Options provides fractional jet ownership.
To identify the persons behind Air Ghislaine Inc., contact Flight Options LLC in Ohio.
http://www.flightoptions.com/
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
On May 01, 2009, Air Ghislaine Inc., Richmond Heights, Ohio purchased 6.25% in a Beech 400A jet, serial number RK-244,
tail number N439LX.
On February 11, 2010, Air Ghislaine Inc. changed their name to Shmitka Air Inc. and on July 06, 2010 Shmitka Air Inc.
changed their name to
Freedom Air International Inc.
On June 02, 2011, Freedom Air International Inc sold their 6.25% share in N439LX to Flight Options LLC in Cleveland, Ohio.
signed the bill of sale as Director of Sales Administration of Flight Options LLC, acting as attorney-in-fact
for
Freedom Air International Inc.
(this aircraft is currently assigned tail number N188TH)
Flight Options provides fractional jet ownership.
To identify the persons behind Shmitka Air Inc and Freedom Air International Inc., contact Flight Options LLC in Ohio.
http://www.flightoptions.com/
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Bell 407, serial number 53375, G-IORB was deregistered by the United Kingdom civil aviation authority on November 04,
2002 for
export to the United States. G-IORB was sold on October 30, 2002 to;
Air Ghislaine Inc
EFTA00023442

=== Page 7 ===
New York, NY 10022
It was registered as N491GM on November 13, 2002 to;
Air Ghislaine Inc
Wilmington, Delaware
The signature of the registrant is illegible but looks like that of VISOSKI.
Based on a name change from Air Ghislaine Inc to Shmitka Air Inc, the aircraft was registered on February 23, 2010 to
Shmitka Air Inc
Wilmington, DE
The registrant was Darren K. INDYKE, he signed as Vice President
Based on a name change from Shmitka Air Inc to Freedom Air International Inc, the aircraft was registered on August 25,
2010 to
Freedom Air International Inc
Wilmington, DE
The registrant was Darren K. INDYKE, he signed as Vice President
On April 30, 2012, Freedom Air International Inc (Darren K. INDYKE) sold N491GM to Eagle Copters Ltd in Calgary, Canada.
The aircraft was registered in a trust and subsequently deregistered on May 07, 2012 for export to Canada.
It was later re-registered in the U.S. with tail number N405PJ.
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
1997 Sikorsky S-76C helicopter, serial number 760472, N162AE was sold on July 26, 2021 by ASI Wings Inc
(
) to
Freedom Air International Inc.
Sikorsky S-76C helicopter N162AE was registered on August 2011 to;
Freedom Air International Inc
Wilmington, Delaware
The registrant was Darren K. INDYKE, he signed as Vice President.
They changed the tail number in August 2011 to N162AD. Lawrence VISOSKI signed the 8050-64 as Director of
Maintenance of
Freedom Air International Inc to change the tail number from N162AE to N162AD.
Per a bill of sale dated February 09, 2012, Freedom Air International Inc. (Darren K. INDYKE) sold N162AD to
Greenwich Aerogroup Inc Brazil Leasing Inc
Middletown, Delaware
N162AD was deregistered on April 10, 2013 for export to Brazil.
I ordered Blue Ribbon (certified) copies of the aircraft registration records of the ten aircraft and they will be sent via
regular mail from the FAA in Oklahoma.
EFTA00023443

=== Page 8 ===
In the next few hours you will receive an email with links to working copies of these aircraft registration files.
No other aircraft registered to or indexed to Hyperion Inc/LLC, Plan D LLC, Ossa Properties Inc. or
Jeffrey Epstein
Ghislaine Maxwell
Thomas World Air LLC
Freedom Air Petroleum LLC
NES LLC
Maple, Inc.
Nautilus Inc.
No FAA certificates issued to Darren INDYKE.
I hope this helps,
Special Agent
Federal Aviation Administration
Law Enforcement Assistance Program
Atlanta, GA
From:
Sent: Wednesday, August 18, 2021 1:08 PM
To:
Cc:
>;
Subject: RE: FAA Question
Thanks,
From:
Sent: Wednesday, August 18, 2021 1:07 PM
To:
Cc:
is
(
is
Subject: RE: FAA Question
In 2015/2016, DEA S/A
was interested in EPSTEIN and his aircraft;
Special Agent
Saint Thomas Resident Office
Drug Enforcement Administration
Saint Thomas, Virgin Islands 00802
EFTA00023444

=== Page 9 ===
In August 2019, the FBI in Atlanta, GA was interested in aircraft linked to EPSTEIN.
More will follow.
Special Agent
Federal Aviation Administration
Law Enforcement Assistance Program
Atlanta, GA
From:
Sent: Wednesday, August 18, 2021 12:41 PM
To:
Cc:
is
)
>;
Subject: RE: FAA Question
Hi
Thanks again for the helpful call this morning. Here is the list of entities we'd like you to use as search terms:
Jeffrey Epstein
Ghislaine Maxwell
Air Ghislaine
Thomas World Air LLC
Hyperion Air LLC
Freedom Air Petroleum LLC
NES LLC
Maple, Inc.
Nautilus Inc.
Thanks,
From:
Sent: Tuesday, August 17, 2021 3:56 PM
To:
Cc:
is
(
is
)
Subject: Re: FAA Question
Anytime after 0930 is preferable.
Special Agent
EFTA00023445

=== Page 10 ===
Federal Aviation Administration
Atlanta, GA
From:
Sent: Tuesday, August 17, 2021 3:53:43 PM
To:
Cc:
is
(
>;
Subject: RE: FAA Question
Thanks,
We'll plan to give you a call tomorrow morning, assuming you're free to talk then.
Thanks,
From:
Sent: Tuesday, August 17, 2021 3:30 PM
To:
Cc:
is
(
i
Subject: RE: FAA Question
Hi!
Feel free to call my cell at your convenience.
Happy to help,
Special Agent
Federal Aviation Administration
Law Enforcement Assistance Program
Atlanta, GA
From:
Sent: Tuesday, August 17, 2021 3:25 PM
To:
Cc:
>;
V.
Subject: FAA Question
Hi
I hope all's well. I got your email from
at the FBI. We are working on a case and could use some assistance
from the FAA. Do you have a few minutes to talk sometime this week?
EFTA00023446

=== Page 11 ===
Thanks,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00023447


c1: EFTA00021362
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021362.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Cc:
)"
(USANYS)"
Subject: RE: Jeffrey Epstein/FOIA matters
Date: Wed, 17 Mar 2021 17:12:20 +0000
It appears that we only have 2 FOIA cases on Epstein
NY Times case before Judge Engelmayer and
Radar Online case before Judge Gardephe, 17 Civ. 3956 (PGG).
Please let me know if I can help in any way.
From:
Sent: Tuesday, March 16, 2021 6:09 PM
To:
(USANYS)
Cc:
is
(USANYS)
Subject: Re: Jeffrey Epstein/FOIA matters
Hi
Just following up to see if you found out anything from the civil clerks. Thanks for your help with this.
Best,
On Mar 12, 2021, at 11:22 AM,
wrote:
Thanks,
Much appreciated.
From:
(USANYS)
Sent: Friday, March 12, 2021 11:18 AM
To:
Cc:
is
(USANYS)
;
(USANYS)
Subject: Re: Jeffrey Epstein/FOIA matters
Hi
I am copying
who is handling the main matter before Judge Engelmayer and who likely
would know if there are related FOIAs. I will also ask our civil clerk.
Sent from my iPhone
EFTA00021362

=== Page 2 ===
On Mar 12, 2021, at 10:59 AM,
wrote:
Hi
In connection with a criminal discovery matter,
and
and I are trying to find a list of all Jeffrey Epstein-
related FOIA lawsuits that the Civil Division has handled (either pending or historical). Our chiefs suggested that you
might be able to help us generate that list - if you have any guidance or information on how we could track this down,
we'd really appreciate your help. Or if there's someone else we should reach out to in the Civil Division instead, please
let us know.
Thanks so much-
Assistant United States Attorney
Southern District of New York
EFTA00021363


c1: EFTA00021414
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021414.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
,
)"
Subject: RE: photos
Date: Tue, 16 Jul 2019 17:50:12 +0000
Importance: Normal
Attachments: 2019-07-16,_JE,_detention_submission.docx
Updated version.
From:
Sent: Tuesday, July 16, 2019 1:46 PM
To:
Cc:
(USANYS)
is
is
(USANYS)
Subject: Re: photos
I can look now too
Sent from my iPhone
On Jul 16, 2019, at 13:41,
)
wrote:
Just finished reviewing and discussing my thoughts with
now.
From:
(USANYS)
Sent: Tuesday, July 16, 2019 1:39 PM
To:
is
(USANYS)
Cc:
is
Subject: RE: photos
Are
and
able to look now? If it will be a while, we will review the interim version.
From:
Sent: Tuesday, July 16, 2019 1:32 PM
To:
(USANYS)
Cc:
(USANYS)
i
)
is
)
Subject: RE: photos
Just sent to
and
for a first look, and will circulate shortly after I input their comments. Thanks.
From:
(USANYS)
Sent: Tuesday, July 16, 2019 1:19 PM
To:
Cc:
(USANYS)
is
)
is
)
Subject: Re: photos
Okay. What is timing on a draft?
EFTA00021414

=== Page 2 ===
Sent from my iPhone
On Jul 16, 2019, at 12:07 PM,
wrote:
FYI, I spoke with Judge Berman's chambers and the clerk told me the Judge does not want to see photographs (he did
not explain), so we are not going to bring them to chambers.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00021415


c1: EFTA00023341
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023341.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To
)"
Subject: RE: Steptoe
Date: Mon, 09 Mar 2020 00:50:56 +0000
Indeed.
From
)
Sent: Sunday, March 08, 2020 20:50
To:
Subject: Re: Steptoe
Can't say I feel bad for Steptoe about this.
Sent from my iPhone
On Mar 8, 2020, at 7:05 PM,
wrote:
oops
https://www.detroitnews.com/story/news/local/michigan/2020/03/07/university-of-michigan-switches-firm-repped-
jeffery-epstein-roman-polanski-robert-anderson/4990660002/
Assistant U.S. Attorney
Southern District of New York
EFTA00023341


c1: EFTA00021075
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021075.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: added this to the folder
Date: Wed, 29 Jan 2020 22:09:41 +0000
Attachments: 2019-09-10,
interview_notes.pdf
Assistant U.S. Attorney
Southern District of New York
EFTA00021075


c1: EFTA00023087
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023087.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:19-cr-00830-AT Document 59 Filed 05/25
Page 5
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 5/25/2021
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
United States of America
Deferred Prosecution Agreement
v.
19 Cr. 830 (AT)
Tova Noel,
Defendant.
TO:
TOVA NOEL
On November 19, 2019, a grand jury sitting in this District returned a six-count indictment
(the "Indictment"), which charged Tova Noel ("you") with committing offenses against the United
States, to wit, conspiring to knowingly defraud the United States and to knowingly make and use
a false writing or document, in violation of 18 U.S.C. § 371, and five counts of knowingly making
and using a false writing or document, in violation of 18 U.S.C. § 1001. However, after a thorough
investigation, and based on the facts of this case and your personal circumstances, the U.S.
Attorney's Office for the Southern District of New York ("USAO-SDNY") has determined that
the interests of justice will best be served by deferring prosecution in this District. Upon your
acceptance of responsibility for your behavior and by your signature on this deferred prosecution
agreement (the "Agreement"), prosecution will be deferred during the term of your behavior and
satisfactory compliance with the terms of this Agreement for the period of six months from the
date of this Agreement.
The terms and conditions constituting your good behavior and satisfactory compliance are
as follows:
(1)
You shall refrain from violating any federal, state, or local law. You shall immediately
contact your U.S. Pretrial Services Officer if arrested or questioned by a law-
enforcement officer.
(2)
You shall associate only with law-abiding persons.
(3)
You shall work regularly at a lawful occupation, regularly attend school, and/or support
or care for your legal dependents, if any, to the best of your ability, as approved by your
U.S. Pretrial Services Officer. You shall notify your supervising U.S. Pretrial Services
Officer prior to any work or school changes.
(4)
You shall not leave the contiguous United States without permission of your
supervising U.S. Pretrial Services Officer. In accordance with this condition, the U.S.
Pretrial Services Office shall return your passport upon the Court's entering this
Agreement, and shall do so indefinitely unless this Agreement is violated.
= 1 -
EFTA00023087

=== Page 2 ===
Case 1:19-cr-00830-AT Document 59 Filed 05/25/21 Page 2 of 5
(5)
You shall notify your supervising U.S. Pretrial Services Officer immediately of any
change in your place of residence.
(6)
You shall follow your supervising U.S. Pretrial Services Officer's instructions and
advice.
(7)
You shall report to your supervising U.S. Pretrial Services Officer as directed.
As a further condition you hereby consent to disclosure, by any federal, state, or local
government agency, or by any medical or substance abuse treatment provider, to the U.S. Pretrial
Services Officer supervising your case, of such medical and treatment records as may be requested
by the Pretrial Services Officer to evaluate deferral of prosecution in this case. You further agree
that you will execute any additional consent forms that any such agency or provider may require
to release such information.
Special conditions are as follows:
You shall truthfully and completely disclose all information with respect to the activities
of yourself and others related to your employment by the Bureau of Prisons ("BOP"), which
information can be used for any purpose. You shall agree to meet with and be interviewed by the
USAO-SDNY, the Federal Bureau of Investigation, the Department of Justice, Office of the
Inspector General ("DOJ-OIG"), and any other law enforcement agency designated by this Office.
You shall complete 100 documented hours of community service, preferably related to the
criminal justice system, including working with recently released inmates. The specific type of
community service to be performed must be approved by your Pretrial Services Officer.
The USAO-SDNY may at any time revoke or modify any condition of this provisional
release or change the period of such supervision, which shall in no case exceed six months. The
USAO-SDNY may discharge you from supervision at any time. The USAO-SDNY may at any
time proceed with the prosecution for this offense should the USAO-SDNY, in its sole discretion,
deem such action advisable.
If upon completion of your supervision a written report from your supervising U.S. Pretrial
Services Officer is received to the effect that you have complied with all the rules, regulations and
conditions and special conditions applicable to your deferred prosecution, no further prosecution
will be instituted in this District for the above offenses.
Nothing in this Agreement shall be interpreted to preclude the BOP or the DOJ-OIG from
taking any administrative action against you, including suspension or termination of employment,
based on the facts alleged in the Indictment, the facts identified in the course of the investigation
that led to the Indictment, or your own statements to the DOJ-OIG or any other law enforcement
entity. Nothing in this Agreement shall be interpreted to require the BOP or the DOJ-OIG to delay
2 -
EFTA00023088

=== Page 3 ===
Case 1:19-cr-00830-AT Document 59 Filed 05/25/21 Page 3 of 5
any administrative action until after the expiration of the period of deferment contemplated by this
Agreement. You agree that a copy of this Agreement, including your admission and acceptance
of responsibility, shall be provided to the BOP.
*
*
*
If you successfully complete the term of supervision and fulfills all the terms and
conditions of this Agreement, the Government will move the Court to dismiss the Indictment as to
the defendant.
It is further understood that this Agreement and the terms and conditions set forth herein
are limited to the facts and circumstances of this case and lack precedential value.
Dated: New York, New York
May 20, 2021
United States Attorney for the
Southern District of New York
By:
Assistant United States Attorneys
3 -
EFTA00023089

=== Page 4 ===
Case 1:19-cr-00830-AT Document 59 Filed 05/25/21 Page 4 of 5
The undersigned hereby consents to the foregoing. The undersigned hereby further admits
that she willfully and knowingly completed materially false count and round slips regarding
required counts and rounds in the Special Housing Unit of the Metropolitan Correctional Center
("MCC") on August 9, 2019 and August 10, 2019. The undersigned expressly waives any and all
rights to a speedy trial pursuant to the Sixth Amendment to the United States Constitution, the
Speedy Trial Act, §§ 3161 et seq., and any other pertinent provisions, and consents to the
adjournment of all pending proceedings in this case. The undersigned further waives the
applicable statute of limitations with respect to any prosecution that is not time-barred on the date
that this agreement is signed. It is the intent of this provision to toll the applicable statute of
limitations during the pendency of the deferred prosecution.
The undersigned understands that pursuant to Title 18, United States Code, Section
3161(h)(2), this Agreement is subject to approval by the Court. Should the Court refuse to
approve, and thereby reject, this Agreement, neither party shall be bound to any term of this
Agreement, and no admissions in this Agreement may be used against the undersigned.
Finally, the undersigned acknowledges that she has read this Agreement and has carefully
reviewed each provision with her attorney. The undersigned and her attorney acknowledge that
no threats, promises, or representations have been made, nor agreements reached, other than those
set forth in this Agreement. The undersigned further acknowledges that she understands and
voluntarily accepts each and every term and condition of this Agreement.
Dated: New York, New York
May 2021
Attorney J-17 for Defendant
1
9
Jason Foy, Esq.
Tova Noel
Defendant
4
EFTA00023090

=== Page 5 ===
Case 1:19-cr-00830-AT Document 59 Filed 05/25/21 Page 5 of 5
Pursuant to 18 U.S.C. $3161(h)(2), exclusion under the Speedy Trial Act of the period of
time during which the prosecution of the defendant is deferred pursuant to this Agreement is
hereby approved.
Dated: New York, New York
May 25, 2021
as
Honorable Analisa Torres
United States District Judge
The undersigned hereby consents to the foregoing and will accept supervision of the
above-named defendant on the conditions set forth herein.
Dated: New York, New York
May 24, 2021
United States Pretrial Services
Officer
- -5-
EFTA00023091


c1: EFTA00021530
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021530.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB)
Date: Thu, 01 Aug 2019 23:02:50 +0000
Great, thanks. I'm going to email her and take it from there. Thanks all.
Sent from my iPhone
On Aug 1, 2019, at 6:58 PM
wrote:
That's correct. This is the same attorney I spoke with you about that called our hotline last night.
-
On Aug 1, 2019 6:54 PM,
wrote:
Thanks
I think this same attorney called the FBI, so I've copied
so we are all on the same
page. I will contact this attorney and discuss next steps.
Sent from my iPhone
On Aug 1, 2019, at 6:20 PM,
wrote:
I do not mind assisting these two woman with travel.
Sent from my iPhone
Begin forwarded message:
From: Colleen Mullen <
Date: August 1, 2019 at 5:55:06 PM EDT
To:
Cc:
Subject: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear
The Bloom Firm represents two women who allege they were fraudulently recruited and enticed
by Epstein and/or his agents to perform a personal massage on him at his private residence,
located at 9 East 71st St., New York, NY 10021, in exchange for hundreds of dollars that
resulted in Epstein forcefully sexually assaulting our clients in what we believe is in violation of
Title 18, United States Code, Sections 1591(a) and (b). Our clients believe they were assaulted
EFTA00021530

=== Page 2 ===
by Epstein in or around June 2004. Our clients did not consent or agree to any sexual touching
or activity with Mr. Epstein. Our clients are also concerned, after learning about the pictures
recovered from Mr. Epstein's home, that sexually explicit pictures were unknowingly taken of
them during the incidents.
Our clients' names are
Please
be advised, our clients wish to remain anonymous at this juncture and do not consent to their
names being released to the public. Please advise immediately if it appears as if our clients'
identities will be released to the public and/or Mr. Epstein's legal team. If revealing the identities
is necessary for the case to move forward, please advise prior to doing so, so that our clients
can make an informed decision.
We understand your office may be interested in interviewing our clients for additional details. We
can help coordinate a time for you to interview our clients in New York.
Please let us know if you need any additional information at this time; otherwise, we look
forward to hearing from you soon.
Best,
Colleen
Colleen M. Mullen, Esq.
This message is for the designated recipient only and may contain privileged, proprietary, or
otherwise private information. If you have received it in error, please notify the sender
immediately and delete the original. Any other use of the email by you is prohibited.
EFTA00021531


c1: EFTA00021297
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021297.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
STATES
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
September 9, 2019
Florence Hutner, Esq.
General Counsel
Office of the Chief Medical Examiner
421 East 26th Street
New York, New York
Re: Autopsy Report and File for Jeffrey Epstein
Dear Ms. Hutner:
By letter dated August 28, 2019, the United States Attorney's Office for the Southern
District of New York ("USAO") requested that the OCME withhold from disclosure to any third
party (i) "any documents, evidence or information made available to OCME by the USAO or the
FBI-including documents, records, or materials from the MCC-or created by OCME or within
the OCME case file that include, reflect, or contain information made available to OCME by the
USAO or FBI"; and (ii) "the names and identifying information of any federal law enforcement
agents or employees who were interviewed by the OCME, along with the substance of any
statements or interviews made by those agents or employees" (the "August 28 Letter").
At OCME's request, the USAO has made proposed redactions to the version of the OCME
report and file for Jeffrey Epstein that was previously provided by OCME to the FBI, consistent
with the requests set forth in the August 28 Letter. That redacted document is attached hereto. For
the reasons set forth in the August 28 Letter, we also request that OCME withhold from disclosure
to any third party any photographs of the scene at the MCC. Finally, in order to preserve the
integrity of the ongoing investigation, in addition to the requests set forth in the August 28 Letter,
we also request that OCME withhold from disclosure to any third party this letter and its
attachment, and the August 28 Letter. We appreciate your willingness to comply with these
requests. Please contact us with any further questions.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
by:
/s/
Encl.
EFTA00021297


c1: EFTA00020711
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020711.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 1 of 18
JANE DOE V. UNITED STATES
COURT FILE NO. 08-80736-CV-MARRA
SECOND SUPPLEMENTAL PRIVILEGE LOG - BOX #4
Bates Range
Description
Privilege(s) Asserted
P-013970
11/29/2006-12/1/2006 emails between Marie Villafaña and prison
Work Product
thru
employee regarding attempted contact with potential witness
Investigative Privilege
P-013971
Privacy Act
P-013972
5/18/2007 email from Marie Villafaña to Matt Menchel informing him
Work Product
of intent to subpoena Roy Black's private investigator and steps taken to
6(e)
obtain DOJ authorization
Deliberative Process
Investigative Privilege
P-013973
5/18/2007 emails between Marie Villafaña and expert witness regarding
Work Product
thru
securing pre-indictment consultation contract
6(e)
P-013976
Investigative Privilege
P-013977
5/21/2007 email from Marie Villafaña to Myesha Braden (CEOS) re
Work Product
thru
2423(b) charging question
6(e)
P-013979
Deliberative Process
Investigative Privilege
P-013980
5/21/2007 email from Marie Villafaña to Matt Menchel and Jeff Sloman
Work Product
regarding guidance on grand jury presentation
6(e)
Deliberative Process
P-013981
5/22/2007 email from Andy Lourie to Matt Menchel and Jeff Sloman
Work Product
(cc: Marie Villafaña) re letter received from Gerald Lefcourt discussing
Deliberative Process
a meeting to discuss Epstein investigation
P-013982
5/23/2007 email from Jason Richards to Marie Villafaña re extradition
Work Product
research
A/C privilege
Investigative Privilege
P-013983
5/23/2007 emails between Karen Atkinson and Marie Villafaña
Work Product
thru
regarding decision to meet with counsel for Epstein
Deliberative Process
P-013984
Page 1 of 18
EFTA00020711

=== Page 2 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 2 of 18
Bates Range
Description
Privilege(s) Asserted
P-013985
6/14/2007-6/21/2007 emails between Marie Villafaña, Karen Atkinson,
6(e)
thru
Andrew Lourie, Matt Menchel, and Jeff Sloman regarding addendum to
Work Product
P-013989
Pros Memo, grand jury presentation and changes to indictment, and
Deliberative Process
meeting with counsel for Epstein
Investigative Privilege
P-013990
6/26/2007 email from Marie Villafaña to Jeff Sloman, Matt Menchel,
Work Product
thru
and Andrew Lourie addressing arguments regarding interstate nexus for
Deliberative Process
P-013991
2422(b) charges
P-013992
7/3/2007-7/4/2007 emails between Marie Villafaña and Andrew Lourie
6(e)
thru
regarding extension of time to respond to subpoenas requested by Lilly
Work Product
P-013994
Ann Sanchez and possible resolution of case
Investigative Privilege
Deliberative Process
P-013995
6/12/2007-7/6/2007 series of emails between Marie Villafaña and
Work Product
thru
AUSAs Serene Nakano and James Cott re an earlier unrelated
Investigative Privilege
P-014010
investigation of Epstein
Privacy Act
P-014011
7/3/2007-7/13/2007 email chain between Matt Menchel and Marie
6(e)
thru
Villafaña regarding disagreement on Menchel's plea negotiations and
Work Product
P-014025
written request for meeting between USAO management and victims
Deliberative Process
Investigative Privilege
P-014026
7/16/2007 email from Marie Villafaña to Matt Menchel and Andrew
6(e)
thru
Lourie regarding correspondence from Roy Black and Motion to Quash
Work Product
P-014027
Deliberative Process
Investigative Privilege
P-014028
7/18/2007 emails from Marie Villafaña to Andrew Lourie and Matt
6(e)
thru
Menchel regarding Motion to Quash grand jury subpoena and
Work Product
P-014030
supporting affidavit filed by Roy Black
Deliberative Process
Investigative Privilege
P-014031
7/19/2007 email chain between Marie Villafaña, Andrew Lourie, Matt
6(e)
thru
Menchel, S/A Jason Richards and S/A Eliasib Ortiz regarding potential
Work Product
P-014032
service of target letters
Deliberative Process
Investigative Privilege
Attorney-Client Privilege
Page 2 of 18
EFTA00020712

=== Page 3 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 3 of 18
Bates Range
Description
Privilege(s) Asserted
P-014033
7/19/2007 email from Marie Villafaña to Andrew Lourie and Matt
Work Product
Menchel regarding planned service of target letters
6(e)
Investigative Privilege
Deliberative Process
P-014034
7/26/2007 email from Marie Villafaña to Matt Menchel and Andrew
6(e)
Lourie regarding proposed changes to the indictment
Work Product
Deliberative Process
Investigative Privilege
P-014035
7/31/2007 email from Marie Villafaña to Jeff Sloman, Matt Menchel,
Work Product
and Andrew Lourie summarizing proposed plea terms as per Menchel
Deliberative Process
recommendation
P-014036
7/31/2007-8/2/2007 email chain between Jeff Sloman, Matt Menchel,
Work Product
Andrew Lourie, and Marie Villafaña regarding plea negotiations
Deliberative Process
Investigative Privilege
P-014037
8/2/2007 email drom Marie Villafaña to Jeff Sloman, Matt Menchel,
Work Product
and Andrew Lourie with draft response to Epstein counsel regarding
Deliberative Process
agreement
Investigative Privilege
P-014038
8/2/2007 emails between Matt Menchel, Jeff Sloman, Andy Lourie, and
Work Product
thru
Marie Villafaña regarding letter received from Lilly Ann Sanchez
Deliberative Process
P-014041
P-014042
8/3/2007 Email from Marie Villafaña to Matt Menchel, Andrew Lourie,
Work Product
Jeff Sloman, and Karen Atkinson regarding draft response to
Deliberative Process
correspondence from Epstein counsel and planned investigative steps if
Investigative Privilege
agreement cannot be reached.
P-014043
Emails dated 8/6/2007 from Marie Villafaña to Cyndee
Work Product
thru
Campos/Frederica Devlin and Jeff Sloman regarding Matt Menchel's
Deliberative Process
P-014044
correspondence prior to his departure.
P-014045
8/7/2007 email chain between Marie Villafaña, Cyndee Campos, and
Work Product
thru
Alex Acosta regarding meeting to discuss Epstein matter
Deliberative Process
P-014046
Investigative Privilege
Page 3 of 18
EFTA00020713

=== Page 4 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 4 of 18
Bates Range
Description
Privilege(s) Asserted
P-014047
8/7/2007 email from Marie Villafaña to Andy Lourie regarding deadline
Work Product
set for Epstein plea and Epstein's plan to demand a meeting with CEOS.
Deliberative Process
Investigative Privilege
P-014048
8/7/2007 email from Marie Villafaña to Andrew Oosterbaan regarding
Work Product
Epstein meeting
Deliberative Process
Investigative Privilege
P-014049
8/7/2007 email chain from Jeff Sloman to Andrew Oosterbaan, Marie
Work Product
thru
Villafaña, and Alex Acosta regarding Epstein meeting
Deliberative Process
P-014050
Investigative Privilege
P-014051
8/8/2007 emails between Marie Villafaña and Andrew Oosterbaan
Work Product
(CEOS) regarding case staffing and plea negotiations
Deliberative Process
Investigative Privilege
P-014052
8/8/2007 email chain between Andrew Oosterbaan, Alex Acosta, Marie
Work Product
Villafaña, Cyndee Campos, Jeff Sloman, and Andrew Lourie regarding
Deliberative Process
"The meeting on Epstein"
Investigative Privilege
P-014053
8/8/2007 email from Marie Villafana to Drew Oosterbaan regarding
Work Product
plea negotiations, guideline calculations, and assistance in preparing
Investigative Privilege
case for trial
Deliberative Process
P-014054
8/8/2007 email from Marie Villafaña to Alex Acosta, Cyndee Campos,
Work Product
Jeff Sloman, Andrew Lourie, and Drew Oosterbaan regarding planning
6(e)
meeting with Epstein counsel and service of target letters
Investigative Privilege
Deliberative Process
P-014055
8/10/2007 Electronic correspondence from Marie Villafaña to expert
Work Product
witness regarding topics for expert testimony
P-014056
8/10/2007 email from Marie Villafaña to Andrew Lourie regarding
Work Product
target letters and staying motion to compel production of computers
P-014057
8/30/2007 email from Marie Villafaña to Jeff Sloman, Andrew Lourie,
Work Product
Drew Oosterbaan, John McMillan, and Karen Atkinson regarding press
coverage of meeting with Ken Starr
P-014058
9/4/2007-9/6/2007 emails between Marie Villafana and Jeff Sloman
Work Product
regarding planned participation of FBI ASAIC at 9/7/2007 meeting with
Deliberative Process
Epstein defense team
Page 4 of 18
EFTA00020714

=== Page 5 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 5 of 18
Bates Range
Description
Privilege(s) Asserted
P-014059
9/6/2007 emails between Marie Villafaña, Jeff Sloman, Andrew Lourie
Work Product
thru
Drew Oosterbaan, and Rolando Garcia regarding status of plea
Deliberative Process
P-014061
negotiations, draft agreements, and need to confer with victims
P-014062
9/10/2007-9/14/2007 emails between Marie Villafaña, Andrew Lourie,
Work Product
thru
Jeff Sloman, Karen Atkinson, Rolando Garcia, Shawn Ball, and Alex
Deliberative Process
P-014068
Acosta regarding final plea negotiations, finalizing details with State
6(e)
Attorney's Office and final revisions to indictment package
Investigative Privilege
P-014069
9/10/2007 email from Marie Villafaña to Jeff Sloman and John
Work Product
McMillan regarding Acosta inquiry about FBI investigation into State
6(e)
grand jury proceeding
Investigative Privilege
P-014070
9/11/2007 emails between Marie Villafaña, John McMillan, Drew
Work Product
thru
Oosterbaan, Nesbitt Kuyrkendall, and Jason Richards regarding changes
Deliberative Process
P-014074
to the draft indictment and status of plea negotiations
Investigative Privilege
Attorney-Client Privilege
P-014075
9/10/2007-9/11/2007 emails between Marie Villafaña, Alex Acosta, and
Work Product
thru
Jeff Sloman regarding modifications to the proposed Non-Prosecution
Deliberative Process
P-014089
Agreement
P-014090
9/13/2007 emails from Marie Villafaña to Andrew Lourie, Alex Acosta,
Work Product
thru
Jeff Sloman, Rolando Garcia, and Karen Atkinson regarding plea to
Deliberative Process
P-014102
federal charges recommending 18 USC 403 or 1512(d), or 47 USC
223(a)(1)(B); response that Epstein was only willing to plead to assault
on the plane; and rejection of facts supporting assault on the plane
charge
P-014103
9/13/2007-9/14/2007 emails regarding Marie Villafaña research
Work Product
thru
regarding victim trust fund set up in Alaska child exploitation case
P-014107
P-014108
9/17/2007-9/19/2007 emails between Marie Villafaña, Rolando Garcia,
Work Product
thru
Andrew Lourie, Alex Acosta, Karen Atkinson, and John McMillan
Deliberative Process
P-014134
regarding negotiations of a federal plea and a non-prosecution
agreement
Page 5 of 18
EFTA00020715

=== Page 6 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 6 of 18
Bates Range
Description
Privilege(s) Asserted
P-014135
9/19/2007-9/20/2007 emails between Marie Villafaña, Andrew Lourie,
Work Product
thru
and Rolando Garcia regarding plea negotiations with counsel for
Deliberative Process
P-014149
Epstein
P-014150
9/20/2007 emails between Marie Villafaña and Andrew Lourie
Work Product
thru
regarding plea agreement to federal charges and factual proffer
Deliberative Process
P-014156
P-014157
9/21/2007 emails between Marie Villafaña and Andrew Lourie, Rolando
Work Product
thru
Garcia, Karen Atkinson, and John McMillan regarding revisions to the
Deliberative Process
P-014160
non-prosecution agreement
P-014161
9/21/2007 email from Marie Villafaña to Alex Acosta, Rolando Garcia,
Work Product
Karen Atkinson, and Andrew Lourie regarding review of Epstein
Deliberative Process
indictment package
P-014162
9/24/2007 series of emails between Marie Villafaña, Alex Acosta, and
Work Production
thru
Andrew Lourie regarding plea negotiations and revisions to non-
Deliberative Process
P-014170
prosecution agreement
P-014171
9/23/2007-9/24/2007 series of emails between Alex Acosta, Marie
Work Product
thru
Villafaña, Andrew Lourie, Rolando Garcia, and Jeff Sloman regarding
Deliberative Process
P-014174
proposed revisions to non-prosecution agreement
P-014175
9/20/2007-9/24/2007 emails between Alex Acosta, Marie Villafaña, and
Work Product
thru
Andrew Lourie regarding revisions to the non-prosecution agreement
Deliberative Process
P-014203
P-014204
9/24/2007 emails between Marie Villafaña and Rolando Garcia
Work Product
thru
regarding notifying Palm Beach Police Chief and victims about
Deliberative Process
P-014205
agreement
P-014206
9/24/2007-9/25/2007 emails between Alex Acosta, Marie Villafaña,
Work Product
thru
Andrew Lourie, and Rolanda Garcia regarding Lefkowitz email about
Deliberative Process
P-014216
keeping agreement from becoming public and confidentiality provision
in agreement
P-014217
10/5/2007-10/16/2007 emails between Marie Villafaña, Jeff Sloman,
Work Product
thru
and Alex Acosta re selection of Special Master and negotiation of
Deliberative Process
P-014238
revision/addendum to Non-Prosecution Agreement
Page 6 of 18
EFTA00020716

=== Page 7 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 7 of 18
Bates Range
Description
Privilege(s) Asserted
P-014239
10/18/2007 emails between Marie Villafaña and Jeff Sloman regarding
Work Product
thru
Epstein's request to delay his change of plea
Deliberative Process
P-014242
P-014243
10/19/2007 emails between Jeff Sloman and Marie Villafaña regarding
Work Product
thru
Special Master's Selection of Attorney Representative
Deliberative Process
P-014251
P-014252
10/22/2007-10/31/2007 emails between Jeff Sloman, Alex Acosta, and
Work Product
thru
Marie Villafaña regarding negotiation of Addendum to Non-Prosecution
Deliberative Process
P-014275
Agreement and drafting of correspondence regarding scope of Special
Master's duties and selection criteria
P-014276
10/31/2007 email from Nesbitt Kurykendall to Marie Villafaña
Work Product
regarding attempts to interview additional witnesses/victims
Attorney-Client Privilege
Investigative Privilege
6(e)
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
P-014277
11/2/2007-11/5/2007 emails between Marie Villafaña and Jeff Sloman
Work Product
thru
regarding drafting 11/5/2007 letter from Sloman to Lefkowitz
Deliberative Process
P-014282
P-014283
11/5/2007-11/7/2007 emails from Marie Villafaña to Jeff Sloman
Work Product
thru
inquiring about status of matter and contact by Epstein investigators
Deliberative Process
P-014284
with victims
P-014285
11/8/2007-11/14/2007 emails between Marie Villafaña, Jeff Sloman,
Work Product
thru
Karen Atkinson, and Jason Richards regarding response to objections
Deliberative Process
P-014298
raised by Epstein counsel and efforts to change date for guilty plea
Attorney-Client Privilege
P-014299
11/14/2007-11/19/2007 emails between Marie Villafaña, Jason
Work Product
thru
Richards, Jeff Sloman, Rolando Garcia, Alex Acosta, and Karen
Deliberative Process
P-014307
Atkinson regarding communications with State Attorney's Office and
Attorney-Client Privilege
Sheriff's Office in an attempt to insure that Epstein was ineligible for
work release
Page 7 of 18
EFTA00020717

=== Page 8 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 8 of 18
Bates Range
Description
Privilege(s) Asserted
P-014308
11/19/2007 emails between Marie Villafaña, Jeff Sloman, and Rolando
Work Product
thru
Garcia about efforts by Epstein's counsel to change date for change of
Deliberative Process
P-014310
plea
P-014311
11/19/2007-11/28/2007 emails between Marie Villafaña, Nesbitt
Work Product
thru
Kuyrkendall, Jason Richards, and Jeff Sloman regarding drafting victim
Deliberative Process
P-014329
notification letter of upcoming plea
Attorney-Client Privilege
6(e)
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
P-014330
11/28/2007 correspondence between Marie Villafaña, Andrew Lourie,
Work Product
thru
Drew Oosterbaan, and Rolando Garcia regarding Lefkowitz 11/27/2007
Deliberative Process
P-014337
email discussing presentation to DAAG
P-014338
11/29/2007-12/1/2007 emails between Marie Villafaña, Alex Acosta,
Work Product
thru
Jeff Sloman, Cyndee Campos, and Andrew Lourie regarding draft
Deliberative Process
P-014354
response to Jay Lefkowitz and victim notification letters
P-014355
12/3/2007 emails between Marie Villafaña, Alex Acosta, and Jeff
Work Product
thru
Sloman regarding history of plea negotiations and drafting response to
Deliberative Process
P-014361
correspondence from Jay Lekowitz and Ken Starr
P-014362
12/3/2007-12/5/2007 correspondence between Alex Acosta, Jeff
Work Product
thru
Sloman, Marie Villafaña, Nesbitt Kuyrkendall, Cyndee Campos, and
Deliberative Process
P-014402
Annette Castillo about drafting and sending the 12/4/2007 Acosta letter
6(e)
to Ken Starr
Attorney-Client Privilege
P-014403
12/6/2007 emails between Marie Villafaña, Andrew Lourie, Cyndee
Work Product
thru
Campos, Jeff Sloman, Alex Acosta, Karen Atkinson, and Nesbitt
Deliberative Process
P-014414
Kuyrkendall regarding correspondence from Ken Starr, request for a
meeting from Epstein counsel, and need to notify victims of upcoming
plea
P-014415
12/6/2007-12/7/2007 emails between Marie Villafaña, Cyndee Campos,
Work Product
thru
Karen Atkinson, Jeff Sloman, and Alex Acosta regarding draft victim
Deliberative Process
P-014420
notification letter
Page 8 of 18
EFTA00020718

=== Page 9 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 9 of 18
Bates Range
Description
Privilege(s) Asserted
P-014421
12/6/2007-12/7/2007 emails between Marie Villafaña, Nesbitt
Work Product
thru
Kuyrkendall, Jason Richards, Jeff Sloman, Cyndee Campos, Annette
Deliberative Process
P-014428
Castillo, Karen Atkinson, and Shawn Ball regarding request from State
6(e)
Attorney's Office for draft plea proffer
Attorney-Client Privilege
Investigative Privilege
P-014429
12/9/2007-12/12/2007 emails between Marie Villafaña, Jeff Sloman,
Work Product
thru
Jason Richards, Nesbitt Kuyrkendall, Annette Castillo, Karen Atkinson,
Deliberative Process
P-014439
and Rolando Garcia regarding drafting response to personal attacks and
upcoming meeting with Ken Starr
P-014440
12/11/2007 email from Marie Villafaña to Jeff Sloman and Alex Acosta
Work Product
regarding call with lawyer for Jane Doe #2 (T.M.)
Deliberative Process
P-014441
12/12/2007 emails between Marie Villafaña, Frederica Devlin, and Bob
Work Product
Senior regarding planning indictment review
Deliberative Process
6(e)
P-014442
12/14/2007 email from Marie Villafaña to Jeff Sloman, Alex Acosta,
Work Product
and Janice LeClainche regarding state cases mentioned by Epstein's
Deliberative Process
counsel
P-014443
12/14/2007 email from Marie Villafaña to Alex Acosta, Jeff Sloman,
Work Product
Rolando Garcia, and Karen Atkinson with draft letters to State
Deliberative Process
Attorney's Office and victims
P-014444
12/17/2007 email from Marie Villafaña to Jeff Sloman inquiring about
Work Product
case status and informing Sloman regarding agent concern about victim
Deliberative Process
notifications
P-014445
12/19/2007 email from Marie Villafaña to Alex Acosta and Jeff Sloman
Work Product
thru
summarizing research into other cases where individuals were charged
Deliberative Process
P-014447
with violating 2422(b) based upon the use of a telephone
6(e)
P-014448
12/19/2007 emails between Marie Villafaña, Alex Acosta, and Jeff
Work Product
thru
Sloman regarding drafting response to concerns raised during December
Deliberative Process
P-014454
14, 2007 meeting between Epstein counsel, Alex Acosta, Jeff Sloman,
the FBI SAIC, and Marie Villafaña
Page 9 of 18
EFTA00020719

=== Page 10 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 10 of
18
Bates Range
Description
Privilege(s) Asserted
P-014455
12/19/2007 email from Marie Villafaña to Alex Acosta, Jeff Sloman,
Work Product
thru
and Janice LeClainche regarding challenge to state charge raised by
Deliberative Process
P-014456
Epstein counsel during 12/14/2007 meeting
6(e)
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
P-014457
12/20/2007 emails between Marie Villafaña and Jeff Sloman regarding
Work Product
thru
inquiries from State Attorney's Office regarding Epstein plea to state
Deliberative Process
P-014464
charge and facts supporting state plea
6(e)
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
P-014465
12/18/2007-12/21/2007 emails between Marie Villafaña and other
Work Product
thru
AUSAs regarding other instances of charging 2422(b) based on the use
6(e)
P-014485
of a telephone as a "facility of interstate commerce"
P-014486
12/21/2007 email from Marie Villafaña to Jeff Sloman with thoughts on
Work Product
recent correspondence from Jay Lefkowitz raising concerns about
Deliberative Process
interpretation of the Nonprosecution Agreement
P-014487
12/27/2007 email from Marie Villafaña to Alex Acosta and Jeff Sloman
Work Product
regarding proposed approach to providing potential notice of breach of
Deliberative Process
non-prosecution agreement
P-014488
12/27/2007 emails between Jeff Sloman, Alex Acosta, Annette Castillo,
Work Product
thru
Karen Atkinson, Rolando Garcia, and Marie Villafaña regarding Jay
Deliberative Process
P-014499
Lefkowitz letter of 12/26/2007
P-014500
1/2/2008 email from Jeff Sloman to Alex Acosta and Marie Villafana
Work Product
regarding telephone conversation with State Attorney's Office about
Deliberative Process
delay in Epstein state plea.
P-014501
1/2/2008 emails between Alex Acosta, Marie Villafaña, and Jeff Sloman
Work Product
thru
regarding requests from Alex Acosta to Marie Villafaña for information
Deliberative Process
P-014506
related to the handling of the investigation by the State Attorney's Office
Page 10 of 18
EFTA00020720

=== Page 11 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 11 of
18
Bates Range
Description
Privilege(s) Asserted
P-014507
1/2/2008 emails from Marie Villafaña to Alex Acosta and Jeff Sloman
Work Product
thru
regarding renewed plea negotiations for federal plea agreement
Deliberative Process
P-014508
6(e)
P-014509
1/3/2008 emails between Marie Villafaña, Alex Acosta, and Jeff Sloman
Work Product
thru
regarding Alex Acosta telephone conference with Jay Lefkowitz where
Deliberative Process
P-014519
Lefkowitz admitted that he never intended to have Epstein plead guilty
to an offense that required sex offender registration.
P-014520
1/3/2008 email from Marie Villafaña to Nesbitt Kuyrkendall and Jason
Attorney client privilege
Richards regarding renewed plea negotiations and press coverage of
Deliberative Process
Epstein matter.
Investigative Privilege
P-014521
1/7/2008 email from Marie Villafaña to Alex Acosta, Jeff Sloman,
Work Product
thru
Robert Senior, Karen Atkinson, and Rolando Garcia regarding proposed
Deliberative Process
P-014522
additional investigative steps in Epstein case.
6(e)
Privacy Act
P-014523
1/9/2008 email from Jeff Sloman to Drew Oosterbaan, Alex Acosta, and
Work Product
Marie Villafaña regarding informing Jay Lefkowitz that a CEOS
Deliberative Process
attorney would join the SDFL team regarding the Epstein case and
would review the prosecution and defense materials.
P-014524
1/9/2008-1/14/2008 emails between Marie Villafaña, Drew Oosterbaan,
Work Product
thru
Myesha Braden, Nesbitt Kuyrkendall, and Jason Richards regarding
Deliberative Process
P-014550
assigning a CEOS attorney to the investigation, meeting with the CEOS
Attorney-client privilege
attorney and victims in Florida, the results of the meetings and planned
Investigative Privilege
additional meetings, and revisions to the indictment in light of the
6(e)
meetings.
P-014551
1/17/2008 email from Nesbitt Kuyrkendall to Marie Villafaña regarding
Attorney-client privilege
updated summary charts for indictment preparation, meetings with
Investigative Privilege
victims, and victim notification letters from FBI
Also contains information subject to
privacy rights of victims who are not
parties to this litigation 6(e)
P-014552
1/23/2008 email from Marie Villafaña to Jeff Sloman and Alex Acosta
Work Product
regarding FBI involvement in meeting in DC
Deliberative Process
Page 11 of 18
EFTA00020721

=== Page 12 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 12 of
18
Bates Range
Description
Privilege(s) Asserted
P-014553
1/25/2008 emails between Marie Villafaña and Myesha Braden
Work Product
thru
regarding press coverage of case and strategic decisions regarding
6(e)
P-014556
revisions to initial indictment
Deliberative Process
Investigative Privilege
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
P-014557
1/25/2008 email from Nesbitt Kuyrkendall to Marie Villafaña and
6(e)
Shawn Ball regarding research for purposes of issuing grand jury
Attorney-client privilege
subpoenas.
Investigative Privilege
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
P-014558
1/29/2008 email from Marie Villafaña to Drew Oosterbaan and Myesha
Work Product
Braden regarding status of meeting in DC and concerns regarding delay.
Deliberative Process
6(e)
Investigative Privilege
P-014559
1/28/2008-1/29/2008 emails between Marie Villafaña and Myesha
Work Product
thru
Braden regarding scheduling victim interviews on 1/31/2008-2/1/2008
6(e)
P-014562
Investigative Privilege
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
P-014563
1/30/2008 emails between Marie Villafaña, Alex Acosta, and Jeff
Work Product
thru
Sloman regarding Lefkowitz email about lawsuit filed against Epstein
Deliberative Process
P-014565
by one of the victims identified during the state investigation.
6(e)
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
Page 12 of 18
EFTA00020722

=== Page 13 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 13 of
18
Bates Range
Description
Privilege(s) Asserted
P-014566
1/31/2008 emails between Marie Villafaña and Nesbitt Kuyrkendall
Work Product
thru
regarding interviews with victims.
Investigative Privilege
P-014568
Attorney-client privilege
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
P-014569
1/31/2008-2/1/2008 emails between Marie Villafaña, Jeff Sloman, Alex
Work Product
thru
Acosta, Nesbitt Kuyrkendall, Jason Richards, and Alan Santiago
Deliberative Process
P-014573
regarding results of additional victim-witness interviews and requesting
6(e)
intervention with CEOS to move review process along
Attorney-Client Privilege
Also contains information subject to
privacy rights of victims who are not
parties to this litigation Investigative
Privilege
P-014574
2/20/2008-2/21/2008 emails between Drew Oosterbaan, Marie
Work Product
thru
Villafaña, Robert Senior, Jeff Sloman, Sigal Mandelker, Karen
Deliberative Process
P-014583
Atkinson, Alex Acosta, Rolando Garcia and Myesha Braden regarding
6(e)
status of CEOS plans to meet with counsel for Epstein and status of
indictment review
P-014584
2/12/2008-2/22/2008 emails between Marie Villafaña, Nesbitt
Work Product
thru
Kuyrkendall, Jason Richards, and Myesha Braden analyzing facts
Attorney-Client Privilege
P-014622
gathered from grand jury investigation and discussing strategy for
Investigative Privilege
drafting revised indictment
6(e)
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
P-014623
2/25/2008 emails between Marie Villafaña and Caroline Heck Miller
Work Product
thru
regarding ethical issue about whether or not to present proposed revised
Deliberative Process
P-014627
indictment to new grand jury
6(e)
P-014628
2/25/2008 email from Marie Villafana to Jeff Sloman, Robert Senior,
Work Product
Rolando Garcia, Karen Atkinson, and Myesha Braden regarding result
Deliberative Process
of consultation with Caroline Heck Miller about grand jury question
6(e)
Page 13 of 18
EFTA00020723

=== Page 14 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 14 of
18
Bates Range
Description
Privilege(s) Asserted
P-014629
2/26/2008 email from Marie Villafaña to Myesha Braden regarding
Work Product
CEOS review and draft indictment package
Deliberative Process
P-014630
2/26/2008 email from Marie Villafaña to Jeff Sloman regarding Jeff
Work Product
thru
Sloman's 2/25/2008 correspondence to Jay Lefkowitz further extending
Deliberative Process
P-014631
the plea deadline for Epstein
Investigative Privilege
6(e)
P-014632
2/21/2008-2/27/2008 emails between Marie Villafaña, David Weinstein,
Work Product
thru
Robert Senior, Karen Atkinson, and Rolando Garcia regarding notifying
Deliberative Process
P-014646
DOJ's Civil Rights Division regarding the status of the case and the
6(e)
planned indictment, and the draft written notification
Investigative Privilege
P-014647
2/28/2008 emails between Marie Villafaña and Susan Roe regarding
Work Product
thru
related investigation, potential investigatory leads, and CEOS review
Investigative Privilege
P-014649
6(e)
P-014650
2/27/2008-2/28/2008 emails between Marie Villafaña, Nesbitt
Work Product
thru
Kuyrkendall, and Jason Richards regarding review of evidence received
Investigative Privilege
P-014653
pursuant to subpoenas and planned interviews of additional potential
Attorney-client privilege
victim-witnesses
6(e)
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
P-014654
2/29/2008 emails between Jeff Sloman, Marie Villafaña, Robert Senior,
Work Product
thru
and David Weinstein regarding continuing investigation and status of
Deliberative Process
P-014655
CEOS review
Investigative Privilege
6(e)
P-014656
3/4/2008-3/5/2008 emails between Nesbitt Kuyrkendall and Marie
Work Product
thru
Villafaña regarding search warrant and victim contact with attorneys
Attorney-client privilege
P-014665
6(e)
Investigative Privilege
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
Page 14 of 18
EFTA00020724

=== Page 15 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 15 of
18
Bates Range
Description
Privilege(s) Asserted
P-014666
3/5/2008-3/6/2008 emails between Marie Villafaña, Alex Acosta, Jeff
Work Product
thru
Sloman, Drew Oosterbaan, Robert Senior, Myesha Braden, Rolando
Deliberative Process
P-014693
Garcia, and Karen Atkinson regarding meeting in DC, additional
6(e)
information to prepare for meeting, and new information from ongoing
Investigative Privilege
investigation
P-014694
3/10/2008-3/12/2008 emails between Marie Villafaña, Robert Senior,
Work Product
thru
Myesha Braden, Krishna Patel, Nesbitt Kuyrkendall, E.J. Yera, and
Deliberative Process
P-014706
Karen Atkinson about Epstein attempts to contact victims and finding
Attorney-client privilege
counsel for victims
P-014707
3/12/2008 emails between Marie Villafaña, Drew Oosterbaan, and
Work Product
thru
Myesha Braden regarding CEOS meeting with Epstein counsel
P-014711
P-014712
3/14/2008 emails between Marie Villafaña, Rolando Garcia, Karen
Work Product
thru
Atkinson, Frederica Devlin, and Shawn Ball regarding complete
Deliberative Process
P-014716
indictment package for Robert Senior final review
6(e)
P-014717
3/12/2008-3/17/2008 emails between Marie Villafaña, Nesbitt
Work Product
thru
Kuyrkendall and E.J. Yera regarding search warrant application and
Attorney client privilege
P-014721
execution of search warrant
Investigative Privilege
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
P-014722
3/14/2008-3/17/2008 emails between Marie Villafaña, Nesbitt
Work Product
thru
Kuyrkendall, Jason Richards, and Robert Senior regarding corrections
Deliberative Process
P-014727
to indictment package and proposed grand jury presentation
6(e)
Attorney-Client Privilege
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
Page 15 of 18
EFTA00020725

=== Page 16 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 16 of
18
Bates Range
Description
Privilege(s) Asserted
P-014728
3/14/2008-3/19/2008 emails between Marie Villafaña, Nesibtt
Work Product
thru
Kuyrkendall, Jason Richards, Robert Senior, Jeff Sloman, Karen
Deliberative Process
P-014742
Atkinson, and Rolando Garcia about Epstein attempts to contact victims
Attorney-client privilege
and finding counsel for victims
Also contains information subject to
privacy rights of victims who are not
parties to this litigation
P-014743
3/19/2008-3/21/2008 emails between Marie Villafaña, Drew Oosterbaan
Work Product
thru
(CEOS), Alexandra Gelber (CEOS), Jeff Sloman, and Robert Senior
6(e)
P-014780
about meeting between Esptein counsel and CEOS and follow-up
Deliberative Process
questions
Investigative Privilege
P-014781
3/19/2008-3/27/2008 emails between Jeff Sloman, Bob Senior, Karen
Work Product
thru
Atkinson, Rolando Garcia, Nesbitt Kurykendall, and Jason Richards
Deliberative Process
P-014800
regarding waiting for DC's decision regarding Epstein's challenges to
Investigative Privilege
NPA; status of ongoing investigation; problems with Epstein's counsel
6(e)
contacting victims in the guise of deposing them for the state criminal
action; and securing pro bono counsel for those victims to represent
them in connection with the depositions
P-014801
3/28/2008 emails between Marie Villafaña, Nesbitt Kuyrkendall, Jeff
Work Product
thru
Sloman, Robert Senior, and Karen Atkinson regarding status of DC
6(e)
P-014810
review of case and preparing for grand jury presentation
Investigative Privilege
Deliberative Process
P-014811
3/31/2008 emails between Marie Villafaña, Jeff Sloman, Robert Senior,
6(e)
thru
and Nesbitt Kuyrkendall regarding status of ongoing investigation,
Work Product
P-014829
planned presentation to grand jury, continued delay in awaiting decision
Deliberative Process
from Washington, DC, and problems with victims being harassed
Investigative Privilege
P-014830
4/2/2008 emails between Marie Villafaña, Alex Acosta, Jeff Sloman,
Deliberative Process
thru
Karen Atkinson, Robert Senior, Rolando Garcia, and Nesbitt
Work Product
P-014837
Kuyrkendall regarding efforts by Jay Lefkowitz and Ken Starr to speak
Attorney-Client Privilege
with Alex Acosta and instructions to direct question to Marie Villafana
and Karen Atkinson
Page 16 of 18
EFTA00020726

=== Page 17 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 17 of
18
Bates Range
Description
Privilege(s) Asserted
P-014838
4/4/2008-4/7/2008 emails between Marie Villafaña, Robert Senior,
Work Product
thru
Andrew Oosterbaan, and Jeff Sloman regarding status of CEOS review
6(e)
P-014843
of Epstein matter
Deliberative Process
P-014844
4/10/2008-4/18/2008 emails between Marie Villafaña, Robert Senior,
6(e)
thru
Karen Atkinson, Nesbitt Kuyrkendall, and Jeff Sloman about continued
Work Product
P-014851
delay in presenting case to grand jury due to failure to receive decision
Deliberative Process
from DC, status of grand jury presentation and ongoing investigation
Investigative Privilege
P-014852
4/11/2008-4/23/2008 emails between Marie Villafaña, Jeff Sloman, and
Work Product
thru
Dexter Lee regarding self-reporting to OPR false allegations of ethics
Deliberative Process
P-014864
violations
Privacy Act
P-014865
4/29/2008 email from Marie Villafaña to Robert Senior, Jeff Sloman,
Work Product
Karen Atkins, on Rolando Garcia re grand jury presentation
6(e)
Deliberative Process
Investigative Privilege
P-014866
4/21/2008-5/1/2008 emails between Marie Villafaña, Robert Senior, Jeff
6(e)
thru
Sloman, Karen Atkinson, Nesbitt Kuyrkendall, and Drew Oosterbaan
Work Product
P-014883
about continued delay in presenting case to grand jury due to failure to
Deliberative Process
receive decision from DC, status of grand jury presentation and ongoing
Investigative Privilege
investigation, staffing of case for purposes of trial, and meeting to
prepare for grand jury presentation
P-014884
5/2/2008 emails between Robert Senior, Marie Villafaña, Karen
6(e)
thru
Atkinson, Nesbitt Kuyrkendall, and Jason Richards regarding
Work Product
P-014886
developments in Epstein investigation and impact on grand jury
Attorney-Client Privilege
presentation
Investigative Privilege
Deliberative Process
P-014887
4/29/2008-5/2/2008 emails between Marie Villafaña and Jeff Sloman
6(e)
thru
regarding contact by Epstein counsel and victims and draft letter to
Work Product
P-014894
counsel for Epstein
Deliberative Process
Investigative Privilege
Page 17 of 18
EFTA00020727

=== Page 18 ===
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 18 of
18
Bates Range
Description
Privilege(s) Asserted
P-014895
5/7/2008-5/9/2008 emails between Marie Villafaña, Robert Senior, Jeff
Work Product
thru
Sloman, Nesbitt Kuyrkendall, and Jason Richards regarding awaiting
6(e)
P-014900
approval from DC and status of ongoing investigation
Deliberative Process
Attorney-Client Privilege
Investigative Privilege
P-014901
5/15/2008-5/16/2008 emails between Jeff Sloman, Marie Villafaña, and
Work Product
thru
Robert Senior regarding receiving final approval from DC
Deliberative Process
P-014906
P-014907
5/19/2008-5/22/2008 emails between Marie Villafaña, Karen Atkinson,
6(e)
thru
Robert Senior, and Jeff Sloman regarding preparation for grand jury
Work Product
P-014911
presentation; communication with S/A Kuyrkendall regarding plea
Deliberative Process
negotiations; and status of ongoing investigation
Investigative Privilege
P-014912
5/23/2008-5/27/2008 emails between Marie Villafaña, Robert Senior,
Work Product
thru
Jeff Sloman, Karen Atkinson, Nesbitt Kuyrkendall (FBI), and Jason
6(e)
P-014919
Richards (FBI) re status of investigation, indictment review, grand jury
Deliberative Process
preparation, and Epstein's attempt to revisit plea negotiations
Investigative Privilege
P-014920
8/15/2008 email from Marie Villafaña to Alex Acosta, Jeff Sloman,
Work Product
thru
Robert Senior, Karen Atkinson, and Dexter Lee containing draft
Deliberative Process
P-014923
response to 8/15/2008 email from Jay Lefkowitz regarding
implementation of the NPA. (Redacted version produced to opposing
counsel)
Page 18 of 18
EFTA00020728


c1: EFTA00021151
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021151.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
)"
Subject: RE: US V. Epstein - Status Hearing Notification
Date: Mon, 05 Aug 2019 15:33:07 +0000
Attachments: JBAGOYO_20190801164130564_DRAFT.pdf
Inline-Images: New_victims.JPG
Hi
just double checking to see if I can send this notification out. Also, FBI exported 4 more victims, attached are
their names. Is it ok to notify them?
Thank you,
Victim-Witness Assistant
U.S. Attorney's Office - SDNY
1 St. Andrews Plaza
New York, NY 10007
Office:
From:
(USANYS)
Sent: Thursday, August 01, 2019 5:44 PM
To:
is
is
Subject: RE: US V. Epstein - Status Hearing Notification
No worries! No need to apologize. VNS is tricky. A notification is formatted via a template, kind of like a template in Word.
There are certain sections where you can edit but then there are other areas where you can't because that's how it was
made by the programmer. Hope that makes sense
From:
Sent: Thursday, August 01, 2019 5:40 PM
To:
(USANYS)
is
)
is
Subject: RE: US V. Epstein - Status Hearing Notification
Got it, thanks. In the letters that went out, there are several edits we made that were applied to these letters, so I'm
wondering why it is we can change some parts of the letters and not others?
Apologies if I'm misunderstanding how the VNS system works. Thanks.
From:
(USANYS)
Sent: Thursday, August 1, 2019 5:25 PM
To:
is
is
Subject: RE: US V. Epstein - Status Hearing Notification
Hi
,
so, I was the one editing the letters.
EFTA00021151

=== Page 2 ===
Attached are the 2 previous notifications for this case that were sent to the Victims and they both don't those edits you
requested.
From:
Sent: Thursday, August 01, 2019 5:01 PM
To:
(USANYS)
is
)
is
Subject: RE: US V. Epstein - Status Hearing Notification
Hi
Thanks.
has been able to edit the previous letters, so it might be worth checking with her to see how she was able
to do that.
Thanks,
From:
(USANYS)
Sent: Thursday, August 1, 2019 4:45 PM
To:
)
is
V.
Subject: RE: US V. Epstein - Status Hearing Notification
Thanks
Attached is the updated version. I'm sorry but I could only update the hearing information. The other edits
can't be done due to the template in VNS which can't be changed. Frustrating I know, but I did my best to make it look
decent. Let me know if I can send it out. Thanks and sorry again!
From:
Sent: Thursday, August 01, 2019 4:24 PM
To:
(USANYS)
is
)
is
Subject: RE: US V. Epstein - Status Hearing Notification
Hi
Thanks. A few things:
In the case caption, please delete "defendant(s)," so that it does not read "defendant(s) Jeffrey Epstein". I'm not
sure if that's the form language, but it looks like a typo.
Regarding the hearing information, there are several other court dates. l'll forward you the scheduling order so
that you can add them.
Please swap out this language:
Because of the Court's schedule, hearing dates could change on very short notice. If you plan on attending,
you may want to call the VNS Call Center or check the website to confirm the date and time. Please note,
there is a 24-hour delay in information transfer to the website.
And replace it with this language:
If you plan on attending, please call me at 917-301-6861 in case there are any last minute changes.
EFTA00021152

=== Page 3 ===
Thanks!
From:
(USANYS)
Sent: Thursday, August 1, 2019 4:11 PM
To:
is
i
Subject: US V. Epstein - Status Hearing Notification
Hi there, attached is a status hearing notification which showed up on VNS today for this case. Did you want me to send it
out? Thank you.
Victim-Witness Assistant
U.S. Attorney's Office - SDNY
1 St. Andrews Plaza
New York, NY 10007
Office:
Contact
Contact Type Relationship
Victim Name(s)
Allred, Gloria
Victim
Victim
EFTA00021153


c1: EFTA00021627
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021627.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
REISEPASS
REPUBLIK ÖSTERREICH
PASSEPORT
REPUBLIQUE D'AUTRICHE
PASSPORT
REPUBLIC OF AUSTRIA

=== Page 2 ===
2
Reisepaß Nr.
Passeport N°
N 0376775
Passport Nr.
Familienname
Nom
FORTELNI
Surname
Vorname
Prénom
Marius Robert
Christian name
Datum und Ort der Geburt
Date et lieu de naissance
30.Juli 1954 Wien
Date and place of birth
Beruf
Profession
Manager
Profession
Wohnort
Domicile
Residence
Dammam / Saudi Arabien
Staatsbürgerschaft
Nationalité
ÖSTERREICH / AUTRICHE / AUSTRIA
Nationality
PERSONSBESCHREIBUNG
SIGNALEMENT
DESCRIPTION OF BEARER
Größe
Taille
1.84m
Height
Farbe der Augen
Couleur des yeux
Colour of eyes
braun
Besondere Kennzeichen
Signes particuliers
stempel
Distinguishing marks
keine
Unterschrift des Inhabers
Signature du titulaire
3
Signature of bearer

=== Page 3 ===
DIESER REISEPASS GILT FÜR ALLE STAATEN DER WELT
CE PASSEPORT EST VALABLE POUR TOUS LES PAYS DU MONDE
THIS PASSPORT IS VALID FOR ALL COUNTRIES OF THE WORLD
DIE GÜLTIGKEIT DIESES REISEPASSES ENDET AM
ERREICH Sepund
LA VALIDITE DE CE PASSEPORT EXPIRE LE
THE VALIDITY OF THIS PASSPORT EXPIRES
21. Mai 1987
Bundespolizeidinektion Wion
Behörde
Autorité
Authority
STATES SEA SCHILLING 100
If'on on 21. Mai 982
Ort und Datum
Lieu et date
Place and date
100 100
Oberkommissär
Die Gültigkeitsdauer dieses Reisepasses wird verlängert bis
La validité de ce passeport est prorogée jusqu'au
The validity of this passport is renewed until
Stempel-
Behörde
marke
Autorité
Authority
Ort und Datum
Lieu et date
Place and date
Unterschrift / Signature / Signature
Die Gültigkeitsdauer dieses Reisepasses wird verlängert bis
La validité de ce passeport est prorogée jusqu'au
The validity of this passport is renewed until
Stempel-
Behörde
marke
Autorité
Authority
Ort und Datum
Lieu et date
Place and date
5
Unterschrift / Signature / Signature

=== Page 4 ===
SICHTVERMERKE / VISAS / VISAS
CONTROL MALAGA
ENTRADA c EMB a 2. E
19 1 9 OCT. 1982
FRONTERAS
DIRECCION SEG. ESTADO
Crimizea 28 2 NATIONALE DE DEGAULLE MAI FRANCE 1982
\
POLICE NATIONALE
CHARLES-DE-GAULLE 2
05 FEV. 1983
POLICE ORLY NATIONALE
1 8 JUIN 1982
A 237 FRANCE
A 519 FRANCE
Phone NATIONALE
DR GAULLE 1
1983
POLICE MAD HOROLE
NICE COTE AZUR
ANCE
24 OCT. 1983
E 185 FRANCE
9
8

=== Page 5 ===
POLICE NATIONAL
NICE COTE AZOB
2 0 AOUT 1982
E 185 FRANCE
NATIONAL
CHANGE 02 CAULES
1 to as
A240 PRIVANCE
No 001974
P.O. Saudi Arabian Consulate- Vieens
Entry Visa
EIGHT
Y
3:20
1582 ANN 61
25.5.° MAI
CHARLES
¿ month NN
with we
Religion
are
Period of one Stay month -01°N
Non-Driployment Visa Green
F.V XII
201
order
NOT -7 - 7
ST
Consul
4
AVD
18 we
FREE
K.O. ABORADOUR
12.1 IS its T E
ROYAL
17.5
10
(100 THE
SAUDI ARABIAN BRIYAL 20 SAUDI CONSULATE ARABIA OF JU, VILITIA
11

=== Page 6 ===
&
30 MARS 1983
PROMETIED was
E
28HAY W22
04 NOV.
a 542 A 542 129 FRANCE
CHARLES POLICE 6 NATIONALE SEP. FRANCE 1982
2
LEAVE
EMBLOYERT FOR SIX MONTHST
LEAVE TC TC SIX MONTHS
EMPLOYMENT PROMIBITED
IMMIGRATION * OFFICER
M. RATION OFFICER
240CT
*
& 232) *
25 SEP 1982
HEATHROW (2)
HEATHROW (2)
0 0 9 NOV. 1982
CHARLES DE GAULLE 2
POLICE
13
12

=== Page 7 ===
15
14
6 a È & 2019
CHARLEST 1952 DE
OCCC
C
Seen
00
0
"ing
C
L
of
C
C
c
2000 cill in w iiii jo i cill a
000
0000
4035811

=== Page 8 ===
16
0318.
POLICE NATIOR
CHARLES DE GAULLS
26 OCT 1983
FRANCE
A 516
A 252 FRANCE
2 7 OCT. 1983
CHARLES DE GAULLE @
POLICE CLATIONALE
3 0 AVR. 1983
CHARLES DE GAULLE
POLICE NATIONALE
A CO
A 088 FRANCE
2 7 MAI 1982
CHARLES DE GABILE 2
POLICE NATIONALE
17


c1: EFTA00021993
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021993.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Re:
Date: Wed, 12 Dec 2018 12:34:29 +0000
Importance: Normal
Done; no comment yet. Also nothing on Epstein, but will raise when I talk to her, hopefully today, about a
couple other matters.
Sent from my iPhone
On Dec 11, 2018, at 9:40 PM,
Do you want to update ODAG that we will announce
non-pros?
Also, has Epstein come up?
EFTA00021993


c1: EFTA00021246
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021246.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Epstein Op Meeting with FBI
Start Date: 2019-07-01 19:30:00 +0000
End Date: 2019-07-01 20:30:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Comment:
Date Created: 2019-06-27 17:52:24 +0000
Date Modified: 2019-06-27 17:52:24 +0000
Priority: 5
DTSTAMP: 2019-06-27 17:39:42 +0000
EFTA00021246


c1: EFTA00023217
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023217.pdf
c6: pdf
c7: images
c0:
=== 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 25, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today the Government is producing additional materials, including Jencks Act and
Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced
case. Enclosed please find an index detailing the materials included in today's production.
The Government is also producing today certain materials relating to individuals the
Government does not currently intend to call as witnesses at trial in the above-referenced case.
These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the
Government does not expect to call these individuals to testify at trial. Instead, these materials
contain, among other things, certain witness statements. Enclosed please find an index detailing
these materials. Please note that the records stamped 3501.507 through 3501.516 were previously
produced to you on October 11, 2021 with a different stamp (3501.450 through 3501.459), which
was inadvertently used for two sets of witnesses. The Government is reproducing the materials to
avoid any confusion. This production should not be taken to indicate that the Government believes
it has any obligation to provide all of these materials; rather, we make this production as a courtesy.
Moreover, although the Government presently does not intend to call the individuals listed in the
EFTA00023217

=== Page 2 ===
Page 2
enclosed index, we reserve the right to do so and will notify you should the Government determine
that it intends to call any of these individuals at trial.
Please note that this letter, the enclosed indices, and the enclosed materials are
governed by the July 31, 2020 Protective Order in this case. In particular, certain materials are
designated as "confidential" under the Protective Order. The index 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.
Additionally, please note that many of the individuals referenced in this production are
represented by counsel, as detailed in the enclosed indices. The Government reserves its right to
amend and supplement these disclosures.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
Assistant United States Attorneys
EFTA00023218


c1: EFTA00021123
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021123.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Cc:
Subject: RE: travel approval request
Date: Thu, 13 Feb 2020 20:06:41 +0000
Inline-Images: image001.jpg; image002.png
Understood, thanks. Let's do the following flights, please, which both have one of the codes
mentioned:
Feb. 19: Delta, JFK to PNS, 8:35 a.m. (arriving 12:49 p.m.)
Feb. 20: Delta, PNS to JFK, 4:06 p.m. (arriving 9:45 p.m.)
thanks!
From:
Sent: Thursday, February 13, 2020 13:56
To:
is
Cc:
Subject: RE: travel approval request
Thanks
for clarifying the travel procedure to
please let me know if the fully refundable flight option I
sent to you in the previous email is okay and l'll continue with your booking. Note, the return flight on 2/20 you chose is
also not refundable, so I'm looking into other options for that flight as well. l'll send you those options shortly.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Thursday, February 13, 2020 1:51 PM
To:
is
Cc:
Subject: RE: travel approval request
We steer away from penalty flights in all instances. The change fees & cancellation risk is rarely ever worth it. Most
penalty fees are $300.
In the booking screen always scroll down and set the travel preferences for fare type preference to "unrestricted coach"
That way the penalty fares won't even show up in your search.
EFTA00021123

=== Page 2 ===
.
From
. To
* Depart
* Time
mm/dd/yy
Leaves at
Select time
.
Return
.
Time
mm/dd/yy
Leaves at
Select time
Advanced search
Class of Service Preference:
Coach
Lowest available including Penalty fares.
Unrestricted
1st Airline Preference:
From:
Sent: Thursday, February 13, 2020 1:48 PM
To:
i
Cc:
is
Subject: RE: travel approval request
Is it a requirement that our domestic flights be refundable? I knew that was true for international flights but I thought we
could book nonrefundable flights traveling domestically?
From:
Sent: Thursday, February 13, 2020 1:46 PM
To:
)
is
)
Cc:
>;
)
Subject: RE: travel approval request
Importance: High
the Delta departing flight you chose leaving LGA at 9:00am, arriving in Pensacola, FL at 12:49pm is not refundable, so
you'll need to choose another flight option. While checking out your flight options, I found a flight that will get you into
Pensacola, FL around the same time as your preferred option that's fully refundable. The difference is that the flight
leaves at 8:11am instead of 9:00am. I've placed the departing flight below for your review.
American Airlines
Contract carrier
Feb 19
ew York, NY (LGA), 8:11 AM
harlotte, NC (CLT), 10:35 AM
3 miles
EFTA00021124

=== Page 3 ===
A 1252
bach Lowest available including Penalty fares.
rbus A319
eview seat map
Layover (55m)
Charlotte, NC (CLT)
American Airlines
Contract carrier
Feb 19
harlotte, NC (CLT), 11:30 AM
ensacola, FL (PNS), 12:23 PM
0 miles
5298 (Operated by PSA AIRLINES AS AMERICAN
AGLE)
bach Lowest available including Penalty fares.
RJ900
eview seat map
Top of Form
All available fares for Option 28
$161.70
CA
Govt contract fare limited availability
Bottom of Form
Please let me know if you would like me to reserve this flight instead and I'll continue with your reservation. Thanks as
always.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
)
Sent: Thursday, February 13, 2020 1:26 PM
To:
i
Cc:
>;
)
Subject: RE: travel approval request
Apologies for the slight delay yesterday on this travel, we had a witness scheduling issue so the travel will be a day later
than originally anticipated. The city is Pensacola, Florida, and it will be me and
(rather than
and
).
if you could please book me on the following flights:
Feb. 19: Delta, LGA to PNS, 9:00 a.m. (arriving 12:49 p.m.)
Feb. 20: Delta, PNS to LGA, 4:06 p.m. (arriving 9:41 p.m.)
And the following hotel, for the night of Feb. 19:
-
Hilton Garden Inn (listed in E2 as "HGI PENSACOLA AIRPORT MEDICAL")
We will also need a conference room at the Hilton Garden Inn for February 19, starting at 5:00 p.m. for three hours (or for
the entire day, if that's the only way they'll do it).
Please let us know if any questions or issues, and thanks as always.
EFTA00021125

=== Page 4 ===
From:
Sent: Wednesday, February 12, 2020 09:02
To:
is
i
Cc:
Subject: Re: travel approval request
Hi,
Which specific city will the hotel be in?
If
could push the travel authorizations thru to
& I today, that would be great As well as sending the
conference room payment request to Nick Siu.
Remember to take the FL tax exempt form along with you.
Thanks
Sent from my iPhone
On Feb 12, 2020, at 6:43 AM,
wrote:
Approved
Sent from my iPad
On Feb 11, 2020, at 7:53 PM,
)
wrote:
Similar to prior requests in connection with the Epstein investigation (2018R01618),
and I would like to please
request permission for the two of us to travel next week for an interview of a witness in Pensacola, Florida on 2/19.
We'd plan to fly down on 2/18 and fly back on 2/19. Also, similar to prior requests, we'd like to request approval to get
a conference room on 2/19.
Thank you,
From:
Sent: Tuesday, January 21, 2020 2:56 PM
To:
Cc:
is
is
is
i
)
Subject: RE: travel approval request
Approved
From:
Sent: Tuesday, January 21, 2020 2:49 PM
To:
EFTA00021126

=== Page 5 ===
Cc:
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), but with an added international
element, we'd like to please request permission for the team to travel next week for an interview near Stockholm,
Sweden, next week on January 29th and/or 30th. We expect to be traveling, respectively, some combination of the
27th (overnight) to the 31st, depending on when the interview ends up being scheduled, and we'll put final dates on
our formal applications. Also similar to prior trips, we'd like to request approval to get a conference room for one of
those days at a hotel for the interview itself.
Also based on our discussion earlier we'll be mindful of looking for domestic (or domestic-flagged) carrier flights, as
well as the costs of any alternatives, in looking at possible specific bookings. Thanks as always for your help and input
on that.
thank you,
From:
Sent: Wednesday, December 11, 2019 09:58
To:
Cc:
is
)
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16
and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior
trips, we'd like to request approval to get a conference room for one of those days.
thank you,
From:
Sent: Tuesday, November 05, 2019 16:53
To:
Cc:
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be
traveling, respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip).
thanks,
EFTA00021127

=== Page 6 ===
From:
Sent: Tuesday, October 22, 2019 13:55
To:
>
Cc:
is
>;
is
(
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel on that Monday for the interview, please.
thanks very much,
From:
Sent: Wednesday, June 12, 2019 14:51
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no
later than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
,
as previously. And also same as last time, we'd like to ask permission to reserve a conference
room at the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling
allows).
EFTA00021128

=== Page 7 ===
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will
either be me and
or
and
,
but we wanted to ask for permission now either way so we weren't
doing it super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors
for sexual activity,
and I would like to please request permission to travel for approximately three days next
week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday
night and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West
Palm Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return
on Saturday.
Please let us know if any other information would be helpful, and thanks as always.
EFTA00021129

=== Page 8 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00021130


c1: EFTA00023100
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023100.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Bcc: "
Subject: FW: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Letter
Date: Tue, 08 Dec 2020 01:07:39 +0000
Embedded: FW:_Activity_in_Case_1:20-cr-00330-AJN_USA_v_Maxwell_Letter.msg
Sender:
Subject: FW: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Letter
Message-Id:
<DM3P110MB02652133A2EACD5D4B80442D89CD0@DM3P110MB0265.NAMP110.PROD.OUTLOOK.C
OM>
To:
Cc:
EFTA00023100


c1: EFTA00022486
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022486.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Subject: FW: US V. Maxwell, 20 Cr. 330 (AJN) - meet and confer
Date: Thu, 29 Apr 2021 00:35:54 +0000
Attachments: 2021-04-30_Govt_Letter_to_Manley.docx
MC - I can join you for a call on Manley's letter. I put together the start of a letter (attached) based on your notes in the
calendar invite and some other additions, but of course I imagine this may change based on our convo with counsel.
From: Laura Menninger
Sent: Wednesday, April 28, 2021 6:13 PM
To:
)
is
>;
Bobbi Sternheim
>; 'BOBBI C STERNHEIM'
>; ; Jeff Pagliuca
>; Mark S. Cohen
Cc:
>;
(USANYS)
>;
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - meet and confer
Thanks for reaching out. We probably are best served by sending you our position on defense disclosures by email. We
should be able to send that by Friday and can schedule a time to talk thereafter if you wish, with an eye towards the joint
filing on Monday.
We will confer with the team on the Speedy Trial issue and also get back to you on that.
Lastly, do you want to discuss anything regarding Mr. Manley's application to the Court? I believe we are to discuss and
then you are to write the Court by Friday. I am free tomorrow afternoon to discuss if you wish.
Thanks,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
From:
Sent: Tuesday, April 27, 2021 10:22 PM
To:
>; Bobbi Sternheim
>; 'BOBBI C
STERNHEIM'
>; ; Laura Menninger
>; Jeff Pagliuca
>; Mark S. Cohen
Cc:
is
(USANYS)
>;
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - meet and confer
Counsel,
Per Judge Nathan's Order (docket number 250), is there a time this week when you would be available for a call to meet
and confer regarding a proposed schedule for defense disclosure of witness statements pursuant to Rule 26.2? Or if you
EFTA00022486

=== Page 2 ===
would prefer to confer by email, would you please let us know your position?
Additionally, we intend to submit a letter to Judge Nathan requesting that time under the Speedy Trial Act be excluded
through the date the Court intends to set for trial of Counts One through Six of the S2 Indictment. Although Judge Nathan
previously excluded time through July 12, 2021, she has not reissued such an order since the return of the S2 Indictment,
and, of course, the date of trial may change. We therefore intend to seek a clarifying order excluding time, both in light of
the still-pending suppression motion, which automatically excludes time, and in the interests of justice to allow for trial
preparation. Would you please let us know whether you consent to the exclusion?
Thank you,
Assistant United States Attorney
Southern District of New York
EFTA00022487


c1: EFTA00021299
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021299.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Subject: RE: Epstein
Date: Thu, 07 Nov 2019 15:46:00 +0000
Great, thanks.
From:
Sent: Thursday, November 7, 2019 10:29 AM
To:
is
is
;
Subject: RE: Epstein
All three of us can come by at 11:30.
From:
(USANYS)
Sent: Thursday, November 7, 2019 9:42 AM
To:
>;
is
Subject: Epstein
Need 5-10 minutes this morning whenever some or all of you are free to follow up on our conversation last night. I'm tied
up from 10-10:30 and 12-12:30 but otherwise around.
EFTA00021299


c1: EFTA00021248
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021248.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Epstein Op Meeting with FBI
Start Date: 2019-07-01 19:30:00 +0000
End Date: 2019-07-01 20:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-06-27 18:07:11 +0000
Date Modified: 2019-06-27 18:07:11 +0000
Priority: 5
DTSTAMP: 2019-06-27 17:39:02 +0000
Attendee:
EFTA00021248


c1: EFTA00023024
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023024.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
Subject: RE: Epstein FOIA case, Times V. BOP, 20-cv-833
Date: Fri, 15 Jan 2021 14:56:10 +0000
Embedded: RE:_Epstein_FOIA_case,_Times_v_BOP_20-cv-833.msg
Sender:
Subject: RE: Epstein FOIA case, Times V. BOP, 20-cv-833
Message-Id:
<BN3P110MB04657C929F78F23245501471FEA70@BN3P110MB0465.NAMP110.PROD.OUTLOOK.COM>
To:
EFTA00023024


c1: EFTA00020696
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020696.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
)"
Subject: status memo
Date: Mon, 29 Apr 2019 17:32:00 +0000
Importance: Normal
Attachments: 2019-04-26_JE_status_memo_for
v2.docx
I think this is close to the final version
and I talked about it afterwards, and I think he made some edits while I was in
his office, and then after I left, so this isn't the final cut.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00020696


c1: EFTA00021771
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021771.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein Returns
Date: Thu, 23 Apr 2020 17:41:30 +0000
Thanks,
My last day at SDNY is this Friday, so you can coordinate with
(Cc'd), who is taking over my
role on the case. Thanks!
From:
Sent: Monday, April 20, 2020 7:53 AM
To:
Cc:
Subject: Re: Epstein Returns
I am not allowed to attached a hard drive to the computer system which holds the financial productions.
Let me discuss with the special agent and get back to you.
Best
From: Hamilton,
) [Contractor]
Sent: Sunday, April 19, 2020 8:05 PM
To:
Subject: Epstein Returns
Hi
,
Hope you're doing well! Would it be possible to get a hard drive of all of the returns you've received for the
Epstein case? I know you've given me them on discs, but we were hoping to get them all on one drive to make
sure we have a complete set in one place.
Not sure if you're in the office, but I will be this week. No worries if you need some time to get it to us. We can
also get you a hard drive if necessary.
Thanks,
Paralegal Specialist
EFTA00021771

=== Page 2 ===
United States Attorney's Office
Southern District of New York
Office:
Cell:
EFTA00021772


c1: EFTA00021310
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021310.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(NY) (FBI)"
To:
)"
Cc:
)"
)"
(NY) (FBI)"
Subject: New York search warrant materials
Date: Mon, 30 Sep 2019 19:13:05 +0000
Hey
,
I've copied
here who has handled all of the Epstein evidence that was sent to CART. He should be
able to answer your questions regarding what he's processed.
On Sep 30, 2019 1:57 PM,
"
)"
wrote:
The taint team here apparently received materials from the search of the New York house but it's way fewer documents
than we would have expected. Can you please let us know exactly how many electronic devices (phones, computers,
hard drives, thumb drives, and/or discs) were sent to CART for processing, and how many were in fact processed and
sent back to us? Or if it's easier to just put us in touch with the CART people directly, that's fine too. My understanding
was that they were processing the materials in the attached, which appears to list approximately 38 computers and/or
electronic storage devices seized along with an additional approximately 55 CDs.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00021310


c1: EFTA00020922
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020922.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: Amazon contact??
Date: Tue, 16 Jul 2019 16:20:35 +0000
Attachments: 2019-06-24,_subpoena_to_Amazon.pdf
Sure - attached. Thank you!
From:
(USANYS)
Sent: Tuesday, July 16, 2019 08:32
To:
Cc:
(USANYS) 1
Subject: Re: Amazon contact??
I have one. Can you send me the subpoena? Thanks.
Cybercrime Coordinator
Assistant United States Attorney
Southern District of New York
I
On Jul 15, 2019, at 7:19 PM,
wrote:
Ah well, thank you anyway!
From:
(USANYS) 1
Sent: Monday, July 15, 2019 19:18
To:
is
(USANYS)
Subject: RE: Amazon contact??
I unfortunately do not have any special contact at Amazon.
From:
)
Sent: Monday, July 15, 2019 7:18 PM
To:
(USANYS)
is
(USANYS) 1
Subject: Amazon contact??
Do either of you happen to have a contact at Amazon? We're trying to follow up on an overdue subpoena for Epstein
and I can't find any good / current contact info there. Thank you!!
Assistant U.S. Attorney
Southern District of New York
EFTA00020922


c1: EFTA00023494
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023494.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
,
(NY) (FBI)"
Subject: Fwd: RE Request for information
Date: Sat, 13 Feb 2021 20:07:14 +0000
Inline-Images: RE_Request_for_information.png
Begin forwarded message:
From: Jack Scarola
Date: February 13, 2021 at 2:56:08 PM EST
To:
)"
Cc: "Chris R. Rodgers"
Subject: RE Request for information
For whatever help, if any, it may be, this is a picture of
taken at about the time of her abuse by
Epstein. Her recollection is that two photos of her were taken while she was topless. Obviously, copies of those
photos would be of critical importance if they were ever recovered.
EFTA00023494

=== Page 2 ===
*
I
Privileged and Confidential I Electronic communication is not a secure mode of communication and may be
EFTA00023

=== Page 3 ===
accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola
Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-
2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud.
Admin. 2.420 and 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. Personal messages express views solely of the sender and shall not be
attributed to the law firm. If you received this communication in error, please notify the sender immediately by
e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank you.
EFTA00023496


c1: EFTA00021007
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021007.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: Epstein victim requests
Date: Mon, 16 Nov 2020 23:39:37 +0000
Attachments:
Original Message
From:
Sent: Tuesday, November 3, 2020 4:03 PM
To:
Cc:
Subject: RE: Epstein victim requests
Hi
Per our call, please find attached the requests from
including names in footnotes, as well as the Masseuse
list document that I was looking at. I'm probably missing something, but I don't see the names on the list (with
the exception of
but the last name on the list doesn't match the requester's or is not included).
Thanks,
Original Message
From:
Sent: Tuesday, November 3, 2020 2:26 PM
To:
Cc:
Subject: Epstein victim requests
Hi
Do you have time this afternoon for a brief call? I'm
if you have a moment.
Thanks!
Sent from my iPhone
EFTA00021007


c1: EFTA00021158
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021158.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: Arlan Ettinger
Date: Wed, 09 Oct 2019 18:06:26 +0000
Attachments: 4319870-Email_Message-RE_Ettinger.pdf; Arlan_Ettinger.pdf; 4319870-ES_Control_Sheet-
Ettinger.pdf
What is the right way to handle this? It seems to be an offer by Guernsey's Auctioneers & Brokers to be retained to handle
the disposition of Epstein's property. I was assigned to respond to this. Please advise.
Thanks
From:
Sent: Wednesday, October 9, 2019 1:57 PM
To:
Subject: Arlan Ettinger
Good afternoon!
I have been advised to forward you the attached correspondence from Arlan Ettinger, President of Guernsey's Auctioneers
& Brokers. The letter is regarding the property of the late Jeffrey Epstein. As advised by Nathaniel Gamble Il from ODAG
(see email attached), this has been assigned to USAO-SDNY for handling. Please let me know if you have any questions or
concerns.
Thank you very much in advance.
Best,
U.S. Department of Justice
Executive Office for U.S. Attorneys
O:
Pronouns: she/ her/ hers
EFTA00021158


c1: EFTA00021189
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021189.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
Person Encounter Detail
09/21/2021 11:30 EDT
Generated By:
Page 1 of 1
Encounter Person Detail
Last Name
First Name
Middle Initial
Gender
Date of Birth
MAXWELL
GHISLAINE
Document Number
Document Type
Document Country
Class of Admission
Admit Until Date
Encounter Person Detail
Encounter Line Type
Encounter Date
Encounter Time (Eastern)
Terminal Lane
Site/Encounter Location
AIRLINE (NOT API)
08/06/1997
15:07
PJ41
A520 - CBP-MIAMI,
AIRPORT N TERMINAL
Inbound/Outbound
Inspector
Processing Result
Primary Query Result
Referred To Agency
INBOUND
N
NOT REFERRED
Manifest Data
Manifest Indicator
Passenger Status
Updated Passenger Status
Flight/Vessel Number
Departure Location
N
Transmitted By
Carrier Code
Arrival Location
For Official Use Only / Law Enforcement Sensitive
EFTA00021189


c1: EFTA00023023
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023023.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Mark Epstein Meeting
Start Date: 2019-10-28 19:00:00 +0000
End Date: 2019-10-28 20:00:00 +0000
Location: 645
Class: X-PERSONAL
Comment:
Date Created: 2019-10-24 15:14:11 +0000
Date Modified: 2019-10-24 15:14:11 +0000
Priority: 5
DTSTAMP: 2019-10-24 14:57:07 +0000
Attendee:
EFTA00023023


c1: EFTA00021776
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021776.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Fri, 03 Jul 2020 01:39:43 +0000
Inline-Images: image001.png
Any time of year!
From
Sent: Thursday, July 2, 2020 5:11 PM
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Thanks! I hear NH is lovely this time of year.
From
Sent: Thursday, July 2, 2020 1:28 PM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congrats! I was in NH visiting my parents yesterday. If I had only known, I would have offered to handle the presentment!
From
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
Old ind SEQUITUR DEPARTMENT OF DEPARTMENT
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
UNITED
DONINIST
JUSTITIA
SOFFICE
STATES
OF
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
EFTA00021776

=== Page 2 ===
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment [1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey 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 their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
EFTA00021777

=== Page 3 ===
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such 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 were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
EFTA00021778

=== Page 4 ===
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00021779


c1: EFTA00020691
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020691.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein Travel
Date: Thu, 25 Apr 2019 22:48:32 +0000
Importance: Normal
No worries, thanks!
Original Message
From:
Sent: Thursday, April 25, 2019 18:48
To:
Cc:
Subject: RE: Epstein Travel
It is a web based program and when exported it exports to PDF. Sorry, no word version.
Original Message
From:
Sent: Thursday, April 25, 2019 6:41 PM
To:
Cc:
Subject: RE: Epstein Travel
By any chance is there a Word version of this? Totally understand if not but wanted to check -- thanks.
Original Message
From:
Sent: Thursday, April 25, 2019 18:37
To:
Cc:
Subject: Epstein Travel
Attached is a summary of Epstein's travel from 1.1.2015 to 4.21.19.
Special Agent
FBI New York
VCAC/Human Trafficking
C:
O:
EFTA00020691


c1: EFTA00020925
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020925.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: this is quite the story
Date: Tue, 26 Jan 2021 23:51:26 +0000
https://www.miaminewtimes.com/news/julie-brown-and-mike-fisten-fight-over-epstein-book-deal-11804324
Assistant U.S. Attorney
Southern District of New York
EFTA00020925


c1: EFTA00021317
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021317.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Re: Human trafficking victims
Date: Thu, 03 Oct 2019 17:56:05 +0000
Got it, thanks.
On Oct 3, 2019, at 1:45 PM,
wrote:
I was thinking about that; you should be getting the same email from the PC chiefs, so I'd include Epstein there.
From:
Sent: Thursday, October 3, 2019 1:34 PM
To:
Subject: Re: Human trafficking victims
Do you want the numbers from Epstein?
On Oct 3, 2019, at 1:32 PM,
wrote:
Please let us know by tomorrow approximately how many victims or potential victims of human trafficking you have
interviewed over this past year. Thanks very much.
Assistant United States Attorney
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
Tel:
Cell
EFTA00021317


c1: EFTA00021000
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021000.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Final Voucher 10810414-1(1) approved by
,
now awaiting further
approval
Date: Fri, 06 Dec 2019 17:40:37 +0000
Importance: Normal
Dear
Final voucher 10810414-1(1) has been approved by
, now awaiting further approval.
Trip ID: 10810414-1
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13179 - U.S. V. Epstein - Witness Interview
Destination: Santa Monica, CA, United States
Dates: 2019-11-13 - 2019-11-15
Current status: Pending Voucher Approval
Voucher total expenses: 1585.76
Estimated trip cost: 1947.20
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0010
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00021000


c1: EFTA00021545
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021545.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: "Martin G. Weinberg"
Cc:
"Miller, Michael"
>, Reid Weingarten
Subject: RE: US V Epstein
Date: Fri, 02 Aug 2019 14:11:37 +0000
Received, thank you Marty. Going forward, we would be grateful if you would please include all three of us on any emails
related to this case.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Martin G. Weinberg
>
Sent: Friday, August 2, 2019 10:08 AM
To:
is
Cc:
>; 'Martin G. Weinberg'
; 'Miller,
Michael'
>; Reid Weingarten
Subject: US V Epstein
,
I sent the attached to
last night who informed me he is out of the office so to be sure you have
received it as well, I am re-sending to all. Thanks, Marty
Martin G. Weinberg, Esq.
This Electronic Message contains information from the Law Office
of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee
only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents
of this message is prohibited.
EFTA00021545


c1: EFTA00021937
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021937.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Christian Everdell
Cc: "Mark S. Cohen"
Jeff Pagliuca
, 'Laura
Menninger'
)"
Subject: RE: United States V. Maxwell, 20 Cr. 330 (AJN)
Date: Mon, 27 Jul 2020 20:43:15 +0000
Pursuant to the Court's Order of this afternoon, we write to schedule a telephonic meet and confer on issues relating to a
protective order in the above-captioned case. Please let us know what time you are available today between 5:00 p.m.
and 8:00 p.m., or tomorrow between 9:00 a.m. and 1:00 p.m. In particular, it would be helpful to get the defendant's
current position on the following:
-
Whether you are aware of any case in any federal district in which a protective order was entered in a criminal
case that prevented the Government from showing its own documents to prospective witnesses or their counsel
without requiring restrictions upon those witnesses and their counsel;
-
Whether you are able to describe any expected reason why it would be necessary or useful for the defendant to
reference by name - rather than by pseudonym or other anonymized identifier - any victim in a public statement
or publicly-docketed filing (and rather than by sealed filing, if such named identification is necessary), such that
the Government may consider whether it can formulate language to address any such concerns, without
conceding any right of the defendant to name any individual who has self-identified as a victim of Jeffrey Epstein
or Ghislaine Maxwell at any time; and
-
Whether the defense is willing to itself propose any language to address the Government's concerns in relation
to the issue described immediately above, regarding the defendant's desire to be able to reference by name any
victim in a public statement or publicly-docketed filing, without conceding that any such right exists.
Additionally, also relating to the production of discovery, please mail, or otherwise have delivered, a 1 terabyte hard drive
for purposes of the Government's discovery production. While we are in the process of determining the size of an initial
production, and the size may total substantially less than 1 terabyte, that will ensure our ability to make a robust initial
production and should be suitable for subsequent productions as well. That can be sent to my attention at our Office.
Regards,
Assistant U.S. Attorney
Southern District of New York
EFTA00021937


c1: EFTA00023107
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023107.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Nathan NYSD Chambers
To:
)"
)"
(USANYS)"
Bcc:
Subject: 20-cr-330, United States V. Ghislaine Maxwell
Date: Mon, 28 Dec 2020 20:08:24 +0000
Embedded: 20-cr-330,_United_States_v_Ghislaine_Maxwell.msg
Sender:
Subject: 20-cr-330, United States V. Ghislaine Maxwell
Message-Id:
<MN2PR09MB5769B411BB9CE7DAF4C2707893D90@MN2PR09MB5769.namprd09.prod.outlook.com>
Recipient:
Recipient:
Recipient:
Recipient:
Recipient:
EFTA00023107


c1: EFTA00022481
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022481.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS) [Contractor]"
Subject: FW: DAG Memos
Date: Thu, 23 May 2019 15:11:41 +0000
Importance: Normal
Attachments: SDNY_Memo_to_DAG.GSB.cases.5.23.19.final.pdf_SDNY_Memo_to_DAG_-
_GSB_Recused.5.23.19.Finaldocx.pdf
and
thanks for all you and the team did to get this done well and timely.
As you know only the non-recused memo should be passed along to Geoff.
Thanks for all your help.
From:
(USANYS)
Sent: Thursday, May 23, 2019 11:09 AM
To:
(ODAG) (JMD)
Subject: DAG Memos
Here are the two memos for your briefing with Ed of the DAG, one from Geoff and the other from me on the recusal
matters.
After you and I spoke, we realized that we should add Epstein and we have done so.
As always, please feel free to call with any comments or questions.
EFTA00022481


c1: EFTA00022326
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022326.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Subject: Automatic reply: [EXTERNAL] Trial of Ghislaine Maxwell
Date: Wed, 03 Nov 2021 15:47:09 +0000
I am out of the office
For matters relating to the Violent & Organized Crime Unit, please contact [
at
For any matter regarding a specific
case, please contact the other AUSA(s) on the case.
EFTA00022326


c1: EFTA00020473
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020473.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
OFFICIAL RECORD
Intake (Rev. 5-23-17)
Document
signed
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Intake
Date: 08/05/2020
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Drafted By:
Date/Time Received: 08/05/2020 05:48 PM EDT
Details:
On 08/05/2020. at 5:48 p.m. Eastern Time.
email address
telephone number (Cell)
internet protocol (IP) address
which resolves to
Stockholm. SE 132 48. Submitted an online tip to the FBI National Threat Operations Center (NTOC) via
tips.fbi.gov, to report information on Jeffrey Epstein and Ghislaine Maxwell.
Date Submitted: 08/05/2020 05:48:59 PM ET
Transaction Number: A300A5B9-5269-434C-A895-06FC8EB84B76
Threat To Life: False
Submitted Text:
I was living in NYC in 2002-2004 and was introduced to Jeffrey Epstein by a Canadian woman who at the time
was a friend. The woman was in her mid to late twenties at the time. She was also friendly with Ghislaine
Maxwell. The woman.
was an aspiring French Canadian model and a close friend of Jeffrey Epstein.
She told me she was often in his company in his home. She told me "he helped young beautiful women". She also
mentioned he often liked to get massages. I often went with my friend
to nightclubs in NYC and she
would procure young women to meet Jeffrey Epstein. Many women were underage and aspiring models from other
countries. She often had a lot of money in cash that she said Jeffrey Epstein gave to her for helping him with
"various things". I just saw the Netflix documentary and now understand that
was procuring underage
women for sex trafficking to Jeffrey Epstein and Maxwell. She did it as an accomplice of Epstein with full intent of
introducing them to him for payment. She did not seem to be under any duress but only spoke highly of Epstein.
Several times I saw her with Maxwell too.
Violation: Other
Violation Questions
What was the exact crime that occurred?: Sex trafficking/procuring of minors Jeffrey Epstein and G Maxwell
When did the crime/incident occur? (Please provide an approximate date and time): 2002-2004
Where did the crime/incident occur? (Please provide the specific location/address if possible): NYC/Manhattan
Complainant Information
UNCLASSIFIED
EFTA00020473

=== Page 2 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/05/2020
First Name:
Middle Name:
Last Name:
Age:
DOB:
Additional Info:
Type: Cell
Phone:
Extension:
Account:
Type: Other
Address:
City:
State: New York
Zip: 11968
Country: United States
Subject Information
First Name:
Middle Name:
Last Name
Age:
DOB:
Additional Info: The woman is a jewelry designer in a Manhattan.
How is Contact Known: She used to be a friend.
Type: Other
Address:
City:
Zip:
Witness Information
First Name: I am the witness
Middle Name:
Last Name: Me
Age: 40
DOB:
Additional Info: No
How is Contact Known: I am the witness
Type: Other
Address:
UNCLASSIFIED
2
EFTA00020474

=== Page 3 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/05/2020
City:
Zip:
Remote IP:
Remote Host: api.fbi.gov
Http Referrer: https://www.fbi.gov/tips
User Browser:
Latitude:
Longitude:
Country: SE
Region: Stockholm County
City: Saltsjoe-Boo
Postal Code: 132 48
Timezone: 02:00
UNCLASSIFIED
3
EFTA00020475


c1: EFTA00020801
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020801.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
,
)"
Subject: New Victims Emerge As Epstein Awaits Bail Hearing - Gothamist
Date: Fri, 12 Jul 2019 22:42:07 +0000
Importance: Normal
https://gothamist.com/2019/07/12/new_victims_jeffiey_epstein.php
Sent from my iPhone
EFTA00020801


c1: EFTA00020959
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020959.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
12/28/2011 WED 14:25 FAX 3407743017 Kellarhalls Ferguson LLP
001/001
Doc# 2011009441
# Pages 5
12/30/2011 11:23AM
Official Records of
ST THOMAS/ST JOHN
P. COURTNEY REESE, ESQ.
QUITCLAIM DEED
RECORDER OF DEEDS
Fees $6467.00
THIS INDENTURE, made the 23RD day of December, 2011, between L.S.J., LLC, a Delaware
limited 1 ability company with an address of
St. Thomas, VI
00802 ("Grantor"), and Nautilus, Inc., a U.S. Virgin Islands corporation with an address of
St. Thomas, VI 00802 ("Grantee").
WITNESSETH:
THAT Grantor. in consideration of TEN DOLLARS ($10.00) and other good and valuable
consider paid by Grantee, does hereby release and quirclaim unto Grantee, and Grantee's
successo and assigns forever, all the right, title, interest, claim and demand which the said Grantor
has in and to:
ALL that certain plot, piece or parcels of land, with the buildings and improvements thereon
described as:
Parcel Nos. A, B & C
Little St. James Island
U.S. Virgin Islands
As shown on O.L.G. Map No. D9-8021-T007
And consisting of approximately 36.7 acres, 23 acres and 11.8 acres, respectively, more or less;
Being the same premises conveyed to Grantor by Warranty Deed dated April 27, 1998 and recorded
May 15, 1998 in Book 49-T, Page 494 Doc. No. 1988 and entered in Aux 52. Page 141 in the Office
of the Rc corder of Deeds for St. Thomas and St. John, U.S. Virgin Islands.
TOGETHER with the appurtenances thereunto belonging and all the estate, title and rights of
Grantor n and to said premises,
SUBJECT. HOWEVER, to zoning regulations and to covenants, restrictions and easements of
record,
TO HAVE AND TO HOLD, the premises herein granted unto the Grantee, the successors and
assigns of Grantee forever, in fee simple absolute.
The und ersigned further warrants and states that he is the sole member of I.S.J., LLC and that he
has exec ated this deed on behalf of L.S.J., LLC and that by this deed L.S.J., LLC does convey to
Naurilus, Inc. the property described herein.
Doc# 2011009441
EFTA00020959

=== Page 2 ===
IN WI "NESS WHEREOF, Grantor has duly executed this Deed the day and year first above
written.
WITNESSES
GRANTOR:
Brett Yeary
L.S.J., LLC
BY: JEFFREY E. EPSTEIN,
H TERRITORY OF THE U.S. VIRGIN
Sole Member
ISLANDS
)
DIVISION OF ST. THOMAS/ ST. JOHN
) SS:
On the 23RD day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared Jeffrey E. Epstein, personally known to me or proved to me on the basis of
satisfactory evidence to be the individual who subscribed to the within instrument, and
acknowledged to me that he executed the same in his capacity as the sole member of L.S.J., LLC, a
Delawa e limited liability company (the "Company"), the Grantor therein, and that by his signature
on the within instrument, the Company executed the within instrument.
Notary The Public
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Territory of the U.S. Virgin Islands
TERRITORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF ST. THOMAS/ ST. JOHN
) ss:
On the 23RD day of December in the year 2011, before me, the undersigned, a Notary Public,
persons Ily appeared JEFFREY E. EPSTEIN , personally known to me or proved to me on the
basis of satisfactory evidence to be a subscribing witness to the within instrument, who being by me
duly sworn, did depose and say that
resides in the United States Virgin Islands; that
knows
BRET
Jeffrey E. Epstein to be the individual who executed the within instrument; that said subscribing
GEARY
witness was present and saw Jeffrey E. Epstein execute the same; and that said subscribing witness
at the time time subscribed THEIR name as a witness thereto.
Notary R Public
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Territory of the U.S. Virgin Islands
Doc# 2011009441
EFTA00020960

=== Page 3 ===
Doc# 2011009441
# Pages 5
12/30/2011 11:23AM
Official Records of
ST THOMAS/ST JOHN
TERRITORY OF THE U.S. VIRGIN ISLANDS
P. COURTNEY REESE, ESQ.
)
RECORDER OF DEEDS
DIVISION OF ST. THOMAS/ ST. JOHN
) ssees $6467.00
On the 23RD day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared BRET GEARY
, personally known to me or proved to me on the
basis of satisfactory evidence to be a subscribing witness to the within instrument, who being by me
duly SW orn, did depose and say that she resides in the United States Virgin Islands; that she knows
Jeffrey E. Epstein to be the individual who executed the within instrument; that said subscribing
witness was present and saw Jeffrey E. Epstein execute the same; and that said subscribing witness
at the S: me time subscribed her name as a witness thereto.
Notary R
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Territory of the U.S. Virgin Islands
ATTEST:
n Is hereby certified that the above
mentioned property/s which, according
to QUIT CLAIM DEED dated December 23,2011
belongs to: NAUTILUS, INC.
GRANTEE
has nct. according to the Records of
this office, undergone any changes as to
and area.
Cadostral Survey/Tax Assessor Offices
St. Thomas, V.I. Dated :December 29 2011
WAYNE RIBLIC SURVEYOR
Office of the Lieutenant Governor
NOTED IN THE CADASTRAL RECORDS
FOR COUNTRY/TOWN PROPERTY, BOOK FOR
LITTLE ST JAMES ISLAND AKA MINGO KEY
ST THOMAS, U.S. VIRGIN ISLANDS
0811889441 Doc#
WAYNE St. Cadastral Thomas, D.C Survey/Tax ALLWOOD, V.J. Dated: PUBLIC Assessor ecembe SURVEYOR Offices
Office of the L.e. anant Governor
EFTA00020961

=== Page 4 ===
12/30/2011 11:23AM
Official Records of
ST THOMAS/ST JOHN
P. COURTNEY REESE, ESQ.
RECORDER OF DEEDS
AFFIDAVIT
TERRI 'ORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF ST. THOMAS/ ST. JOHN
) ss:
On this 21st day of December, 2011, personally appeared Jeffrey E. Epstein, who as the President
and the sole beneficial owner of Nautilus, Inc., a U.S. Virgin Islands corporation, and the sole
member of L.S.J., LLC, hereby on oath asserts that, pursuant to 33 V.I.C. (128(a)(6), Section 8,
Nautilus, Inc. and I.S.J., LLC are entitled to an exemption from the payment of stamp taxes, in that,
the conveyance by L.S.J., LLC to Nautilus, Inc., pursuant to that certain Warranty Deed of even
date, of all of L.S.J., LLC's rights, title, and interest in Little St. James Island, 6B Red Hook Quarter,
St. Thomas, United States Virgin Islands is a conveyance, for no consideration, between subsidiary
entities, all beneficially owned by Jeffrey E. Epstein.
WITNESSES:
Juonne Deennor
Jeffrey 2 E. Epstein
President and sole beneficial owner, Nautilus, Inc.
Sole member, L.S.J., LLC
In R. Pascal
Subscribed and Sworn before me this 21st day of DSCEMBER 2011.
Daphne Louise Wallace
NOTARY PUBLIC
Name: Daphne Louise Wallace
My Commission Exp: January 6, 2014
NP Commi ision # NP-007-10
St. Thomas St John, USVI District
Valve for Recording PURPOSIS
0811089441 Doc#
$6,442,100.00
EFTA00020962

=== Page 5 ===
OF THE OF THE
UNITED STATES VIRGIN ISL SONS
GOVERNMENT OF
THE UNITED STATES VIRGIN ISLANDS
OFFICE OF THE LIEUTENANT GOVERNOR
DIVISION OF REAL PROPERTY TAX
Christiansted, Virgin Islands 00820
Charlotte Amalle, Virgin Islands 00802
REAL PROPERTY TAX CLEARANCE LETTER
TO:
Office of the Recorder of Deeds
FROM:
Office of the Tax Collector
In accordance with Title 28, Section 121, as amended, this shall certify that
there are no outstanding Real Property Tax obligations for the following:
PARCEL NUMBER
1-09803-0101-00
LITTLE ST JAMES ISLAND
LEGAL DESCRIPTION
RED HOOK
L.SJ., LLC
OWNER'S NAME
Taxes have been researched up to and including
2008
CERTIFIED TRUE AND CORRECT BY
Valencio Jackson
Tax Collector
December 27, 2011
DATE
EFTA00020963


c1: EFTA00023348
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023348.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject:
3500
Date: Fri, 12 Nov 2021 03:24:56 +0000
Attachments: 2021.11.11
notes.pdf
Embedded: [EXTERNAL]_Screenshots_from
msg
Hi
and
Would one of you please save the attached as TW 3500 for
?
Thanks!
EFTA00023348


c1: EFTA00022508
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022508.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
)"
Subject: Quick Epstein FOIA question
Date: Sun, 02 May 2021 15:47:11 +0000
Attachments: Pages from 19-0556 New York Times -
Epstein_Records_Unmasking_Remaining_WIF_2-A_(050121_845_pm).pdf
Hi Jason and Maurene,
The attached got marked as a Tartaglione withheld in full, but I don't think that's right. This can be released with no
Tartaglione concerns, right?
Thanks,
Assistant United States Attorney
300 Quarropas Street
White Plains, NY 10601
Telephone:
EFTA00022508


c1: EFTA00020988
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020988.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
)"
Subject: t/c with Sigrid McCawley, counsel to
Date: Tue, 26 Nov 2019 01:13:55 +0000
Sigrid, t/c November 25, 2019. approximately 16:55 to 17:00
-
got a call from
contacted by Patrick Stupfel (ph), contacted through social networking site
-
received messages from him saying that he had information on Epstein case
-
wanted to pass along the information
-
I advised that she could send them to the case team and we would pass along the communications to the FBI
-
subsequent to the phone conversation, I received an email with the communications and sent them to FBI
Assistant U.S. Attorney
Southern District of New York
EFTA00020988


c1: EFTA00022169
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022169.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
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
)
V.
)
Jeffrey Epstein
)
Case No. 19-CRIM-00490
)
Defendant
)
SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR
OBJECTS IN A CRIMINAL CASE
To: Metropolitan Correctional Center, Legal Department
(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:
Any and all medical or mental health records relating to Jeffrey Epstein, Reg. No. 76318-054.
Place: Please mail, email, or fax the requested records to
Date and Time: 08/26/2019 5:30 pm
defense counsel of record.
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)
STATE
RUBY J. KRAJICK
Date:
08/23/2019
COURT
CLERK COURT
Jath Signature Deputy Clerk
The name, address, man, and telephone number of the attorney representing (name of party)
Jeffrey Epstein,
Defendant
, who requests this subpoena, are:
Michael C. Miller. Steptoe & Johnson LLP, 1114 Avenue of the Americas, New York, NY 10036
direct + 506 3950 fax
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.
EFTA00022169


c1: EFTA00023467
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023467.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: ESI exhibits
Date: Tue, 28 Sep 2021 16:05:24 +0000
Importance: Normal
Attachments: Select_ESI_GX.zip
Not sure if we'll have time to get to this during out meeting later, but the team wanted to talk to you about some of the
ESI exhibits we've marked as potential trial exhibits. They're attached. These items were found on a forensic image of a
computer registered to "gmax," and the evidence would show that this is a clone of a computer in the Palm Beach house
in 2005, which was taken by private investigators working for Epstein. The FBI found the cloned drives in Epstein's NYC
townhouse in 2019.
We are considering whether any of these exhibits should be offered at trial under Rule 404(b). If we don't get to this
during our meeting today, we can find another time to talk.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00023467


c1: EFTA00020572
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020572.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
Subject: co conspirator question transcript
Date: Fri, 07 Feb 2020 17:21:59 +0000
Q: When Jeffrey Epstein died, a lot of people asked what's next? Is the government going to hold people who are accused
of helping him recruit these younger girls, participated in this, can you give us a little bit of an update of where your office
is in this investigation?
A: Well, I'll note that the original charges against Jeffrey Epstein contained a conspiracy charge and we alleged that there
were conspirators involved. And Jeffrey Epstein couldn't have done what he did without the assistance of others and I can
assure you that our investigation is moving forward.
EFTA00020572


c1: EFTA00021332
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021332.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Jack Scarola
Cc:
)"
)"
Subject: RE: Epstein
Date: Mon, 07 Oct 2019 15:54:18 +0000
Hi Jack,
I'm following up on our conversation a few weeks ago about Ms.
We remain interested in meeting with her, if
you are able to arrange a meeting.
Thanks,
From: Jack Scarola
Sent: Friday, September 13, 2019 7:53 PM
To:
Cc:
is
Subject: Re: Epstein
I do.
On Sep 13, 2019, at 4:09 PM,
)
wrote:
Mr. Scarola,
Following up on this, we wanted to check to see whether you represent Ms.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
From: Jack Scarola
Sent: Wednesday, August 7, 2019 6:40 PM
To:
Cc:
is
Subject: Re: Epstein
EFTA00021332

=== Page 2 ===
I have forwarded your message to
On Aug 7, 2019, at 4:48 PM,
)
wrote:
Mr. Scarola,
We have had difficulty contacting Ms.
in connection with our investigation. Are you in touch with her and able
to set up a meeting with us? We would be interested in speaking with her and can travel to Florida to do so.
thank you,
From: Jack Scarola
Sent: Wednesday, August 07, 2019 08:54
To:
Cc: ROBERT C. JOSEFSBERG RJOSEFSBERG@podhurst.com> Brad Edwards <brad@pathtojustice.com>
Subject: Re: Epstein
For whatever value it may have in connection with your pending prosecution of Jeffrey Epstein, one of his
victims,
, who was repeatedly molested in Florida beginning at age 14, received multiple gifts
of lingerie from Epstein shipped to her in Florida from NY.
may be reached at
, and is
willing to speak to investigators.
Privileged and Confidential | Electronic communication is not a secure mode of communication and may be
accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola
Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-
2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin.
2.420 and 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. Personal messages express views solely of the sender and shall not be
attributed to the law firm. If you received this communication in error, please notify the sender immediately by
e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank you.
EFTA00021333


c1: EFTA00022646
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022646.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
i
10/8/21
met am at his house in PB
offered receptionist job by GM
She asked me bring couple friends
w/ me
nome facing intercoastal
under impression Jt $ 6m lived there
am approached me on campus
PBAU - approach out of blue
$ ask it / interest in secretary work
/ said no
/ asked where to go
what about for $200 he
GM wrote down
/ said sure
directions th #
2001 - around 9/11 anthrax fonna in WPB
remember watch together in kitchen onty
1 was by myself
when GM approach
am said answering phones $15 paperwork
no (didnt say who work FOR)
Im from midwest
driveway : - taller hedges
never been
walked in
around people
blk/white photo of topless woman
Rm to left
Shred books Gm ask
EFTA00022646

=== Page 2 ===
2
rt open area
doors to pool
Rm that GM office
doors w/ glass in them
kitchen
bedems upstairs
/ was doing x 6-9 months
drugs at time
hard to say
went when they called
how long
1st was there quite a bit
couple times wk
then go wks w/out being there
GM had told me
1st went brought my PBACH
to bring friends
Gm liked neither of them
interest in work
- tall blonde
- heavier set - didnt like
didnt explain
her b/c that
what friends be doing
JE $ GM $ another girl lived there
lived in one of upstairs
bedrooms
L
thinner light brown dirty hair blonde
EFTA00022647

=== Page 3 ===
3
girl showed me around the house
met house girl at
got upstairs naked on massage
tables
Gm introduced
us
She one showed me things there
She worked for them
1 was 20
think she about my age -assumed
may be ye younger YR older
|
Gm asked me to call baket school in
younger people
WPB
more limber
asked girls to come over th Gm
had done ballet when younger th
wanted get her (GM) ballet skills back
wanted massage person be there too
there guy there when / went
gave me the girl massages
taught us to give massages
Gm wanted make sure massage table
Set up
think I may assume she want guy
there b/c he gave massages
not sure
EFTA00022648

=== Page 4 ===
4
I called school
dont remember if scheduled
didnt see them
GM ask me to give JE massages
hard back/hard binding
ask me to answer phones
only 2-3 of the 8 lines
like half page
had me shred phone books she
made
prob inch thick
not quite half page but
black almost like
they re bound
sketch book
when they update them they
(10th
had me shred
had take pgs out
Gm give me lot cash to get moyie tix
$ shred
City Place theater
Gm told how answer - think just
Remember transfer how to call
home down hallway
1st floor
look like office but
didnt look used
pretty empty not
went home to 1 llinois $ tried to look
much decor
them up b/c IT such weird experience
only gave massage to JE
om said just therapist remember what | earn from
EFTA00022649

=== Page 5 ===
5
1st one / gave was out by pool
chart of gray
come help me pick out a color
gray for my jet
gave mass feet legs start
I didnt wear much back then
Short shorts
hardly stomach wore anything cover my
touchy feely
It was handsy
wasnt afraid
only be me $ him
to say what
you could see from Le area but
he like or not like
doors shut
all over touch
at time never
had Sex 64
breasts, waste, thighs, prob grab ass
had shirt on
over to under touch
massages
outside in lawn chair (JE) by pool
think he wear Shirt/shorts
Kitchen- not full body mass.
only
man who massage dark hair
2-3x saw
couple inches taller (1m 5'4)
him
EFTA00022650

=== Page 6 ===
6
upstairs massages
upstairs seemed
more intimate things
more intimate
massages done upstairs
girl had Rm upstairs
think she told
She had shared w/ me they had
me She lived
guests that stayed upstairs
there but
She took care of those guests
dont remember
1/2 my understanding thats how
She got to live there
/ knew downstairs
/ didnt feel free to roam up there
girl said they were visitors
when 1st went
photo
woman had bikini bottoms on the had
towel walk through
this is nowrich
people live
Kitchen - stacks of fiji water bottles
beautiful naked
people around
JE/GM - my understanding they bf/gt
they lived 2gether
made chear their house
phone lines for them
EFTA00022651

=== Page 7 ===
7
they live 3 work
now thinking
never saw kissing or being intimate
there
dont remember
think all men calling
called about
dont remember if women calling
$200 hk
$100 bills
didnt care to understand
didnt ask questions
assumed they live there or 2nd home
they always there when / there
/ not there whennot they
I stopped going got kicked out of school
I slept on their
couch for a while
he mom 1 came in
2001 I flew home for Christmas
sitting at table
flew back
w/ 2 officers
investigating
Stop around 2002
pros. ring
they asked if
1 would
| was more into partying $ snorting
continue go back
cocaine than working
get info
/ said no
said w/ Vice squad I think
LOCt DD
Man the woman
EFTA00022652

=== Page 8 ===
8
never had talk police prior to that
when I 1st Start 1 told my Mom
I was going 5 making lot money
richguy house
mom called univ. the Said something
wrong -school said no its fine
husband knows
hadnt thought bout it in yes and
worked there but
saw Jt arrest
doesnt know everything
(by Gm) (by GM)
/ feel like / recruited off the bat &
felt like She was going to recruit
use me to
other girls
EFTA00022653


c1: EFTA00021753
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021753.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Michael Bachner
To: "
)"
Cc:
⑉
)"
,
Subject: RE: Epstein investigation
Date: Wed, 07 Aug 2019 17:40:26 +0000
Inline-Images: image001.jpg; image002.jpg; image003.png
I will only have about 10 minutes. But OK
Michael Bachner
Bachner & Associates, P.C.
Partner
39 Broadway, Suite 1610
NY NY 10006
AMERICAN COLLEGE LEGE
OF
TRIAL
LAWYERS
https://www.actl.com/
Michael Bachner, Esq.
Bachner & Associates, PC
39 Broadway, Suite 1610
New York, NY 10006
www.bhlawfirm.com
RATED BY
Super Lawyers
CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic
Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally
privileged. If you are not the intended recipient, you are hereby notified that any retention,
dissemination, distribution, or copying of this communication is strictly prohibited. Please reply to the
sender that you have received the message in error and then delete it. Thank you.
From:
) [mailto:
Sent: Wednesday, August 7, 2019 1:30 PM
To: Michael Bachner
Cc:
)
is
EFTA00021753

=== Page 2 ===
Subject: RE: Epstein investigation
/
Following up, would 2:30 work for a call today? Thanks.
From:
Sent: Wednesday, August 7, 2019 11:35 AM
To: Michael Bachner
Cc:
is
Subject: RE: Epstein investigation
/
Hi Michael,
We just tried your office-please let us know if we should reschedule. Thanks.
From: Michael Bachner
Sent: Thursday, August 1, 2019 3:41 PM
To:
Cc:
is
Subject: RE: Epstein investigation
/
11:30?
Michael Bachner
Bachner & Associates, P.C.
Partner
39 Broadway, Suite 1610
NY NY 10006
AMERICAN COLLEGE LEGE
OF
TRIAL
LAWYERS
https://www.actl.com/
Michael Bachner, Esq.
Bachner & Associates, PC
39 Broadway, Suite 1610
New York. NY 10006
www.bhlawfirm.com
RATED BY
Super Lawyers
EFTA00021754

=== Page 3 ===
CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic
Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally
privileged. If you are not the intended recipient, you are hereby notified that any retention,
dissemination, distribution, or copying of this communication is strictly prohibited. Please reply to the
sender that you have received the message in error and then delete it. Thank you.
From:
)
[mailto:
Sent: Thursday, August 1, 2019 3:11 PM
To: Michael Bachner
Cc:
is
)
Subject: RE: Epstein investigation
Mike,
That would work -- we could do any time between 11 a.m. and 3 p.m. this coming Wednesday. What time should we put
in the calendar?
thanks,
From: Michael Bachner
Sent: Thursday, August 01, 2019 14:48
To:
Cc:
Subject: RE: Epstein investigation
Wednesday ?
Michael Bachner
Bachner & Associates, P.C.
Partner
39 Broadway, Suite 1610
NY NY 10006
AMERICAN COLLEGE
OF TRIAL OF LAWYERS
https://www.actl.com/
Michael Bachner, Esq.
Bachner & Associates, PC
39 Broadway, Suite 1610
New York NV 10006
www.bhlawfirm.com
EFTA00021755

=== Page 4 ===
RATED BY
Super Lawyers
CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic
Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally
privileged. If you are not the intended recipient, you are hereby notified that any retention,
dissemination, distribution, or copying of this communication is strictly prohibited. Please reply to the
sender that you have received the message in error and then delete it. Thank you.
From:
)
[mailto:
Sent: Wednesday, July 31, 2019 7:39 PM
To: Michael Bachner
Cc:
is
)
Subject: RE: Epstein investigation
Michael,
We wanted to follow up on our previous discussions and our meeting the week before last. Is there a good time for you
early next week to discuss status?
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00021756


c1: EFTA00020665
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020665.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)'
To:
(NY) (OGA) (FBI)"
Cc
(NY) (FBI)"
Subject: FW:
Date: Tue, 14 Jul 2020 20:11:09 +0000
Attachments: Initial_Review_of_Records.pdf
Hi
Hope all is well. Are you available for a quick call regarding this 302? Trying to run down how Lt.
got
the number for
Thanks in advance!
Original Message
From:
(NY) (FBI)
Sent: Tuesday, July 14, 2020 2:51 PM
To:
(USANYS)
Subject:
Hey
When looking through my case file, this is where Mike documented the phone number and last call made by
Epstein. Let me know if you need anything else.
Special Agent
FBI New York Field Office
Violent Crimes Task Force
EFTA00020665


c1: EFTA00022130
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022130.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Re: United States V. Ghislaine Maxwell
opens
Date: Mon, 29 Nov 2021 14:28:48 +0000
Good luck guys!!
Sent from my iPhone
On Nov 28, 2021, at 9:59 AM
wrote:
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors
will do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine
Maxwell sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her
accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00022130


c1: EFTA00023311
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023311.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Lyft Ride Receipt <no-reply@lyftmail.com>
To:
Subject: Your ride with
on February 26
Date: Wed, 26 Feb 2020 23:52:08 +0000
lyft
FEBRUARY 26, 2020 AT 10:51 AM
Thanks for riding with
Lyft fare (11.29mi, 39m 49s)
$27.59
Tip
$4.14
$31.73
Ride Map
Pickup 10:51 AM
Los Angeles Int'l Airport, Los Angeles, CA
Drop-off 11:30 AM
FAVORITE DRIVER
TIP DRIVER
FIND LOST ITEM
EFTA00023311

=== Page 2 ===
REQUEST REVIEW
Review price in the Lyft app help tab
Help Center
Receipt #1376271668412774216
We never share your address with your driver after a ride.
Learn more about our commitment to safety.
© Mapbox © OpenStreetMap Improve this map
© 2020 Lyft, Inc.
548 Market St., P.O. Box 68514
San Francisco, CA 94104
CPUC ID No. TCP0032513 - P
Work at Lyft
Become a Driver


c1: EFTA00020889
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020889.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
To:
)"
Cc:
)"
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Date: Fri, 30 Oct 2020 15:14:50 +0000
That works for me. I will call in at 10am Monday.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line:
Thanks,
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
EFTA00020889

=== Page 2 ===
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
>
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
EFTA00020890

=== Page 3 ===
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still be
grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
>
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
II
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com> "Donnini, George B." <donnini@butzel.com>
Cc:
)"
>,
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
EFTA00020891

=== Page 4 ===
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would you
please confirm that your production included all records of any tuition payments that Epstein (or his entities) made for
any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow and
will have limited availability this week, but my colleagues
and
(both cc'd) should be able to
coordinate with you as needed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
Cc:
is
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
II
)"
Date: Thursday, February 6, 2020 at 1:51 PM
EFTA00020892

=== Page 5 ===
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
"
)"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey Epstein
and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00020893


c1: EFTA00020858
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020858.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
Subject: RE: Questionnaire - Hi We also need this one ASAP. Thanks
Date: Fri, 24 Jan 2020 15:32:58 +0000
Attachments: Questionnaire_for_Official_Foreign_Travel_Stockholm_2020_
).pdf
Attached is my questionairre
From:
(USANYS)
Sent: Friday, January 24, 2020 10:32 AM
To:
is
Subject: Questionnaire - Hi We also need this one ASAP. Thanks
Importance: High
EFTA00020858


c1: EFTA00021059
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021059.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Epstein -- travel approval form
Date: Mon, 03 Feb 2020 21:07:07 +0000
Right now 1 p.m. looks open.
From:
Sent: Monday, February 3, 2020 1:33 PM
To:
Subject: RE: Epstein -- travel approval form
No problem at all, and I'm very flexible tomorrow afternoon - whatever time is good for you I can make work, so just let
me know and l'll put it in the calendar.
From:
Sent: Monday, February 03, 2020 13:31
To:
Subject: RE: Epstein -- travel approval form
So sorry for the delay. Maybe tomorrow? I have time in the afternoon.
From:
Sent: Friday, January 31, 2020 1:09 PM
To:
Subject: RE: Epstein -- travel approval form
Totally understand, and next week would be fine - let me know if it's helpful to set a time, and otherwise l'll touch base
midweek if we haven't connected by then.
And thanks very much re: the memo.
From:
Sent: Friday, January 31, 2020 12:53
To:
Cc:
Subject: RE: Epstein -- travel approval form
Already signed and sent upstairs
I will do my best to ensure signature immediately.
Re: this afternoon: it may be best to kick it to next week. If some time develops before 3, I'll let you know, but right now
it is iffy.
From:
Sent: Friday, January 31, 2020 12:21 PM
To:
Cc:
Subject: Epstein -- travel approval form
EFTA00021059

=== Page 2 ===
We dropped off the Sweden travel memo for you - we were unexpectedly significantly delayed in getting OIA approval,
but it finally came this morning, so with apologies for the short turnaround, hoping to get Office and final DOJ approval
this afternoon. Thank you!
And separately, if you still wanted to meet up today, l'll be around until about 3:00, but I'm also flexible next week if that's
easier.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00021060


c1: EFTA00022014
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022014.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: RE: Noel/Thomas FOIA Disclosure
Date: Wed, 23 Jun 2021 21:59:37 +0000
Attachments: 062321_Times_v_BOP_20cv833_Extension_Request_v2.docx
Hi all,
The Times consented to the one-week request. I think it is likely the Court will approve it. I plan to file the attached letter,
which includes the changes we discussed on the phone, around 6:30. Please let me know if you have any issues or
concerns. I'll let you know as soon as the Court rules.
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 5:12 PM
To:
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Hi all,
We now have a 5:45 call scheduled with the Times. Please let me know before then if there's any other info I can share
with them. I'm attaching a draft extension request letter here for review. Please let me know if this looks okay, or if we
need to discuss anything,
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 3:46 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Hi all,
I just spoke with
, who spoke with
I can make this request, but I am not sure it will be successful. Before I
speak to the Times about it, I need to know a little bit more info about what I can share with the Times and what is going
on. Could someone please give me a call at
?1 need to connect with the Times as soon as possible because
we will need to put in the request today to PAE.
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 3:02 PM
EFTA00022014

=== Page 2 ===
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Hi
Could I give you a quick call on this?
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 2:57 PM
To:
(USANYS)
Cc:
(USANYS)
V.
(USANYS)
Subject: Noel/Thomas FOIA Disclosure
Hi
We understand you had been planning to make the Noel/Thomas FOIA disclosure on Friday. We just ran this by
and she'd like you to ask for a brief (1-2 week) extension to enable us to confer internally regarding the interviews, which
were just completed, to confirm we agree they've fulfilled that requirement of their deferred prosecution agreements.
She's going to speak with
about it as well. Is this doable?
Thanks,
Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
Desk
Cell
EFTA00022015


c1: EFTA00021912
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021912.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Joint Automated Booking System - Limited Official Use
Page 1 of 2
MAXWELL, GHISLAINE
Package is Current
Trans ID:
Received: 07/08/2020 14:21:17
FBI No:
FBI Name:
MAXWELL,GHISLAINE NOELLE
DOB:
Date Arrested
or Received: 07/02/2020
Charges:
6405 Sexual Exploitati.
6405 Sexual Exploitati.
3622 Transport Interst
3622 Transport Interst
5003 Perjury
5003 Perjury
Personal History
General Information
FBI Name:
MAXWELL, GHISLAINE NOELLE
FBI No:
Trans ID:
Aliases
MAX, G
Status:
JABS Updated
Package ID:
F5C9BC0CBA14407D96D14A1BF0900815
Phone:
(R);
(R);
Address:
Bradford, NH US 03221
Detention Information
Location:
Date:
07/02/2020
Biographic Information
Gender:
Female
Race:
White
Ethnicity:
DOB:
Hair:
Black
Eye:
Brown
Height:
5' 7"
Weight:
142
Identifying Characteristics (NCIC Code, Description)
NONE
Marital Status:
Occupation:
Health Status:
Education:
Medications
NONE
Birth City:
Birth State:
Birth Country:
FRANCE
Citizenship:
USA
Arrested or Received Information
Officer Name:
Phone:
Jurisdiction:
Charges (Charge, Offense Date)
6405 - Sexual Exploitation of Minor - Sex Performance
07/02/2020
6405 - Sexual Exploitation of Minor - Sex Performance
07/02/2020
3622 - Transport Interstate for Sexual Activity
07/02/2020
3622 - Transport Interstate for Sexual Activity
07/02/2020
5003 Perjury
07/02/2020
5003 Perjury
07/02/2020
Warrant Numbers
NONE
Agency:
FBI
ORI:
NYFBINY00
https://www.cjis.gov/jabs/query_showPrinterFriendlyPersonalHistory.do?transactionld=6.. 7/22/2020
EFTA00021912

=== Page 2 ===
Joint Automated Booking System - Limited Official Use
Page 2 of 2
Agency Site:
1 NEW YORK, NY, US
Date Arrested
07/02/2020
or Received:
Originating Agency
Agent:
Phone:
Agency:
Site:
Place Arrested
...
or Received:
Fingerprint Date:
07/02/2020
Armed Description:
Drug History:
Mental Competency:
Special Handling:
Arrested or
Received Narrative:
Booking Information
Agent:
Phone:
Agency:
FBI
ORI:
NYFBINY00
Site:
1 NEW YORK, NY, US
Role:
Date:
07/02/2020
Offender Identification - Numeric Identifiers
Trans ID:
USMS/BOP No:
SSN:
NADDIS No:
Agency Case No:
FBI No:
INS No:
Identifying Documents
NONE
Vehicle Information
NONE
Incarceration Information
NONE
Separatee Information
NONE
Associates Information
NONE
Immediate Family Information
NONE
Limited Official Use
https://www.cjis.gov/jabs/query_showPrinterFriendlyPersonalHistory.do?transactionld=6.. 7/22/2020
EFTA00021913


c1: EFTA00020487
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020487.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
OFFICIAL RECORD
Intake (Rev. 5-23-17)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Intake
Date: 08/18/2020
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Drafted By:
Date/Time Received: 08/18/2020 03:46 PM EDT
Supplements 50D-NY-3027571 Serial 504
Details:
On 08/17/2020, at 3:03 PM Eastern Time,
date of birth
telephone number
email address
address
Maitland, FL
32751, Internet Protocol (IP) address
which resolves to Orlando,
FL, submitted an online tip to the FBI National Threat Operations Center (NTOC) via tips.fbi.gov, to report
potential information regarding Ghislaine Maxwell and her alleged attempt to recruit her while a minor.
Date Submitted: 08/17/2020 03:03:27 PM ET
Transaction Number: 4266F212-4510-4FDC-A1D3-4A0606A83724
Threat To Life:
Submitted Text:
| made a podcast of my story two weeks ago as I've not known what else to do with my encounter to
support her tactics and MO. She tried to get me to call her about modeling opportunities after coming into
the gym to speak with me personally cater she saw me in the window of the gym
Violation: Other
Violation Questions
What was the exact crime that occurred?: Ghislaine Maxwell tried to recruit me when I was a child/minor
UNCLASSIFIED
EFTA00020487

=== Page 2 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/18/2020
When did the crime/incident occur? (Please provide an approximate date and time): 1993? I was 14/15
years old working at a GYM daycare in Jupiter FL
Where did the crime/incident occur? (Please provide the specific location/address if possible): 1993? I was
14/15 years old working at a GYM daycare in Jupiter FL
Complainant Information
First Name:
Middle Name:
Last Name:
Age:
DOB:
Additional Info:
Type: Cell
Phone:
Extension: NA
Account:
Type: Residential
Address:
City: Maitland
State: Florida
Zip: 32751
Country: United States
Subject Information
First Name: Ghislaine
UNCLASSIFIED
2
EFTA00020488

=== Page 3 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/18/2020
Middle Name:
Last Name: Maxwell
Age: 31
DOB:
Additional Info: My podcast has additional information
Happy to provide once someone reaches out to me.
How is Contact Known: She approached me for modeling opportunities from the gym I was working at in
Jupiter florida when I was 14 years old.
She gave me her card but I never called her as I had several legit modeling agencies tell me I am not
runway/model type so I just smiled and listened politely to her offers.
Type: Other
Address:
City:
Zip:
Witness Information
First Name:
Middle Name:
Last Name:
Age: 14
DOB:
Additional Info: Please contact
How is Contact Known: I am the witness
UNCLASSIFIED
3
EFTA00020489

=== Page 4 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/18/2020
Type: Cell
Phone:
Extension: NA
Type: Other
Address:
City:
Zip:
Remote IP:
Remote Host: api.fbi.gov
Http Referrer: https://tips.fbi.gov/reported
User Browser:
Latitude:
Longitude:
Country: US
Region: Florida
City: Orlando
Postal Code: 32805
Timezone: -04:00
UNCLASSIFIED
4
EFTA00020490


c1: EFTA00023122
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023122.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Travel for trial witness
Date: Thu, 28 Oct 2021 18:40:56 +0000
Attachments: Fact_Witness_Travel_Request_
docx
Hi
See attached. We haven't set a firm time for our meeting on November 14, so let me know if you want to discuss any
logistics. Please let me know if you need any other information.
Thanks so much!!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
EFTA00023122


c1: EFTA00020790
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020790.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Re:
Date: Mon, 11 Mar 2019 18:33:18 +0000
Importance: Normal
We're going to hold off til next week.
Sent from my iPhone
> On Mar 11, 2019, at 2:30 PM,
(USANYS)
wrote:
>
> Epstein OK
V
> Sent from my iPhone
>
>> On Mar 11, 2019, at 2:12 PM,
(USANYS)
wrote:
and I have been asked by
to present on our campaign finance cases. We're doing NRA, PIC
and GEP, all of which have POTUS ties. Do we need to ask
to step out?
>>
Sent from my iPhone
EFTA00020790


c1: EFTA00021349
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021349.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: some updates
Date: Thu, 26 Sep 2019 16:59:21 +0000
1) The agents think that
is in Florida. They told me they'll plan to approach him the next time we're in
Florida, whenever that happens.
2) The agents are in touch with
He is cooperative but would like a subpoena (which I'll issue). He has
boxes of case files that he does not think the FBI ever collected, and he has agreed to provide them to us when/if
we meet with him (in Florida).
3) I asked the agents for more information about the envelopes of cash in Epstein's safe marked
They'll get
back to us.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00021349


c1: EFTA00020509
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020509.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
OFFICIAL RECORD
Intake (Rev. 5-23-17)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Intake
Date: 10/13/2020
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Drafted By:
Date/Time Received: 10/13/2020 04:21 PM EDT
Details:
On 10/12/2020, at 3:14 p.m. Eastern Time,
date of birth
cellular telephone
number
email account
home address
Brownsboro, AL 35741, Internet Protocol (IP) address
which resolves to Huntsville,
Alabama 35801, submitted an online tip to the FBI National Threat Operations Center (NTOC) via
tips.fbi.gov, regarding possible evidence related to Jeffrey Epstein case in Brownsboro, AL.
Date Submitted: 10/12/2020 03:14:39 PM ET
Transaction Number: 71070050-AE2D-4C04-B0CB-2885FAE50B45
Threat To Life: False
Submitted Text:
I have an email from girl who was in Growing Together Inc. at same time
was abducted and
raped for 6 months by Jeffery Epstein. Other kids that were there at this time also telling same story in
email. Also in email is lots of information as to who was abusing these kids and those abusers political
connection.
Violation: Public Corruption, White Collar Crime, Civil Rights
Violation Questions
What was the exact crime that occurred?: children tortured in cults in America. Sexual assault, kidnapping,
trafficking
UNCLASSIFIED
EFTA00020509

=== Page 2 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 10/13/2020
Does this information involve a government official? If so, what is their name and position/title?: Yes, John
Scarola/City Attorney of Palm Beach County, Michael Egauger/Chief of Palm Beach Sheriff, Mark Foley/ was
member of House of Rep. to many to list. FBI has names of the ones involved in Straight Inc. Investigation
around 1983. This tip refers to Growing Together Inc. the Epstien
Do you have any evidence to support your claim or know of any witnesses to the crime(s)?: yes
Did you suffer any personal losses (financially or physically) due to the crime?: Yes, most children have
suffered
How long has this activity been going on?: 40+ years
Complainant Information
First Name:
Middle Name:
Last Name:
Age:
DOB:
Additional Info:
Type: Cell
Phone:
Extension:
Account:
Type: Residential
Address:
City: Brownsboro
State: Alabama
Zip: 35741
UNCLASSIFIED
2
EFTA00020510

=== Page 3 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 10/13/2020
Country: United States
Subject Information
First Name:
Middle Name:
Last Name:
Age:
DOB:
Additional Info: Your going to have to contact me. To much information
How is Contact Known: Benn told
Type: Other
Address:
City:
Zip:
Witness Information
First Name:
Middle Name:
Last Name:
Age: 15
DOB:
Additional Info: I have emails
How is Contact Known: Meet because of same abuse in different time frames but same abusive cults against
kids
UNCLASSIFIED
3
EFTA00020511

=== Page 4 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 10/13/2020
Type: Cell
Phone:
Extension:
Type: Other
Address:
City:
Zip:
Agency Name: detective in Atl. Ga, 2 Alabama Representatives, 1advocate of Human trafficking
Report Number:
Address:
City:
Zip:
Remote IP:
Remote Host: api.fbi.gov
Http Referrer: https://tips.fbi.gov/
User Browser:
Latitude:
Longitude:
Country: US
Region: Alabama
UNCLASSIFIED
4
EFTA00020512

=== Page 5 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 10/13/2020
City: Huntsville
Postal Code: 35801
Timezone: -05:00
UNCLASSIFIED
5
EFTA00020513


c1: EFTA00022989
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022989.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: notes from t/c with counsel to Prince Andrew
Date: Fri, 10 Jan 2020 14:52:05 +0000
- introductions
0 prosecutors and also two primary FBI agents
- may be helpful to start by describing what we're requesting, and then we can answer any questions that we're able to
requesting a voluntary, consensual interview
0 how does such an interview ordinarily work?
not recorded, not videotaped or audiotaped; instead, agents take notes (and of course counsel can
take notes as well)
the interview is not formally under oath, there's no swearing-in, but it is a crime in the U.S. to
knowingly lie to federal law enforcement officers
0 again in terms of process, we do not publicize the content or even the existence of these interviews
obviously can't guarantee that no one who might come to know about the interview would tell the
press, but our office does not advise the press of interviews
notably, it was reported months ago that we were attempting to interview Prince Andrew, which was
inaccurate, and now we have been working on this request for approximately the past month and
there have been no media reports about it
0 after we've completed an interview, we communicate with counsel as necessary, including with any required
follow-up
- so that's the process, in terms of the substance
explain target / subject / witness
ordinarily we don't confer a label like that unless asked, but those are the categories
0 subject matter we are interested in is, broadly, the nature and scope of client's relationship with Jeffrey Epstein
and his associates, including professional associates, staff, and personal relationships, including Ghislaine
Maxwell
how they came to know each other, how long they were in contact, what the nature of their contacts
were, how often communicated
for Epstein in particular but also Epstein's associates
0 then in particular there have been public allegations from at least one individual and we would
- able to identify targets?
0 no, can't identify targets, but are not saying that their client is a target
- expected timeline?
0 as soon as reasonably practicable (moving the investigation forward expeditiously), and with the goal of
covering all relevant subjects in the initial meeting if possible
- as matters stand, whether we would say he is a target / witness / subject?
0 subject, and noting that it is sometimes the case that individuals are a subject by default until there is sufficient
information to classify them as a witness
- parties agreed to be in touch in the coming days
EFTA00022989


c1: EFTA00022958
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022958.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: FW: New documents:
V. Maxwell (Doc# -, 2d Cir. 20-02413)
Date: Thu, 30 Jul 2020 21:13:15 +0000
Attachments: 2020-07-30_[-].zip
Inline-Images: image001.jpg
From: Sigrid McCawley
Sent: Thursday, July 30, 2020 4:42 PM
To:
>;
is
;
Cc: Peter Skinner
Subject: FW: New documents:
V. Maxwell (Doc# ", 2d Cir. 20-02413)
Please see the attached Motion to Stay filed with the Second Circuit by Maxwell's counsel today. I will be responding to
this by tomorrow.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
From: ECFdocuments@pacerpro.com [mailto:ECFdocuments@pacerpro.com
Sent: Thursday, July 30, 2020 2:47 PM
To: Sigrid McCawley
Subject: New documents:
V. Maxwell (Doc# -, 2d Cir. 20-02413)
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
EFTA00022958

=== Page 2 ===
V. Maxwell
Docket entry number:
MOTION, to stay, on behalf of Appellant Ghislaine Maxwell, FILED. Service date
07/30/2020 by CM/ECF. [2896538] [20-2413]
Date entered: 2020-07-30
VIEW CASE
https://app.pacerpro.com/cases 13420037
Sent from PacerPro, the fastest and most insightful way to access federal court records.
Questions? sales@pacerpro.com or (415) 890-4958
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
EFTA00022959


c1: EFTA00021398
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021398.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
Subject: RE: Wednesday
Date: Mon, 29 Jul 2019 22:09:10 +0000
Inline-Images: image005.jpg; image006.png; image002.jpg; image004.png
Hi
Thanks for letting us know about the possible meeting location change- please let us know once you've been able to
confirm with your client, and we can let
know so that she can cancel the car service.
Regarding the court conference, we are unfortunately not able to reserve seats for anyone-the court manages court
security and the crowd, so we don't have control over that. The other victim attorneys have been attending the
conferences on their own, and although I don't know, I would guess that means that they have been arriving early.
Thanks,
From:
Sent: Monday, July 29, 2019 6:00 PM
To:
Subject: RE: Wednesday
Thank you very much for this information. I plan to attend this court this status conference on Wednesday. I am
concerned that the courtroom may be full and no seat will be available for me Would you be kind enough to have
someone on your staff save a seat for me? Also, since the courthouse is very close to your office I have emailed
to
ask if she would be willing to meet at your office instead of at my hotel at 1P.M.Since her hotel is near to your office and
near the courthouse and since I will be in the area now as well, if she feels comfortable meeting at your office instead of
my hotel I am willing to meet at your office to save you and her the time to travel to my hotel. I will let you know when
she responds.
From:
Sent: Monday, July 29, 2019 1:50 PM
EFTA00021398

=== Page 2 ===
To:
Subject: RE: Wednesday
Hi
Yes-in - this district, criminal defendants are present at all court conferences absent unusual circumstances.
From:
Sent: Monday, July 29, 2019 4:46 PM
To:
Subject: Wednesday
I see that a status conference is scheduled for Mr. Epstein 's criminal case in court in New York at 11A.M.on Wednesday
,July 31. Do you know if Mr. Epstein will be present for the status conference in court on Wednesday?
EFTA00021399


c1: EFTA00023125
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023125.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: [EXTERNAL] information
Date: Thu, 28 Oct 2021 19:50:05 +0000
Hi,
I submitted the request via the on line website of the BOP as suggested by the person I spoke to there.
The below is what I am requesting at this time.
i am the sole heir and next of kin of JEFFRFEY EPSTEIN, who died while in federal custody at the MCC in NYC.
I am requesting the same information that was released to the New York Times regarding all of the information they
requested under the FOIA regarding my brother's case.
I would also like a copy of the video tape from the camera outside of the SHU on August 9th 2019, which would show the
last time anybody (guards, etc) left the SHU prior to my brother being found dead in his cell the next morning.
This is the tape that then Attorney General Barr publicly stated that he personally watched.
I would also like a list of the inmates that were on that tier on August 9th, 2019. Also, please provide the information of
when they were placed on that tier and when and where they were transferred to if they are not still on that tier.
I would like any information that would reveal the identities of the people in the prison who were directing the action on
that tier, and who was in the cell with the EMT's that came after my brother was found dead. I am trying to find out why
normal protocol was not followed in that the body of a clearly dead person was moved prior to the medical examiner
office being given the chance to photograph the crime scene. I would imagine that there was some sort of incident report
filed regarding this matter and I would like that as well.
I would appreciate it if you can get this done in a timely manner.
Thanks,
From:
Sent: Monday, October 25, 2021 8:34 PM
To:
Cc:
Subject: Re: [EXTERNAL] information
Hi Mr.
As I discussed with Ms.
over the summer, you would need to submit a FOIA request to the BOP and note that
you are specifically requesting what they released to the NYT. You can send me copy of that request once it has been
submitted to the BOP and as a courtesy I will ensure that the correct recipient in the Civil Division of our Office has
received it. We do not handle FOIA requests in our division.
EFTA00023125

=== Page 2 ===
Best,
On Oct 25, 2021, at 12:40 PM,
wrote:
Hi,
Hope this finds you well.
I would like to get a copy of ALL of the records that were released to the New York Times on their FOI request regarding
my brother's case (Jeffrey Epstein).
Please advise the quickest way to accomplish this.
Thanks,
Scanned by McAfee and confirmed virus-free.
EFTA00023126


c1: EFTA00020797
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020797.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Date:
M BEACH POLICE DEPARTMENT
Page:
Time:
Incident Report
Program:
Case No
(Continued)
Entered By. :
On
2006, I received several phone calls throughout the day
from
who stated he had been followed aggressively by a private
investigator.
stated that as he drove to and from work and
running errands throughout the county, the same vehicle was behind him
running other vehicles off the road in an attempt not to lose sight of
's vehicle.
I explained to him as Mr. Epstein had retained new legal council it
was possible it would be new private investigators following him to
observe his daily activities. I also explained to him that there was
a meeting scheduled with
and
at
scheduled on
I attempted to call
to inform
of the
private investigators following
however;
I received other phone calls from
and
who
/
advised they were able to acquire the private investigators license
plate information. The subject following them was again driving very
aggressively and caused
to run off the road.
stated
the vehicle is a green Chevy
bearing Florida tag
The vehicle is registered to
of
Florida.
is employed with
Investigations from
/
Florida.
is a licensed Private Investigator in the State of Florida.
Since the discovery of the threat made against one of the victims in
this case
/
I requested subpoenas for all calls made to and
received from
during the month of March 2006 for her
cell phone and home phone. I had confirmed with Florida State
the exact dates of Spring Break
The Spring Break
was from March 4, 2006 through March 12, 2006. I received a subpoena
from
with all calls made during the month of
I reviewed the 989 calls made and received during the month of March
2006. I observed on
2006,
made and received thirty
five calls during that day.
Date
Time
Seconds
In/Out
To/From
-06
11:03 AM
492
Outbound
-06 11:16 AM
6
Inbound
06 11:22 AM
887.2
Inbound
-06 11:37 AM
48
Outbound
06 11:39 AM
28.2
Inbound
06 12:02 PM
727.2
Inbound
The table reflects the date of the calls, time of day (EST), duration
EFTA00020797

=== Page 2 ===
Date:
LM BEACH POLICE DEPARTMENT
Page:
Time:
Incident Report
Program:
Case No
:
(Continued)
of call in seconds, inbound or outbound calls and calls made to or
from
phone. On
,
2006, at 11:03 am,
made a call
to the victim which lasted 492 seconds (8 minutes and 2 seconds)
The victim then returned the call at 11:16 am which lasted 6 seconds.
The victim then made contact with
at 11:22 am for 877.2 seconds
(14 minutes and 6 seconds). These sequences of calls were consistent
with what the victim had described to me on the date of the
intimidation. Immediately after speaking with the victim,
makes
a call to
Epstein's assistant, which lasts for
forty-eight seconds. A call is then immediately received, a telephone
number registered to a Corporation affiliated with Jeffrey Epstein
located at 457 Madison Ave in New York. An extensive computer check
revealed 457 Madison Ave is a business address in which Epstein has
his corporations assigned to. Epstein had corporation attorney,
register the businesses and register himself as an
agent. I also observed Epstein has his El Zorro Ranch Corporation,
New York Strategy Group, Ghislaine Corporation, J Epstein and Company
and the Financial Strategy Group registered to this same address.
Finally, a third call is received by
at 12:02 pm from the same
corporate number which lasts 12 minutes and 1 second. It should be
noted that there is no further contact with either the victim during
the month of
of 2006. I also noted that there was no
further contact with
or Jeffrey Epstein during the
remainder of the month of
2006.
On
, 2006,
telephoned me to inform me of the
meeting that occurred with Atty.
and
reference
this case.
Inv Continues.
EFTA00020798


c1: EFTA00023460
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023460.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Nathan NYSD Chambers
To:
)"
(USANYS)"
>, Laura Menninger
>, , "Jeff
Pagliuca"
,
)"
Subject: 20cr330, US V. Maxwell
Date: Fri, 29 Oct 2021 22:17:31 +0000
Attachments: 20cr330_Order_10.29.21.pdf
Counsel:
Attached please find an Order 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
EFTA00023460


c1: EFTA00020907
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020907.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: Re: Epstein catch up
Date: Sun, 17 Nov 2019 17:25:41 +0000
I'm in White Plains all day Wednesday. Monday 5:30 would work for me.
On Nov 17, 2019, at 11:47 AM,
)
wrote:
Wednesday morning okay for you both?
Sent from my iPhone
Begin forwarded message:
From:
(USANYS)"
Date: November 16, 2019 at 21:18:48 EST
To:
)"
)"
)"
Cc:
(USANYS)"
Subject: Epstein catch up
Can we find a time in the near future to catch up on a few things, including hearing more about your
interview last week? Unfortunately both
and I have to be out portions of Monday/Tuesday. Would
Monday at 530 work for you guys? If not, can we aim for Wednesday morning. Thanks
Sent from my iPhone
EFTA00020907


c1: EFTA00022641
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022641.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Jeffrey EPSTEIN
Date: Thu, 25 Jul 2019 14:40:39 +0000
Gimme a call on this when you have a second, not urgent. Thanks
From:
Sent: Thursday, July 25, 2019 8:04 AM
To:
Cc:
;
Subject: Re: Jeffrey EPSTEIN
Just spoke with
It sounds like the SHU Lieutenant who wrote the first report about the incident only mentioned
redness on Epstein's neck without mentioning any sort of object around the neck. Two other officers who responded to
the cell apparently wrote supplemental reports saying that Epstein had something around his neck when they saw him.
didn't have the reports in front of him when we spoke, so he couldn't be more specific. I've asked him to provide
us with the reports as soon as possible.
On Jul 24, 2019, at 10:45 PM,
wrote:
Yes, if true, would be somewhat shocking that
didn't report (and more shocking that they took him off suicide
watch). Please let us know what you find out.
Sent from my iPhone
On Jul 24, 2019, at 10:43 PM,
wrote:
FYI, just received the below. The noose is a new detail I had not heard. I've reached out to
to ask if he has any
new information or reports.
Begin forwarded message:
From:
Date: July 24, 2019 at 9:35:05 PM EDT
To:
>,
Subject: Jeffrey EPSTEIN
All,
Please be advised that we received he following report from the Bureau of Prisons MCC New York at 2115 hours on
this date:
Associate Warden (AW)
at MCC New York advised that Jeffrey EPSTEIN was found in his cell this
morning at 0127 hours in a fetal position with a noose around his neck. EPSTEIN was escorted to medical and was
assessed. EPSTEIN was initially placed on suicide watch and subsequently downgraded to suicide observation, where
he currently remains. Additionally, AW
advised that EPSTEIN's cell mate reported threated to kill him.
No further information was provided.
EFTA00022641

=== Page 2 ===
The above incident is currently under investigation with the BOP.
Supervisory Deputy United States Marshal
Southern District of New York
EFTA00022642


c1: EFTA00021785
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021785.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Ghislaine Maxwell
Date: Tue, 07 Jul 2020 18:39:15 +0000
Hi
Thanks very much.
has connected with us about this issue, so we'll coordinate with her.
Thanks, and hope you're doing well-
EFTA00021785

=== Page 2 ===
EFTA00021786


c1: EFTA00020662
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020662.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: RE: for the AUSA handling the new investigation
Date: Mon, 13 Jul 2020 22:51:57 +0000
From:
Sent: Saturday, August 10, 2019 5:34 PM
To:
Cc:
Subject: RE: for the AUSA handling the new investigation
We just got word from C-19 that Epstein made a phone call last night to Kristina Schuliak (ph), who is his current / latest
girlfriend, around 7:00 p.m. The agents contacted her, she said she wanted a lawyer, and the agents have now heard from
her lawyer who says she'll tell them about the content of the phone call but she wants some kind of protections. It
sounds like the girlfriend is willing to talk sooner rather than later, so whenever someone is assigned to the new
investigation, we can put him or her in touch with that agent for whatever follow-up is appropriate.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00020662


c1: EFTA00023316
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023316.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 11061409-1(1) prepared by a travel arranger is pending your review
Date: Wed, 04 Mar 2020 13:40:10 +0000
Importance: Normal
Dear
Final voucher 11061409-1(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 11061409-1
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13400 - Epstein Investigation Witness interviews
Destination: Beverly Hills, CA, United States
Dates: 2020-02-26 - 2020-02-29
Current status: Pending Voucher Approval
Voucher total expenses: 1196.11
Estimated trip cost: 1634.37
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0012
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00023316


c1: EFTA00023412
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023412.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject:
Question
Date: Sat, 13 Nov 2021 23:50:46 +0000
Attachments: Pages_from_3507-011.pdf
I'm attaching two pages in
deposition in which he refers to PBPD taking his computer back when
they executed the search. Wanted to check in with you on this. Do you know if that happened and if they did take it,
what happened with his computer?
EFTA00023412


c1: EFTA00021347
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021347.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Re: proposed schedule.
Date: Sat, 21 Sep 2019 12:57:08 +0000
I could do Thursday afternoon
On Sep 21, 2019, at 7:38 AM,
wrote:
What about this Thursday assuming we get the proposal from BB by Tuesday ?
Assistant U.S. Attorney
Begin forwarded message:
From:
Date: September 21, 2019 at 07:21:28 EDT
To:
Cc:
Subject: Re: proposed schedule.
Any day next week works for me. Also in my role as Learned Counsel, and in full compliance with the ABA Guidelines, I
will be submitting a proposed schedule for penalty phase pleadings over the weekend.
Thanks
Tonyricco
Original Message
From:
To: Bruce Barket
Cc:
Sent: Fri, Sep 20, 2019 9:15 pm
Subject: Re: proposed schedule.
We are free next Friday afternoon if that works for you all.
Assistant U.S. Attorney
On Sep 20, 2019, at 12:16, Bruce Barket
wrote:
I think we will be ready to propose a schedule sometime early next week. Is there a day and time when you
can meet to discuss? We will send you a proposed briefing schedule ahead of the meeting. I hope to have
ours finalized no later than Tuesday.
EFTA00021347

=== Page 2 ===
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it
is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error;
any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have
received this communication in error, please notify us immediately by telephone or email and immediately delete this
message and all its attachments
EFTA00021348


c1: EFTA00023073
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023073.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From
To
Subject: Maxwell motions 2 of 3
Date: Wed, 03 Feb 2021 22:04:52 +0000
Attachments: 1.25.2021_Filing_2.zip
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York NY 10007
EFTA00023073


c1: EFTA00022633
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022633.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: FW: SDNY raid on Little Saint James
Date: Wed, 14 Aug 2019 18:37:56 +0000
Inline-Images: imagel.png; image2.png; image3.png; image4.png
Below is an email I received from someone who has a radio broadcast in USVI. He's investigating (what he believes is) an
ambulance which operated out of Epstein's compound. Just forwarding along, FWIW. Thanks.
From:
Sent: Wednesday, August 14, 2019 1:35 PM
To:
(USANYS)
Subject: Re: SDNY raid on Little Saint James
Mr.
Thank you for the reply. On the Ambulance issue I confirmed through Ms.
at USVI EMS the
following.
1. The vehicle has no registration of any kind. Required are Certificate of Need, ALS and BLS certification,
Medical Director, Protocols, Staff providing care need to be USVI certified. These are huge violations of law.
None of these requirements we even attempted to be obtained.
2. To import a vehicle of this type, the above requirements need to be in compliance. No record if it's
importation is on record with USVI EMS. This could mean
A. Some corruption in customs allowed its importation.
Or
B. It was smuggled via shipping container.
3. It holds a USVI license plate. Registering a vehicle of this type would be impossible, considering the above
items. It was however able to obtain a tag from BMV.
We confirmed through FDLE the vehicle was NOT listed on his Sex Offender Registration as his many other
vehicles are.
I will attach several screen shots of drone video we obtained from YouTube channel Rusty Shackleford In the
final picture the Ambulance appears to have been moved or removed from the property.
This is Ms.
email
I gave her yours also. I believe they are doing an official investigation and would be glad to cooperate. I am
available if I can be of any further help.
Our viewers, and I think the public in general, are not happy with what happened with Epstein. As I'm sure
SDNY is not. The questions we hear most, and are trying to answer with factual information are:
EFTA00022633

=== Page 2 ===
1. Is this video an official raid?
2. Why did it take so long?
3. Has this, and all his properties been searched and seized?
Answers to these questions would do much to restore the public's confidence in the investigation, as well as
those victims yet to come forward. A statement from SDNY would be welcomed.
Do you think a statement will be forthcoming? If so when? Thank you again for your time and attention.
Godspeed with the Epstein case.
PS: You might have already done this, but the Rusty Shackleford videos showed a lot of activity going on prior to
the raid. Think this would be valuable if evidence was being removed or destroyed.
Regards,
J Taylor
Host Traffick Report Show
L S J
...
BEAMBULANCE
EFTA00022634

=== Page 3 ===
BOOTON
Sent from my iPhone
> On Aug 14, 2019, at 12:49 PM,
(USANYS)
wrote:
V
> Thanks very much for the call, I'll decline to comment at this time.
>
> And if you want to share any of the information , you can forward anything to this email.
V
V
V
>
V
Public Affairs
> United States Department of Justice
> U.S. Attorney's Office Southern District of New York
V
Mobile:
I
Press Office:
V
V
>
V
V
Original Message
> From: John Taylor
> Sent: Tuesday, August 13, 2019 11:38 AM
> To:
,
Nicholas (USANYS)
> Subject: SDNY raid on Little Saint James
>
> Mr.
,
V
> Per our phone conversation please send us a statement (press release) on the recent Task Force raid on LSJ. We also had a
question about the seizure of that property. Just a reminder about the Ambulance. We have a source with USVI EMS who
states this is an unregistered vehicle operating illegally, that possibly was smuggled into USVI. We have a decent bit of
information we would be happy to share with SDNY about this.
V
> Warmest Regards,
> J. Taylor
> Host Traffick Report Show
V
> Sent from my iPhone
EFTA00022635


c1: EFTA00021050
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021050.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: WSJ; Deutsche Bank/Epstein
Date: Tue, 23 Jul 2019 14:46:36 +0000
The Journal plans to run an article basically connecting Deutsche to most of Epstein's business. It doesn't seem like
they're going to suggest that DB was complicit in anything nefarious, as far as I can tell.
Epstein used DB to wire the $350k payment to a victim after several Miami Herald articles.
Epstein moved millions through various DB accounts, some of it going through at least one Russian bank.
DB managers raised concerns after seeing the Miami Herald articles and actually shut down several of Epstein's
accounts.
He had dozens of accounts with many beneficiaries who had authority to make disbursements, one of whom was
Ghislaine Maxwell. Her account was named "Butterfly," or something like that.
He conducted hundreds of millions of dollars of business on the foreign exchange markets using DB in the last year.
Thanks.
EFTA00021050


c1: EFTA00021396
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021396.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: Re: subpoena of
Date: Tue, 30 Jul 2019 15:05:47 +0000
I will call you then. Thanks.
Sent from my iPhone
On Jul 30, 2019, at 10:40 AM,
wrote:
Sure - you can call
or let us know if there's a number we can reach you at if you prefer we call you.
thanks,
From:
Sent: Tuesday, July 30, 2019 07:16
To:
Cc:
Subject: Re: subpoena of
Would 4:30 work?
Sent from my iPhone
On Jul 29, 2019, at 11:22 PM,
wrote:
Is there a good time for you tomorrow afternoon, 2:00 or later?
thanks,
From:
Sent: Monday, July 29, 2019 10:25
To:
Cc:
Subject: RE: subpoena of
Let me know when would be a good time for a call to further discuss the
subpoena.
Thanks,
EFTA00021396

=== Page 2 ===
From:
Sent: Tuesday, July 16, 2019 12:53 PM
To:
Cc:
L
Subject: RE: subpoena of
Following up on our phone conversation earlier today, thank you for being in touch and advising us of your
representation of
in connection with
receipt of a grand jury subpoena. So you have contact info
for our full team, we're all reachable anytime at the copied emails or by phone at:
As we briefly discussed, the documentary materials we are seeking from
in the first instance are any
flight manifests, flight plans, or other documents reflecting passengers and/or travel records, dating back to 2000. And
we would like to hear from
about
observations, if any, of young women or girls on flights, as well as any
discussions with Mr. Epstein about his relationships with young women or girls, or his legal issues relating to those
relationships. We are also interested to know the identities of Epstein's employees and staff whom
is
aware of, current and previous.
As I mentioned on the phone, given the prospect of attorney proffer information and/or a possible voluntary interview,
we are prepared to hold in abeyance the current subpoena return date of July 22, 2019.
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00021397


c1: EFTA00022524
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022524.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: 7/15 status report
(
)
Date: Thu, 18 Jul 2019 02:30:33 +0000
Because the unredacted
search warrant materials and July 15 status report will be filed at 11 and the
Epstein bail hearing is at 11:30, a couple of reporters have asked if I can tell them how many pages the status
report is, so they have a sense of how much they'll have to read between 11 and 11:30 if they're covering both.
EFTA00022524


c1: EFTA00021569
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021569.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
"Mark S. Cohen"
Cc:
Subject: RE: SDNY investigation (re: Epstein)
Date: Tue, 16 Jul 2019 18:09:24 +0000
Thanks,
That works for us. We'll see you at 5pm.
From:
Sent: Tuesday, July 16, 2019 2:07 PM
To: Christian Everdell; Mark S. Cohen
Cc:
)
Subject: RE: SDNY investigation (re: Epstein)
Chris,
Sorry to have missed your call, and I hope you and Mark are still able to get this - we can meet at 5:00 today, if that's
convenient for you both, and I'm happy to ask the CSOs to allow you to retain your phones. Please let us know if that
works, and we'll put it on our calendars.
thanks,
From: Christian Everdell
Sent: Tuesday, July 16, 2019 13:38
To:
>; Mark S. Cohen
Cc:
Subject: RE: SDNY investigation (re: Epstein)
Hi
-
I just tried your desk. Do we have a time this afternoon when you can meet? Let us know as soon as you can because
Mark will be in court soon and will not have his phone.
Also, would you mind asking the CSOs to allow us to bring our phones into the building? Let me know if that's a problem.
Thanks,
Chris
From:
Sent: Monday, July 15, 2019 7:57 PM
To: Christian Everdell; Mark S. Cohen
Cc:
)
Subject: RE: SDNY investigation (re: Epstein)
Chris, Mark,
EFTA00021569

=== Page 2 ===
Following up on my very brief conversation with Chris earlier this afternoon, and the voicemail you left earlier, thanks for
getting in touch regarding your representation of Ms. Maxwell. I understand you'll be in our neighborhood tomorrow
afternoon; we can make ourselves available to meet, but will that have been enough time for you to speak with your
client? Let us know what you think would be best to proceed, and we'll figure out next steps.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00021570


c1: EFTA00020799
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020799.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: Re:
meeting / new subpoena
Date: Mon, 15 Jul 2019 10:31:12 +0000
Importance: Normal
Nothing other than Tuesday morning, thanks.
On Jul 14, 2019, at 10:53 PM,
)
wrote:
just bumping this - any conflicts for you this week (other than Tuesday morning)?
From:
Sent: Saturday, July 13, 2019 17:18
To:
Cc:
Subject: Re:
meeting / new subpoena
I can make any time that works for the agents work. Thanks.
Sent from my iPhone
On Jul 13, 2019, at 5:15 PM,
wrote:
How about y'all
is occupied Tuesday morning but that's bad for the agents anyway; any other conflicts? Once
we know scheduling l'll email
to try to set up a time.
From:
Sent: Saturday, July 13, 2019 17:14
To:
is
Cc:
is
Subject: RE:
sisters meeting / new subpoena
Got it, perfect.
From:
(NY) (FBI)
Sent: Saturday, July 13, 2019 17:13
To:
is
Cc:
is
Subject: RE:
meeting / new subpoena
We will reach out to him.
As for this week, Tuesday during the day would not be great, but evening would be fine. Wednesday morning and
Thursday anytime is good. Monday after the hearing is good. Preferably, we'd like to avoid Friday.
EFTA00020799

=== Page 2 ===
On Jul 13, 2019 4:48 PM,
)"
wrote:
Two quick things - first, we'd like to set up a meeting for this coming week with
who previously
worked with Epstein, and possibly
as well. I don't believe they were underage victims of Epstein,
but they apparently have useful information and also may have been victims of coercive sexual encounters with
Epstein and/or his associates. Any days or times this week you would *not* be available for that?
Separately, there have now been two stories in the Times where a publicist, Mr. R. Couri Hay, has been referenced
as having recently been told by Epstein about Epstein's prior conduct. Can we please try to contact him? Can issue
him a subpoena, attached, if he doesn't want to be interviewed informally.
(Here's the latest reference to him: "Just three months ago, as federal prosecutors were closing in with new
charges, Mr. Epstein had a conversation with R. Couri Hay, a publicist, about continuing to improve his
reputation. Mr. Epstein asserted that what he was convicted of did not constitute pedophilia, said Mr. Hay,
who declined to represent him. The girls he had sex with were "tweens and teens," Mr. Epstein told him.")
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00020800


c1: EFTA00020909
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020909.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Voice Message Attached from
-
Date: Fri, 15 Nov 2019 21:14:47 +0000
Embedded: two_communications_from_individuals_who_may_have_JE_information.msg
Note that this is the same individual who called us in October (see attached email and associated voicemail), so I
imagine it already has either been addressed or is in the queue.
Original Message
From:
)
Sent: Friday, November 15, 2019 14:44
To:
Cc:
i
Subject: FW: Voice Message Attached from
-
,
The attached voicemail is from someone who claims to have information pertinent to our ongoing investigation.
Per our policy of passing along civilian information, I'm forwarding so that the FBI can handle as it sees fit.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Original Message
From: postmaster@voip.usa.doj.gov <postmaster@voip.usa.doj.gov>
Sent: Friday, November 15, 2019 2:29 PM
To:
Cc:
Subject: Voice Message Attached from
Time: Nov 15, 2019 2:28:31 PM
Click attachment to listen to Voice Message
EFTA00020909


c1: EFTA00023318
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023318.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Fwd: Follow-up
Date: Fri, 16 Oct 2020 20:33:09 +0000
Hi
,
Do you recall where you left things with this firm about
?
Thanks.
Sent from my iPhone
Begin forwarded message:
From:
Date:
21, 2020 at 9:18:10 PM GMT+
To: Colleen
Cc: Teri Gibbs
Subject: RE: Follow-up
Colleen,
Per our discussion - the protective order is attached, as are the Court's opinion on this as well as the Government's strong
argument on these issues.
thanks,
From: Colleen
Sent: Fridav
21 2020 14:07
To:
Cc: Teri Gibbs
Subject: Re: Follow-up
Thank you,
I will give you a call today.
Colleen
On Thu, Aug 20, 2020 at 3:05 PM
wrote:
Colleen,
The times were EST, but I can do 1:00 p.m. PST (4:00 p.m. EST) tomorrow, thanks. We can use the following dial-in:
conference ID: 698244
thanks,
From: Colleen
Sent: Thursday,
20, 2020 15:30
To:
EFTA00023318

=== Page 2 ===
Cc: Teri Gibbs
Subject: Re: Follow-up
I am available tomorrow after 1pm (PST). Are your proposed times in PST or EST?
Colleen
On Thu, Aug 20, 2020 at 9:55 AM
wrote:
Colleen,
I don't, I'm sorry - I'm unfortunately totally booked today. I could talk at 12:30 or 1:00 tomorrow, or sometime
early next week, if that's better for you?
thanks,
From: Colleen
Sent: Thursday,
20, 2020 12:08
To:
Cc: Teri Gibbs
Subject: Re: Follow-up
Do you have time to speak today around 1pm (PST)? Please let me know.
Colleen
On Wed, Aug 19, 2020 at 6:35 PM
wrote:
Colleen,
Following up on the below - please let us know? Thanks very much.
From:
Sent: Tuesday,
11, 2020 18:03
To: Colleen
Cc: Teri Gibbs
Subject: RE: Follow-up
Colleen,
We are happy to speak with you - we had only followed up because we were under the impression she was
interested in speaking with us. We certainly can discuss issues of witness safety and confidentiality, but we also
are not looking to pressure anyone, at all. Please let us know if it makes sense to chat, and if so, what time ranges
would work for you later this week or next.
thanks.
From: Colleen
Sent: Monday,
10. 2020 19:17
To:
Cc: Teri Gibbs
Subject: Re: Follow-up
Do you have any time to speak this week? My client is deeply concerned about her personal safety and
wishes to maintain her anonymity.
Best,
Colleen
On Thu. Aug 6, 2020 at 10:26 AM
wrote:
Colleen,
EFTA00023319

=== Page 3 ===
We wanted to follow up on this from last month. Please let us know? (And obviously we're past late July now,
but we could look at dates and times for an interview this month.)
thanks,
From:
Sent: Wednesday, July 08, 2020 17:30
To: Colleen
Cc: Teri Gibbs
Subject: RE: Follow-up
Colleen,
Thanks very much for being in touch, and we would like to speak with Ms.
As a threshold
question, would it be possible for you to share with us the documents from and email correspondence with
Maxwell referenced in your email below? And is there a good date or dates later in July that would work for a
phone or videoconference interview?
thanks again,
From: Colleen
Sent: Monday, July 06, 2020 15:20
To:
Cc: Teri Gibbs
Subject
Follow-up
We wanted to follow up on our prior email and offer to speak with our client
As stated earlier, Ms.
worked for Ms. Maxwell (and, by extension, Jeffrey
Epstein).
I confirmed with our client that she is willing to speak with you and wants to fully cooperate with the
criminal investigation/action pending against Ms. Maxwell. She could be a valuable witness for you.
Please let us know if you would like to speak with our client. We are happy to facilitate this
conversation.
Best,
Colleen
On Wed, Jan 29, 2020 at 12:57 PM
wrote:
Received, thanks very much.
From: Teri Gibbs
Sent: Tuesday, January 28, 2020 19:08
To:
Cc:
Subject: Re: Follow-up
Hi
As we discussed last week, our client,
has in her possession documents
from and email correspondence with Ghislaine Maxwell. Thus far, we have received authorization
to share the list of office numbers Ms.
used during her employment with Ghislaine
Maxwell from 2003-2007. Please see attached.
Please let us know if you have any questions.
Best,
Teri
On Wed, Jan 22, 2020 at 1:48 PM
wrote:
Will do, speak with you then. Thanks.
EFTA00023320

=== Page 4 ===
From: Teri Gibbs
Sent: Wednesday, January 22, 2020 16:44
To:
Cc.
Colleen
Subject: Re: Follow-up
Great. Tomorrow at 12PM PST/3PM EST works. Please call our conference line at
Best,
Teri
On Wed, Jan 22, 2020 at 1:39 PM
wrote:
Teri,
I can give you a call at 3:00 p.m. tomorrow (Thursday). Please let me know what number is best to
reach you at, and I'll plan to call you then.
thanks,
From: Teri Gibbs
Sent: Tuesday, January 21, 2020 20:15
To:
Cc:
>; Colleen
Subject: Re: Follow-up
Wonderful,
I am available tomorrow through Friday from 1PM-3PM EST. Please let me
know what time works best for you.
Best,
Teri
On Tue, Jan 21, 2020 at 5:06 PM
)
wrote:
Teri,
We would be happy to set up a call to speak with you and receive the new information-please let us
know a few times this week that would work for you.
thanks,
From: Teri Gibbs
Sent: Tuesdav. January 21. 2020 18:50
To:
Cc:
; Colleen
Subject: Re: Follow-up
Hi
I am following up regarding our clients,
and
We
have more information from Ms.
that may be important to your investigation.
Please let us know if you would like to speak with us over the phone or set up interviews
with either of them.
Best regards,
Teri
On Mon, Jan 6, 2020 at 1:12 PM Teri Gibbs
wrote:
Great. Please call our conference line at
You should receive an invitation
EFTA00023321

=== Page 5 ===
in a few moments from UberConference. You will not need a sign-in pin.
Looking forward to our call on Wednesday at 12:30PM PST.
Best,
Teri
On Mon. Jan 6, 2020 at 1:07 PM
wrote:
Yes, we can do Wednesday at 12:30 p.m. PST (3:30 p.m. EST). Please let us know the best
number to reach you at, and we'll call you then.
From: Teri Gibbs
Sent: Monday, January 06, 2020 12:15
To:
Cc:
Subject: Re: Witness re Prince
We have a last-minute mediation that is now scheduled for Tuesday. Are you available
on Wednesday between 10-11AM PST and 12-2PM PST or Thursday at any time
between 9 AM-5PM PST?
Thank you in advance for your flexibility.
Best,
Teri
On Fri, Jan 3, 2020 at 6:04 PM
wrote:
Teri,
No problem, and thanks for getting back to us. We could do a call on Tuesday the 7th at
11:00 a.m. PST (2:00 p.m. EST). Please let us know the best number to reach you at, and
we'll give you a call then.
thanks,
From: Teri Gibbs
Sent: Thursday, January 02. 2020 19:26
To:
Cc:
Subject: Re: Witness re Prince
Hi
Thank you for your response. I apologize for the delay. I hope you had a wonderful
holiday. Attorney Lisa Bloom and I are available at the following times for a phone
or video conference:
Tuesday (1/7) between 10AM-1PM PST
Wednesday (1/8) between 10-11AM PST and 12-2PM PST
Please let me know if any of these times work for you.
Best regards,
Teri
On Fri, Dec 20, 2019 at 9:55 AM
wrote:
Teri,
Thanks for being in touch. In the first instance, before we would request an interview
directly, it would be helpful for us to get a full attorney proffer from you about what the
EFTA00023322

=== Page 6 ===
client's information is, what you expect she would convey in an interview, any relevant
documentary or other corroborating materials, etc. That way we can make sure we're not
re-victimizing any individual unnecessarily, and be efficient with any necessary follow-up
interview of the individual him- or herself. Please let us know when a good time would be
for an attorney proffer? And we can figure out scheduling.
thanks very much,
From: Teri Gibbs
Sent: Thursday, December 19. 2019 20:01
To:
Cc:
Subject: Witness re Prince
Hi
We have a client who witnessed Prince
interactions with
I would like to set up a phone or video interview with the appropriate
party to allow our client to make a statement. Please let me know how to proceed.
Best regards,
Teri Gibbs
Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by
law. If you received this e-mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please
notify us immediately of the error by return e-mail and please delete this message and any and all duplicates of this message from your
system. Thank you in advance for your cooperation.
IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S.
tax advice contained in this communication (including any attachments) is not intended 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.
Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law.
If you received this e-mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us
immediately of the error by return e-mail and please delete this message and any and all duplicates of this message from your system. Thank
you in advance for your cooperation.
IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax
advice contained in this communication (including any attachments) is not intended 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.
Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If
you received this e-mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us
immediately of the error by return e-mail and please delete this message and any and all duplicates of this message from your system. Thank you in
advance for your cooperation.
IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax
advice contained in this communication (including any attachments) is not intended 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.
Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you
received this e-mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of
the error by return e-mail and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your
cooperation.
IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice
contained in this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (i) avoiding penalties
EFTA00023323

=== Page 7 ===
under the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein.
Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you
received this e-mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the
error by return e-mail and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your
cooperation.
IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice
contained in this communication (including any attachments) is not intended 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.
Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received
this e-mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by
return e-mail and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation.
IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained
in this communication (including any attachments) is not intended 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.
Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this e-
mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e-mail
and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation.
IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in
this communication (including any attachments) is not intended 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.
Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this e-
mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e-mail and
please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation.
IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in this
communication (including any attachments) is not intended 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.
Colleen M.
Esq.
To protect the health and safety of our clients and employees, and in compliance with local orders,
The Bloom Firm has closed its physical offices until further notice. We are fully operational
remotely. Attorneys and staff continue to be available via videoconference, email, telephone, and fax.
Please do not send mail or attempt service at our physical office.
This message is for the designated recipient only and may contain privileged, proprietary, or
otherwise private information. If you have received it in error, please notify the sender immediately
and delete the original. Any other use of the email by you is prohibited.
Colleen M.
Esq.
To protect the health and safety of our clients and employees, and in compliance with local orders, The
Bloom Firm has closed its physical offices until further notice. We are fully operational remotely.
Attorneys and staff continue to be available via videoconference, email, telephone, and fax. Please do
not send mail or attempt service at our physical office.
This message is for the designated recipient only and may contain privileged, proprietary, or otherwise
private information. If you have received it in error, please notify the sender immediately and delete the
original. Any other use of the email by you is prohibited.
EFTA00023324

=== Page 8 ===
Colleen M.
, Esq.
To protect the health and safety of our clients and employees, and in compliance with local orders, The
Bloom Firm has closed its physical offices until further notice. We are fully operational remotely.
Attorneys and staff continue to be available via videoconference, email, telephone, and fax. Please do not
send mail or attempt service at our physical office.
This message is for the designated recipient only and may contain privileged, proprietary, or otherwise
private information. If you have received it in error, please notify the sender immediately and delete the
original. Any other use of the email by you is prohibited.
Colleen M.
,
Esq.
To protect the health and safety of our clients and employees, and in compliance with local orders, The
Bloom Firm has closed its physical offices until further notice. We are fully operational remotely.
Attorneys and staff continue to be available via videoconference, email, telephone, and fax. Please do not
send mail or attempt service at our physical office.
This message is for the designated recipient only and may contain privileged, proprietary, or otherwise
private information. If you have received it in error, please notify the sender immediately and delete the
original. Any other use of the email by you is prohibited.
Colleen M.
, Esq.
To protect the health and safety of our clients and employees, and in compliance with local orders, The Bloom
Firm has closed its physical offices until further notice. We are fully operational remotely. Attorneys and staff
continue to be available via videoconference, email, telephone, and fax. Please do not send mail or attempt
service at our physical office.
This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private
information. If you have received it in error, please notify the sender immediately and delete the original. Any
other use of the email by you is prohibited.
<2020-07-31, GM, signed protective order (docketed).pdf.
<2020-07-31, GM, memorandum & order granting government motion.pdf>
<2020-07-28, government letter re protective order (docketed).pdf>
EFTA00023325


c1: EFTA00021174
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021174.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: "Strauss, Audrey (USANYS)"
Cc:
Subject: GM Press Materials
Date: Fri, 26 Jun 2020 22:45:02 +0000
Attachments: Ghislaine_Maxwell_Press_Remarks_v3.docx;Maxwell_possible_QA_v2.docx
Audrey - We've put together some draft remarks and a Q&A for a potential press conference next week. The team is also
working with the press office to put together a visual. Happy to discuss further after you've had a chance to review.
Thanks,
EFTA00021174


c1: EFTA00022061
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022061.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
U.S. Department of Justice
Criminal Division
Office of International Affairs
United States Embassy, London
April 7, 2020
Via Email
Philomena Creffield, Esq.
United Kingdom Central Authority
Home Office
London, United Kingdom
Re:
Request for Assistance in the Matter of Material Witness PA:
DOJ No. CRM-182-73090
Dear Ms. Creffield:
Enclosed please find a request for assistance concerning the above-referenced matter.
The United States Attorney for the Southern District of New York and the Federal Bureau of
Investigation are conducting an investigation into sex trafficking and other related crimes. This request
seeks the interview of a witness in the United Kingdom as well as relevant documents within that
witness's custody and control. U.S authorities request confidential treatment of this request as well as
prompt handling.
Your assistance in this matter is greatly appreciated. Please do not hesitate to contact me at
if you have any questions or if I can otherwise be of assistance.
Sincerely,
Director
By:
U.S. Department of Justice Attaché
Enclosure
cc. Philip Newman, UKCA
Margaret Browne, UKCA
Julian Gibbs, UKCA
SBU -LAW ENFORCEMENT
EFTA00022061


c1: EFTA00023240
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023240.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 10643456-2(1) prepared by a travel arranger is pending your review
Date: Thu, 10 Oct 2019 22:43:18 +0000
Importance: Normal
Dear
Final voucher
has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID:
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews
Destination: Santa Monica, CA, United States
Dates: 2019-09-17 - 2019-09-20
Current status: Pending Voucher Approval
Voucher total expenses: 2145.79
Estimated trip cost: 2489.21
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0012
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00023240


c1: EFTA00020851
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020851.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Google
Google
Google
Google
Google
Google
Our Tean
ROMAN
Repo X
Hi adria
[ServeM
12 H
+
i
https://www.cyber.gov.au/reporting/#/?form=pshop
III\
Q
?
is
ACSC
Australian Government
Australian
Cyber Security
Australian Signals Directorate
Centre
If there is an immediate threat to life or risk of harm please call 000
Thank you for your report
Based on the information you have provided; someone may have committed fraud against you.
The reference number for this report is: CIRS-20190723-30
Your matter has been referred to QLD Police.
Advice to help you reduce the consequences of the issue you are experiencing now:
Contact your bank immediately if you have sent money or if you think you have provided confidential banking information to someone online.
Report the issue to the financial institution who owns the fraudulent bank details you were sent.
Change vour email address, passwords and account usernames.
https://www.cyber.gov.au/reporting/#
9:22 AM
Type here to search
W
D"))
ENG
23/07/2019
1
EFTA00020851


c1: EFTA00023008
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023008.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: BOBBI C STERNHEIM
To:
)"
)"
(USANYS)"
,
)"
Cc: Christian Everdell
>, , Laura Menninger
>, , Jeff Pagliuca
Subject: U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Mon, 26 Apr 2021 23:05:05 +0000
Attachments: Letter_to_Court_re-_42421.pdf; ATT00001.htm
Good evening-
Attached please find a courtesy copy of today's ECF filing.
Regards-
Bobbi
EFTA00023008


c1: EFTA00021173
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021173.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Hi everyone.
Last week had some very notable achievements:
a $678 million civil settlement with Novartis for years of paying illicit
kickbacks;
and also the arrest of GELANE Maxwell, a co-conspirator of Jeffrey
Epstein.
I cheer both of those the teams that worked so hard to bring those
worthy cases.
Of course, some of our most important achievements happen out of
the spotlight, and I want to celebrate everyone who has:
taken on new gun cases to combat our District's recent rise in
violence;
chipped in to skillfully handle the increase in FOIA litigation; and
diligently prepared thoughtful responses to compassionate
release motions.
And many thanks to all of our AUSAs, paralegals, and staff who are
shouldering the work of the Office every day.
We miss seeing you, but even when you are out of sight, we know we
are lucky to have you.
Stay safe and keep up the great work.
EFTA00021173


c1: EFTA00023181
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023181.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "Thrapp, Jacklyn"
To:
"
:
Subject: [EXTERNAL] Press Question (Ghislaine Maxwell Trial)
Date: Fri, 22 Oct 2021 15:18:14 +0000
Inline-Images: image001.jpg; image002.jpg
Hello,
I'm a reporter for the National Enquirer covering the trial of Ghislaine Maxwell. I heard
won't be called to
the stand during the trial.
Is this true? And if so, can you elaborate on why, if possible.
Thanks
JACKI THRAPP
REPORTER
THE NATIONAL ENQUIRER
EFTA00023181


c1: EFTA00021512
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021512.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 9:08-cv-80736-KAM Document 468 Entered on FLSD Docket 07/24/2019 Page 1 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80736-CIV-MARRA
JANE DOE 1 AND JANE DOE 2,
Petitioners,
vs
UNITED STATES OF AMERICA,
Respondent.
/
JEFFREY EPSTEIN,
Limited Intervenor.
/
LIMITED INTERVENOR JEFFREY EPSTEIN'S MOTION FOR
LEAVE TO FILE A REPLY ON OR BEFORE AUGUST 22, 2019
Limited Intervenor JEFFREY EPSTEIN, through undersigned counsel, respectfully
moves the Court for an Order granting him leave to file a reply to Petitioners' Reply to
Intervenor Epstein's Brief in Opposition to Proposed Remedies (DE 466), on or before
August 22, 2019.
1. On May 13, 2019, this Court entered an Order (DE 454) setting a briefing
schedule for the Petitioners to file their initial submission on proposed remedies,
the government and Mr. Epstein to file a response, and for Petitioners to file a
reply.
2. Petitioners filed their initial submission on May 23, 2019 (DE 458), the
government filed its response on June 24, 2019 (DE 462), Mr. Epstein filed his
1
EFTA00021512

=== Page 2 ===
Case 9:08-cv-80736-KAM Document 468 Entered on FLSD Docket 07/24/2019 Page 2 of 5
response on July 8, 2019 (DE 463), and Petitioners filed their replies to the
government and Mr. Epstein's submissions on July 9 & 23, 2019, respectively
(DE 464; DE 466).
3. Petitioners' reply to Mr. Epstein's Brief (DE 466) is 65 pages long. In that reply,
among other things, Petitioners' counsel:
a)
raise an issue, for the first time, about the binding nature of the NPA
on other districts, which is not relevant to the issues before the Court and has
never been briefed before this Court (DE 466:3-5);
b)
rely on sealed documents that Mr. Epstein has never seen (DE 466:19-
23, 48), to argue, for the first time at the remedy phase, that a purported
conflict of interest that allegedly plagued one of Mr. Epstein's lawyers
somehow requires partial rescission of the NPA, despite that it is a criminal
defendant's sixth amendment right - not an alleged victim's - to insist that
the defendant be represented by conflict-free counsel;
c)
rely heavily on the case of San Pedro V. United States, 79 f.3d 1065,
1068 (11th Cir. 1999) (DE 466:24-25, 38), an easily distinguished case not
cited by Petitioners in their initial submission (DE 458) that Mr. Epstein has
never had an opportunity to address;
d)
adopt positions that are different from their initial submission,
compare DE 466:27 (now defining "partial rescission" as "rescission of the
immunity provisions for only those victims who seek rescission") with DE
2
EFTA00021513

=== Page 3 ===
Case 9:08-cv-80736-KAM Document 468 Entered on FLSD Docket 07/24/2019 Page 3 of 5
458:4, 5, 13 (not limiting the request for partial rescission to only
Petitioners);
e)
accuse Mr. Epstein's counsel of "misleading briefing" in the section
on the general releases in the Settlement Agreements (DE 466:42), for using
ellipses in place of the words "compensatory or punitive damages," even
though the general releases preclude all actions or claims in equity against
Mr. Epstein which, by definition, involve injunctive relief and do not involve
compensatory or punitive damages;
f)
contend that the Court's Order (DE 454:2) permitting the filing of
affidavits and declarations at the remedy phase undermines Mr. Epstein's
procedural due process argument (DE 466:7-10), a contention to which Mr.
Epstein has never had an opportunity to respond;
g)
mischaracterize Mr. Epstein's discussion of the Walker case (DE
464:55-56), inasmuch as it was not the Seventh Circuit's ruling in Walker
that Mr. Epstein claimed was "entirely confused," but rather the Petitioners'
discussion of it in their initial submission. (DE 463:25); and
h)
advocate for a remarkably primitive view of the constitutional role of
defense lawyers, labeling as "bad faith" defense counsel's denial of their
presumptively innocent client's guilt (DE 466:21), and claiming that they are
"instigators" of government violations as a result of demands they made,
without coercion or bribery, during the normal back and forth of plea
negotiations.
3
EFTA00021514

=== Page 4 ===
Case 9:08-cv-80736-KAM Document 468 Entered on FLSD Docket 07/24/2019 Page 4 of 5
4. Given the new arguments, changed position, and the stakes involved, Mr.
Epstein respectfully requests leave to file a reply to Petitioners' recent
submission on or before August 22, 2019.
5. Mr. Epstein is currently detained at the Metropolitan Correctional Center in
Manhattan. As a result, it is more time-consuming to review drafts of a
submission with him before the submission is filed.
6. Counsel for Mr. Epstein communicated with AUSA Jill E. Steinberg, counsel
for the government, who advises that the government does not object. Counsel
for Mr. Epstein also communicated with Paul Cassell, counsel for the
Petitioners, who advises that the Petitioners will likely object.
Respectfully submitted,
/s/Roy Black
Roy Black, Esq.
(FL Bar No. 126088)
Jackie Perczek, Esq.
(FL Bar No. 42201)
BLACK, SREBNICK, KORNSPAN & STUMPF, P.A.
201 South Biscayne Boulevard, Suite 1300
Miami, Florida 33131
Tele: (305)371-6421
Fax: (305) 358-2006
E-Mail: rblack@royblack.com
E-Mail: jperczek@royblack.com
4
EFTA00021515

=== Page 5 ===
Case 9:08-cv-80736-KAM Document 468 Entered on FLSD Docket 07/24/2019 Page 5 of 5
/s/Martin G. Weinberg
Martin G. Weinberg, Esq.
MARTIN G. WEINBERG, P.C.
(MA Bar No. 519480)
20 Park Plaza, Suite 1000
Boston, Massachusetts 02116
Tele: (617) 227-3700
Fax: (617) 338-9538
E-Mail: owlmgw@att.net
/s/ Scott A. Srebnick
Scott A. Srebnick, Esq.
(FL Bar No 872910)
SCOTT A. SREBNICK, P.A.
201 South Biscayne Boulevard, Suite 1210
Miami, Florida 33131
Tele: (305) 285-9019
Fax: (305) 377-9937
E-Mail: scott@srebnicklaw.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 24th day of July 2019, I electronically filed the
foregoing document with the Clerk of the Court using CM/ECF. According to the Court's
website, counsel for all parties and intervenors are able to receive notice via the CM/ECF
system.
/s/Jackie Perczek
Jackie Perczek
5
EFTA00021516


c1: EFTA00022407
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022407.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UBS Financial Services Inc.
UBS
299 Park Avenue
25th Floor
Resource Management Account
New York NY 10171-0002
May 2016
CNP7005580141 0516 Y1 0
GHISLAINE MAXWELL
116 E 65TH STREET
NEW YORK NY 10065-7007
Account name: GHISLAINE MAXWELL
Friendly account name: Ind:Cash/Saving
Account number:
Your Financial Advisor:
SCOTT STACKMAN/LYLE CASRIEL
Phone: 212-821-7000/800-308-3140
Questions about your statement?
Call your Financial Advisor or the
Value of your account
RMA ResourceLine at 800-RMA-1000,
on April 29 ($)
on May 31 ($)
account 029023575
Your assets
18,955,082.77
16,475,002.07
Visit our website:
Your liabilities
0.00
0.00
www.ubs.com/financialservices
Value of your account
$18,955,082.77
$16,475,002.07
Sources of your account growth
Tracking the value of your account
during 2016
Value of your account
$ Millions
at year end 2015
$6,144,731.58
19.0
Net deposits and
16.5
withdrawals
$10,307,208.06
Your investment return:
Dividend and
interest income
$19,555.08
6.1
4.2
Change in
market value
$3,507.35
Value of your account
Dec 2014
Dec 2015
Apr 2016
May 2016
on May 31, 2016
$16,475,002.07
Member SIPC
CNP70008005580141 NP7000191995 00005 0516 030575004 Y123575550 000000
Page 1 of 8
EFTA00022407

=== Page 2 ===
UBS
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
Friendly account name Ind:
May 2016
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Your account balance sheet
Summary of your assets
Value on
Percentage of
May 31 ($)
your account
A
Cash and money balances
0.00
0.00%
Your current asset allocation
B
Cash alternatives
12,955,415.31
78.64%
C
Equities
0.00
0.00%
D
D
Fixed income
3,519,586.76
21.36%
E
Non-traditional
0.00
0.00%
F
Commodities
0.00
0.00%
G
Other
0.00
0.00%
Total assets
$16,475,002.07
100.00%
B
Value of your account
$16,475,002.07
Eye on the markets
Percentage change
Index
May 2016
Year to date
S&P 500
1.80%
3.57%
Russell 3000
1.79%
3.41%
MSCI- Europe, Australia & Far East
-0.78%
-0.75%
Barclays Capital U.S. Aggregate Bond Index
0.03%
3.45%
Interest rates on May 31, 2016
3-month Treasury bills: 0.34%
One-month LIBOR: 0.47%
CNP70008005580142 NP7000191995 00005 0516 030575004 Y123575550 000000
Page 2 of 8
EFTA00022408

=== Page 3 ===
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
UBS
Friendly account name: Ind:Cash/Saving
May 2016
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Change in the value of your account
Summary of gains and losses
May 2016 ($)
Year to date ($)
Values reported below exclude products for which gains and losses are not classified.
Opening account value
$18,955,082.77
$6,144,731.58
Realized gains and losses
Unrealized
May 2016 ($)
Year to date ($)
Deposits, including investments
gains and losses ($)
transferred in
63,983.30
14,609,549.67
Short term
0.00
0.00
14.28
Withdrawals and fees,
including investments transferred
out
-2,551,221.67
-4,302,341.61
Cash activity summary
Dividend and interest income
7,157.68
19,555.08
See Account activity this month for details. Balances in your Sweep Options are included in the opening and
closing balances value. FDIC insurance applies only to deposits at UBS Bank USA, not to deposits at UBS AG,
Change in market value
-0.01
3,507.35
Stamford Branch or bank deposits placed through the UBS International Deposit Account program. SIPC
protection applies to money market sweep fund holdings but not bank deposits. See Important information
Closing account value
$16,475,002.07
about your statement on the last two pages of this document for details.
$16,475,002.07
May 2016 ($)
Year to date ($)
Dividend and interest income earned
Opening balances
$0.00
$2,010,294.62
Additions
For purposes of this statement, taxability of interest and dividend income has been determined from a US
Deposits and other funds credited
63,983.30
14,609,549.67
tax reporting perspective. Based upon the residence of the account holder, account type, or product type,
some interest and/or dividend payments may not be subject to United States (US) and/or Puerto Rico (PR)
Dividend and interest income
7,157.68
19,555.08
income taxes. The client monthly statement is not intended to be used and cannot be relied upon for tax
purposes. Clients should refer to the applicable tax reporting forms they receive from UBS annually, such as
Proceeds from investment transactions
2,550,221.67
4,254,350.21
the Forms 1099 and the Forms 480, for tax reporting information. It is the practice of UBS to file the
applicable tax reporting forms with the US Internal Revenue Service and PR Treasury Department, and in
Total additions
$2,621,362.65
such forms accurately classify dividends and/or interest as tax exempt or taxable income. Please consult your
$18,883,454.96
individual tax preparer.
Subtractions
May 2016 ($)
Year to date ($)
Checks and bill payments
-2,500,000.00
-2,500,000.00
Taxable dividends
7,142.12
17,344.56
Other funds debited
-51,221.67
-1,802,341.61
Taxable interest
15.56
36.79
Funds withdrawn for investments
bought
-70,140.98
-16,591,407.97
Total current year
$7,157.68
$17,381.35
Total subtractions
-$2,621,362.65
-$20,893,749.58
Prior year adjustment
0.00
2,173.73
Net cash flow
$0.00
Total dividend & interest
-$2,010,294.62
$7,157.68
$19,555.08
Closing balances
$0.00
$0.00
CNP70008005580143 NP7000191995 00005 0516 030575004 Y123575550 000000
Page 3 of 8
EFTA00022409

=== Page 4 ===
UBS
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
Friendly account name: Ind:
SCOTT STACKMAN/LYLE CASRIEL
May 2016
Account number:
212-821-7000/800-308-3140
UBS Bank USA Deposit Account APY
Your account instructions
Interest period Apr 7 - May 5
Your account cost basis default closing method is FIFO, First In, First Out.
Opening UBS Bank USA Deposit balance Apr 7
$0.11
Closing UBS Bank USA Deposit balance May 5
$1,390.79
Number of days in interest period
29
Average daily balance
$34,626.87
Interest earned
$0.28
Annual percentage yield earned
0.01%
UBS AG Deposit Account APY
Interest period Apr 7 - May 5
Opening UBS AG Deposit balance Apr 7
$0.00
Closing UBS AG Deposit balance May 5
$0.00
Number of days in interest period
29
Average daily balance
$1,923,392.62
Interest earned
$15.28
Annual percentage yield earned
0.01%
Your investment objectives:
You have identified the following investment objectives for this account. If you have questions
about these objectives, disagree with them, or wish to change them, please contact your
Financial Advisor or Branch Manager. You can find a full description of the alternative
investment objectives in Important information about your statement at the end of this
document
Your return objective:
Current income & capital appreciation
Your risk profile:
Primary - Moderate
Investment eligibility consideration - None selected
CNP70008005580144 NP7000191995 00005 0516 030575004 Y123575550 000000
Page 4 of 8
EFTA00022410

=== Page 5 ===
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
UBS
Friendly account name:Ind:Cash/Saving
May 2016
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Your assets
Some prices, income and current values shown may be approximate. As a result, gains and losses may not
be accurately reflected. See Important information about your statement at the end of this document for
more information
Cash alternatives
Money market funds
Money market funds are neither insured nor guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although money market funds seek to preserve the value of your investment at $1.00 per
share, it is possible to lose money by investing in these funds.
Total reinvested is the total of all reinvested dividends It does not include any cash dividends. It is not a tax
Unrealized (tax) gain or loss is the difference between the current value and the cost basis and would
lot for the purposes of determining holding periods or cost basis The shares you receive each time you
generally be your taxable gain or loss if the security was sold on this date. The unrealized (tax) gain or loss may
reinvest dividends become a separate tax lot.
need to be adjusted for return of capital payments in order to determine the realized gain or loss for tax
Cost basis is the total purchase cost of the security, including reinvested dividends. The cost basis may
reporting purposes.
need to be adjusted for return of capital payments in order to determine the adjusted cost basis for tax
investment return is the current value minus the amount you invested. It does not include shares that are not
reporting purposes.
reflected on your statement, including shares that have been realized as either a gain or a loss. It also does
not include cash dividends that were not reinvested
Purchase price/
Number
Average price
Client
Cost
Price per share
Value on
Unrealized
Holding
Investment Holding
of shares
per share ($)
investment ($)
basis ($)
on May 31 ($)
May 31 ($)
gain or loss ($)
return ($) period
UBS SELECT PRIME
INSTITUTIONAL FUND
12,955,415.310
1.000
12,955,415.31
12,955,415.31
1.000
12,955,415.31
EAI: $50,526 Current yield: 0.39%
Fixed income
Mutual funds
Total reinvested is the total of all reinvested dividends. It does not include any cash dividends It is not a
Unrealized (tax) gain or loss is the difference between the current value and the cost basis and would
tax lot for the purposes of determining holding periods or cost basis. The shares you receive each time you
generally be your taxable gain or loss if the security was sold on this date. The unrealized (tax) gain or loss may
reinvest dividends become a separate tax lot.
need to be adjusted for return of capital payments in order to determine the realized gain or loss for tax
Cost basis is the total purchase cost of the security, including reinvested dividends The cost basis may
reporting purposes.
need to be adjusted for return of capital payments in order to determine the adjusted cost basis for tax
Investment return is the current value minus the amount you invested It does not include shares that are not
reporting purposes.
reflected on your statement, including shares that have been realized as either a gain or a loss. It also does not
include cash dividends that were not reinvested
Purchase price/
Number
Average price
Client
Cost
Price per share
Value on
Unrealized (tax)
Holding
Investment Holding
of shares
per share ($)
investment ($)
basis ($)
on May 31 ($)
May 31 ($)
gain or loss ($)
return ($) period
PUTNAM SHORT DURATION
INCOME FUND Y
continued next page
CNP70008005580145 NP7000191995 00005 0516 030575004 Y123575550 000000
Page 5 of 8
EFTA00022411

=== Page 6 ===
UBS
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
Friendly account name: Cash/Saving
SCOTT STACKMAN/LYLE CASRIEL
May 2016
Account number:
212-821-7000/800-308-3140
Your assets
Fixed income
Mutual funds (continued)
Purchase price/
Number
Average price
Client
Cost
Price per share
Value on
Unrealized (tax)
Investment
Holding
Holding
of shares
per share ($)
investment ($)
basis ($)
on May 31 ($)
May 31 ($)
gain or loss ($)
return ($)
period
Symbol: PSDYX
Trade date: Jul 20, 15
348,605.578
10.040
3,500,005.25
3,500,005.25
10.040
3,500,000.00
-5.25
ST
Total reinvested
1,950.873
10.029
19,567.23
10.040
19,586.76
19.53
EAI: $23,137 Current yield: 0.66%
Security total
350,556.451
10.040
3,500,005.25
3,519,572.48
3,519,586.76
14.28
19,581.51
Your total assets
Percentage of
Cost
Estimated
Unrealized
Value on May 31 ($)
your account
basis ($)
annual income ($)
gain or loss ($)
Cash alternatives
Money market funds
12,955,415.31
78.64%
12,955,415.31
50,526.00
Fixed income
Mutual funds
3,519,586.76
21.36%
3,519,572.48
23,137.00
14.28
Total
$16,475,002.07
100.00%
$16,474,987.79
$73,663.00
$14.28
Account activity this month
Date
Activity
Description
Amount ($)
Deposits and other funds credited
May 2 Transfer
JOURNAL FROM Y1 23568 GHISLAINE MAXWELL
83.75
May 2 Transfer
JOURNAL FROM Y1 23574 GHISLAINE MAXWELL
1,306.76
May 12 Transfer
JOURNAL FROM Y1 23574 GHISLAINE MAXWELL
62,592.79
Total deposits and other funds credited
$63,983.30
Date
Activity
Description
Amount ($)
Dividend and interest income
Taxable dividends
May 2 Dividend
PUTNAM SHORT DURATION INCOME FUND Y AS OF 04/29/16
2,752.43
May 31 Dividend
UBS SELECT PRIME INSTITUTIONAL FUND
4,389.69
Total taxable dividends
$7,142.12
Taxable interest
May 6 Interest
UBS AG DEPOSIT ACCOUNT AS OF 05/05/16
15.28
May 6 Interest
UBS BANK USA DEPOSIT ACCOUNT AS OF 05/05/16
0.28
Total taxable interest
$15.56
Total dividend and interest income
$7,157.68
Date
Activity
Description
Amount ($)
Bill payments
May 3 Withdrawal
ACH TO Scott Borgerson AT CITIZENS BANK, NA
-2,500,000.00
Total bill payments
-$2,500,000.00
CNP70008005580146 NP7000191995 00005 0516 030575004 Y123575550 000000
Page 6 of 8
EFTA00022412

=== Page 7 ===
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
UBS
Friendly account name: Cash/Saving
SCOTT STACKMAN/LYLE CASRIEL
May 2016
Account number:
212-821-7000/800-308-3140
Account activity this month (continued)
Date
Activity
Description
Amount ($)
Other funds debited
May 6
Withdrawal
FEDERAL FUNDS TO Haddon, Morgan and Foreman, AT WELLS FARGO
-50,000.00
BANK, NA
May 26 Transfer
JOURNAL TO Y1 23692 116 EAST 65TH STREET LLC
-1,221.67
Total other funds debited
-$51,221.67
Investment transactions
For more information about the price/value shown for restricted securities, see Important information about
your statement at the end of this document.
Proceeds from
Funds
investment
withdrawn for
Accrued
Date
Activity
Description
Quantity
Value ($)
Price ($)
transactions ($)
investments bought ($)
interest ($)
May 2
Reinvestment
PUTNAM SHORT DURATION INCOME FUND Y
274.146
-2,752.43
DIVIDEND REINVESTED AT 10.04 NAV ON
04/29/16 AS OF 04/29/16
May 3
Sold
UBS SELECT PRIME INSTITUTIONAL FUND
-2,500,000.000
2,500,000.00
May 6
Sold
UBS SELECT PRIME INSTITUTIONAL FUND
-49,000.000
49,000.00
May 11
Bought
UBS SELECT PRIME INSTITUTIONAL FUND
406.070
-406.07
May 12
Bought
UBS SELECT PRIME INSTITUTIONAL FUND
62,592.790
-62,592.79
May 26
Sold
UBS SELECT PRIME INSTITUTIONAL FUND
-1,221.670
1,221.67
May 31
Reinvestment
UBS SELECT PRIME INSTITUTIONAL FUND
4,389.690
-4,389.69
DIVIDEND REINVESTED AT 1.00 NAV ON
05/31/16
Total
$2,550,221.67
-$70,140.98
Date
Activity
Description
Amount ($)
Money balance activities
Apr 29
Balance forward
$0.00
May 3
Deposit
UBS BANK USA DEPOSIT ACCOUNT
1,390.51
May 6
Deposit
UBS BANK USA DEPOSIT ACCOUNT AS OF 05/05/16
0.28
May 9
Withdrawal
UBS BANK USA DEPOSIT ACCOUNT AS OF 05/06/16
-984.72
May 12
Withdrawal
UBS BANK USA DEPOSIT ACCOUNT AS OF 05/11/16
-406.07
May 31
Closing UBS Bank USA Deposit Account
$0.00
The UBS Bank USA Deposit Account is your primary sweep option.
CNP70008005580147 NP7000191995 00005 0516 030575004 Y123575550 000000
Page 7 of 8
EFTA00022413

=== Page 8 ===
UBS
Your notes
CNP70008005580148 NP7000191995 00005 0516 030575004 Y123575550 000000
Page 8 of 8
End of statement for account number Y1 23575 S5
EFTA00022414


c1: EFTA00023415
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023415.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Second Daubert Motion
Date: Mon, 15 Nov 2021 04:41:26 +0000
Attachments: Motion_to_preclude_Hall_et_al_v3.docx
Hi Chiefs,
I hope you had a nice weekend! Attached is our second Daubert motion for your review. It is due tomorrow.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00023415


c1: EFTA00022980
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022980.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Subject: Re: U.S. Department of Justice investigation
Date: Tue, 28 Jan 2020 23:55:36 +0000
Inline-Images: image893248.jpg; image531942.jpg
On Jan 28, 2020, at 6:43 PM,
)
wrote:
Begin forwarded message:
From:
(USANYS)"
Date: January 28, 2020 at 6:32:33 PM EST
To:
)"
Subject: FW: U.S. Department of Justice investigation
From:
Sent: Tuesday, January 28, 2020 12:02 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: FW: U.S. Department of Justice investigation
From: Gary Bloxsome
Sent: Tuesday, January 28, 2020 11:59
To:
Cc:
is
>; ; Daniel Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Dear
Thank you for your email response claiming that US Attorney Berman's statements were factually accurate
and did not create a misleading impression.
EFTA00022980

=== Page 2 ===
We only have access to edited video and newspaper reporting of what the US Attorney said. Those reports
suggest the US Attorney described the position of the Duke of York and his advisors in misleading,
condemnatory and prejudicial terms. US Attorney Berman is quoted as having stated there has been "zero
co-operation". This is not an accurate statement of the position. The following are also false statements
ascribed to Mr Berman and to the DOJ/FBI: "F.B.I. agents and federal prosecutors in New York reached out
to his lawyers and asked to interview him. There was no response at all, according to three people familiar
with the investigation." (New York Times 27.01.20) and "Geoffrey Berman, a US attorney, said federal
prosecutors and the FBI had asked to interview Prince Andrew about the late paedophile billionaire, but had
been met with a wall of silence "(The Telegraph 28.01.20).
Please provide us with an accurate record of the statements made by The US Attorney and/or the DOJ/FBI
including a transcript of any relevant questions and answers.
We note from your email that you have not provided any response to our request that you confirm that the
DOJ will not be making any further public statements about the Duke of York. We had understood from our
conversations with you and from the rules governing media relations that DOJ personnel and the US
Attorney would not comment on the nature or progress of any grand jury investigation and in particular
would not comment on the willingness of any Subject to make a voluntary statement to the DOJ. We ask you
to confirm that there will be no further public comment on any contact between the Duke of York and the
DOJ.
Kind regards
Gary
Gary Bloxsome
Partner
Blackfords LLP
London
EC4M 7EF
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 27 Jan 2020, at 22:59,
wrote:
External email: is it safe to open attachments and links?
Gary,
Our understanding is that U.S. Attorney Berman made a factual statement in response to a specific question that
suggested the Duke of York either would or was cooperating, and he responded that to date he has not in fact
provided cooperation with our investigation. That is, he corrected the record generally in a factually accurate
statement; I don't believe this would create a misleading impression. I appreciate that you have advised us that your
client has a desire to cooperate, and we look forward to hearing from you when he has made a determination as to
whether he is in fact willing to speak with us.
EFTA00022981

=== Page 3 ===
Regards,
From: Gary Bloxsome
Sent: Monday, January 27, 2020 13:44
To:
Cc:
>; Daniel Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
The press are reporting that Geoffrey S. Berman, the United States Attorney for the Southern District of New York
has disclosed what we understood were confidential communications between us and
and
It has also been suggested that Geoffrey S. Berman has stated that the Duke of York has not co-operated with the
Southern District. As you know we have made it very clear that the Duke of York has a strong desire to cooperate
with the ongoing investigation by the DOJ and we are trying to reach a position where we are able to advise him to
do so.
We are concerned about the misleading impression that has been created and the effect this has on our ability to
advise the Duke to proceed with any voluntary co-operation. Please confirm that the DOJ will not be making any
further public statements on this topic.
Thank you.
Gary Bloxsome
Gary Bloxsome
Partner
Blackfords LLP
London EC4M 7EF
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 22 Jan 2020, at 17:34,
)
wrote:
External email: is it safe to open attachments and links?
Gary,
We've received your response. We look forward to hearing whether the Duke of York is willing to speak with us.
thank you,
EFTA00022982

=== Page 4 ===
From: Gary Bloxsome
Sent: Wednesday, January 22, 2020 11:35
To:
Cc:
is
>; Daniel
Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
We are very grateful for your offer of assistance. At present we do not believe you can help us but we would welcome
a real-time conversation once we have achieved some of the more immediate preliminary tasks, including the need to
gather information from the Royal Household and others.
Best
Gary Bloxsome Partner
Blackfords LLP
London EC4M 7EF
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 20 Jan 2020, at 18:52,
wrote:
External email: is it safe to open attachments and links?
Gary,
Thank you for your response. It would be useful for us if you were able to help us understand the nature of the
issues and procedures with which you are dealing, particularly as it sounds like it will take at least a couple
additional weeks to address even minor preliminary issues, which suggests likely additional subsequent time to
handle further processes-and without a response to the question of whether he is willing to speak with us,
separate from a general desire to cooperate. Our investigation is moving forward expeditiously and so we would
be grateful for some understanding of the relevant issues (especially, though not exclusively, to the extent we
may be able to assist in their resolution) and would be happy to speak via phone if a real-time conversation
would be more conducive to that discussion.
thank you,
From: Gary Bloxsome
Sent: Monday, January 20, 2020 11:23
To:
Cc:
is
>; Daniel
Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
EFTA00022983

=== Page 5 ===
Thank you for your email. The Duke of York has made it clear to us that he has a strong desire to cooperate fully
with the ongoing investigation by the DOJ.
It is our responsibility to deal with the various issues and procedures that arise here that will need to be
addressed to enable him to do so. We should be able to deal with at least some of the minor preliminary issues in
the next two weeks and we will update you on our progress once we have done so.
Regards,
Gary
Gary Bloxsome
Partner
<image001jpg> <image002.jpg>
Blackfords LLP
London
EC4M 7EF
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk,
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 18 Jan 2020, at 01:06,
)
wrote:
External email: is it safe to open attachments and links?
Gary,
We write to follow up on our phone conversation of a week ago. Could you please advise regarding status, in
particular the initial question, separate from any logistics, of whether you expect your client will be willing to
speak with us? And of course please let us know if any additional information would be useful to you.
thank you,
From: Gary Bloxsome
Sent: Wednesday, January 08, 2020 07:38
To:
Cc:
is
>; Daniel
Cundy
>; ; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email.
Friday 10th January at 1400(LDN) time is fine.
EFTA00022984

=== Page 6 ===
Please forward dial in details.
Kind regards
Gary
Gary Bloxsome
Partner
Blackfords LLP
London I EC4M 7EF
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 7 Jan 2020, at 18:56,
wrote:
External email: is it safe to open attachments and links?
Gary,
We are available for a preliminary call this Friday, January 10. If it would be convenient for you, we are
available at 9:00 local time for us (which I believe would be 14:00 your time). If that works, we can plan to call
you at your office line unless you'd prefer we use another number or a conference line.
thank you,
From: Gary Bloxsome
Sent: Tuesday, January 07, 2020 11:20
To:
Cc:
>; ; Daniel
Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email.
Please confirm whether you would be available for a preliminary telephone call on Friday 10th January 2020.
EFTA00022985

=== Page 7 ===
Kind regards.
Gary
Gary Bloxsome
Partner
Blackfords LLP
London EC4M 7EF
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 4 Jan 2020, at 01:38,
)
wrote:
External email: is it safe to open attachments and links?
Mr. Bloxsome,
Thank you for your response and for confirming your representation. To respond to your question generally,
in connection with our investigation of conduct relating to Jeffrey Epstein and certain of his associates, we
wish to request a consensual, voluntary law enforcement interview with your client. Generally, we would
expect to inquire about his relationship and communications with Jeffrey Epstein and his associates, as well
as certain allegations that have arisen publicly and in our investigation to date.
Although we recognize we separately have the ability to convey such a request through diplomatic and law
enforcement channels, we understand we may also alternatively inquire directly with counsel, when an
individual has legal representation. Given your representation, we are inquiring directly with counsel in the
first instance.
Certainly we can discuss our request in more detail, but we hope this will provide the information you were
seeking as a threshold matter, and we look forward to being in touch.
Regards,
Assistant U.S. Attorney
Southern District of New York
212.637.2415
EFTA00022986

=== Page 8 ===
From: Gary Bloxsome
Sent: Friday, January 03, 2020 10:30
To:
Cc:
is
>;
Daniel Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Dear Sirs,
Thank you for your email dated 2 January 2020.
I confirm that we do represent HRH the Duke of York.
I would be grateful if you could please clarify what specifically you invite us to contact you about.
Kind regards
Gary Bloxsome
Gary Bloxsome
Partner
Blackfords LLP
|
London EC4M 7EF
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 2 Jan 2020, at 18:54,
wrote:
External email: is it safe to open attachments and links?
Mr. Bloxsome,
We are the federal prosecutors investigating conduct relating to Jeffrey Epstein, under the U.S. Department
of Justice, Southern District of New York. We have been advised that you currently represent HRH The
Duke of York. Could you please advise whether that is correct? We - my colleagues
and I - can be reached anytime at these email addresses, or please let us know if you would prefer
to set up a time to discuss via phone.
Regards,
Assistant U.S. Attorney
Southern District of New York
EFTA00022987

=== Page 9 ===
TOP TIER
am
2020
009
LEGAL
Leading Firm
2020
UK
Chambers
RANKED IN
212.637.2415


c1: EFTA00021340
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021340.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Epstein subpoena return
Date: Tue, 15 Oct 2019 18:53:54 +0000
Of course. I will come by and grab the disc.
From:
Sent: Tuesday, October 15, 2019 2:47 PM
To:
Subject: Epstein subpoena return
Hi
Any chance you have time to help me out with loading a subpoena return for the Epstein case onto the share? I haven't
been able to open the disc myself, and it may require IT help.
Thanks!
EFTA00021340


c1: EFTA00020972
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020972.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-58 United States of America V. Maxwell "Notice of Appearance for Additional or Substitute
Counsel FILED"
Date: Tue, 26 Jan 2021 00:26:50 +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 01/25/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Document(s): Document(s)
Docket Text:
NOTICE OF APPEARANCE AS ADDITIONAL COUNSEL, on behalf of Appellant Ghislaine Maxwell and
Appellee USA United States of America, FILED. Service date 01/25/2021 by CM/ECF. [3020548] [21-58]
Notice will be electronically mailed to:
Deputy Clerk:
Ms. Bobbi C. Sternheim, -: bc@sternheimlaw.com, bc@sternheimlaw.com, ecf@sternheimlaw.com
Notice will be stored in the notice cart for:
,
Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Notice of Appearance for Additional or Substitute Counsel FILED
Original Filename: 21-58 Additional Counsel.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=01/25/2021] [FileNumber=3020548-0]
66b2cc93331a67d2edeb29c35d07a0c602]]
EFTA00020972


c1: EFTA00023074
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023074.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
)"
Cc:
(USANYS)"
(USANYS)"
)"
(USANYS)"
(USANYS)"
(USANYS) 1"
(USANYS)"
,
(USANYS)"
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Date: Thu, 31 Dec 2020 16:27:07 +0000
Attachments: 2020.12.31_Thompson_Decl_re_Maxwelldocx
Thanks,
I have incorporated your edits and comments.
Also, an update. There will be a separate declaration on Maxwell, which I have attached here. The
substance is the same as before, with one minor exception - it clarifies that Maxwell has daily access to
a social telephone.
From:
(USANYS)
Sent: Thursday, December 31, 2020 10:39 AM
To:
(USANYS)
in
)
Cc:
(USANYS)
is
(USANYS)
V.
is
(USANYS)
>;
(USANYS)
is
(USANYS) 1
is
(USANYS)
is
(USANYS)
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Just a couple small things from me and
Thanks for putting this together.
From:
(USANYS)
Sent: Wednesday, December 30, 2020 11:38 PM
To:
)
Cc:
(USANYS)
is
(USANYS)
is
(USANYS)
is
is
(USANYS)
is
(USANYS)
is
(USANYS) 1
is
(USANYS)
is
(USANYS)
^
Subject: Re: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Thanks to you all!
Assistant United States Attorney
Sent from my iPhone
On Dec 30, 2020, at 10:09 PM,
wrote:
EFTA00023074

=== Page 2 ===
Thanks very much,
and I have reviewed, and from the Maxwell team's perspective, these
documents are accurate and would not present issues in our case if filed.
From:
(USANYS)
Sent: Wednesday, December 30, 2020 5:29 PM
To:
(USANYS)
in
(USANYS)
>;
)
is
(USANYS)
>;
)
Cc:
(USANYS)
>;
(USANYS)
>;
(USANYS) 1
>;
(USANYS)
is
(USANYS)
Subject: FW: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Hey everyone: Here's the latest draft of our letter and declaration on this issue. We are still
confirming a few things, but they shouldn't impact the substance of the Maxwell discussion. There is
also a chance that there's a separate declaration from the MDC; if there is, it should contain the same
substance re: Maxwell that's in the attached draft.
Our response is due tomorrow. I'm generally around later this evening or tomorrow if there's
anything you'd like to discuss.
Thanks very much.
From:
(USANYS)
Sent: Wednesday, December 30, 2020 2:40 PM
To:
(USANYS)
i
(USANYS)
>;
(USANYS)
is
(USANYS)
i
)
is
)
>;
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
^
i
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
:
We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to
explain that the discovery and counsel access accommodations that have been provided to Maxwell
and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of
their lawyers, and their individual housing circumstances. On all of these factors, there are several
important differences, including:
-
The Maxwell case has multiple times more discovery than the Rivera case. Hence, the need
for such expanded discovery access is greater in the Maxwell case.
-
At the MDC, Maxwell has a unique housing situation, as she is in protective custody outside
the general population. She therefore has sole access to a room to use a computer and phone
for approximately 13 hours a day. Rivera, by contrast, is housed in the general population.
-
There are approximately 80 other inmates at the MCC in Rivera's unit that use the same VTC
room for court appearances, probation interviews, and attorney meetings. By contrast,
Maxwell shares access to the MDC VTC room with substantially fewer inmates. The MDC can
EFTA00023075

=== Page 3 ===
therefore provide 15 hours of VTC meetings with her attorneys without compromising access
for other MDC inmates. The same is not true for Rivera at the MCC.
Going forward, even though Rivera's counsel have asked (and the Court has ordered) that Rivera
receive three hours of laptop access each day, the MCC is now leaving the laptop with him all day
long, and only takes it back at night to charge it. Therefore, the MCC is now providing the same
amount of electronic discovery access to Rivera that Maxwell receives at the MDC.
As for providing Rivera with up to 15 hours of VTC access, we will explain that doing so will
compromise access for other inmates. If defense counsel expresses a need for additional time, the
MCC will continue to find ways to accommodate those requests as best as they can.
Please let me know if you have any questions or would like to discuss this further.
Best,
From:
(USANYS)
Sent: Monday, December 21, 2020 4:42 PM
To:
(USANYS)
>;
(USANYS)
i
(USANYS)
i
(USANYS)
i
>;
>;
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
>;
(USANYS)
>;
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Thanks,
Can you keep me posted on what we think will be the substance of the draft declaration when you
know (that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences
between MCC and MDC, as well as specific differences in their housing situations?
From:
(USANYS)
Sent: Monday, December 21, 2020 4:35 PM
To:
(USANYS)
i
(USANYS)
>;
(USANYS)
i
(USANYS)
is
)
is
)
>;
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
All:
I wanted to bring to your attention a recent issue that's surfaced in United States v. Rivera et al., a
sex trafficking case pending before Judge Engelmayer. As I'll describe in more detail below, Judge
Engelmayer has asked us to submit a declaration from the BOP explaining why the discovery and
counsel access accommodations provided to Ghislaine Maxwell (detained at the MDC outside the
general population) cannot be extended to Justin Rivera (detained at the MCC in the general
population).
EFTA00023076

=== Page 4 ===
Justin Rivera was charged in February 2019 with sex trafficking conspiracy. He's been detained at
the MCC since April 2019 on consent (he's also serving a state sentence). His trial, which was
originally scheduled for April 2019, is expected to start on February 16, 2020. In July 2020, he had
new counsel appointed, citing an irreconcilable breakdown with his former counsel.
Since this fall, Judge Engelmayer has become increasingly frustrated with the MCC's treatment of
Rivera. In particular, he's cited their failure to provide Rivera with adequate accommodations to
review discovery and meet with his lawyers, who refuse to visit Rivera at the MCC for personal health
concerns. We have two court orders in place to address these issues: (1) a laptop order, which
requires the MCC to provide Rivera access to a laptop for three hours per day; and (2) a
videoconference order, which requires the MCC to make available four hours of videoconferencing
each week, in addition to any telephone or videoconference calls obtained through the Federal
Defenders.
At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time
Rivera has for videoconferences and electronic discovery review is insufficient for trial preparation,
although defense counsel has stated that they may request more time in the future. However, in a
letter last night and during a court conference this morning (transcript attached), defense counsel
cited the accommodations that the MDC has provided to Maxwell, describing them as "strikingly
different and far superior" to those afforded to Rivera. Defense counsel further suggested that Rivera
was being treated differently on account of his race, gender and class. Judge Engelmayer stated that
the disparity in access "jumped off the page" and that the optics were "terrible," and asked us to
explain the rationale for the differing treatment. After conferring with
and
before our conference, we explained our understanding that the disparity comes down to
the fact that Maxwell and Rivera have very different housing situations, with Maxwell's situation
being more amenable to greater access to electronic discovery review and legal visits.
Judge Engelmayer asked us to submit a declaration, from an appropriate person at the BOP,
explaining in more detail why the accommodations provided to Maxwell cannot be extended to
Rivera. Based on the recent bail opposition in the Maxwell case, I believe the differences in
counsel/discovery access are as follows:
Accommodation
Maxwell
Rivera
Review of electronic
13 hours per day/7 days per
3 hours per day/7 days per
discovery (NB: each
week (91 hours total)
week (21 hours total)
defendant has laptop access)
Counsel visits (by video)
3 hours per day/5 days per
Four hours per week (plus an
week (15 hours total)
additional two hours
scheduled through the
Federal Defenders) (6 hours
total)
Weekend legal calls
As needed
Not available
The declaration is due by December 31. Because Judge Engelmayer's request implicates at least two
criminal cases, and potentially the ongoing civil litigation with the MCC, we wanted to make sure that
you were all aware of this issue. We are also happy to set up a call to discuss this further. In the
meantime, we are working with
to identify the appropriate declarant and draft an
explanation for the Court.
EFTA00023077

=== Page 5 ===
Best,
Assistant United States Attorney
United States Attorney's Office for the Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Tel:
EFTA00023078


c1: EFTA00022142
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022142.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(NY) (FBI)"
@fbi.gov>
To:
(USANYS)"
Subject: Re: Time to chat?
Date: Thu, 05 Dec 2019 18:47:14 +0000
Sounds good. I'll call your desk.
Thanks
-
On Dec 5, 2019 1:45 PM,
(USANYS)"
wrote:
Sure - would 430 work?
Sent from my iPhone
On Dec 5, 2019, at 1:37 PM,
(NY) (FBI)
@fbi.gov> wrote:
Hi Ted,
Any time this afternoon for a quick status call on Epstein?
-
On Nov 25, 2019 3:29 PM, "
(USANYS)"
wrote:
Let me know if you have a few minutes to connect later today or tomorrow. Thanks
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00022142


c1: EFTA00023363
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023363.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Nathan NYSD Chambers
To: Christian Everdell <CEverdell@CohenGresser.com>
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, Laura Menninger <lmenninger@hmflaw.com>,
bcsternheim mac.com <bcsternheim@mac.com>,
(USANYS)"
)"
Subject: Re: U.S. V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) -- Response to Government's Letter re:
Birth Certificates
Date: Sun, 21 Nov 2021 15:09:21 +0000
Inline-Images: image001.gif; image002.gif
Counsel:
Please refer to Dkt. No. 474 for instructions as to filing the redacted letter on the public docket.
Sincerely,
Chambers of the Hon. Alison J. Nathan
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Saturday, November 20, 2021 11:14 PM
To: Nathan NYSD Chambers
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Laura Menninger <lmenninger@hmflaw.com>; bcsternheim_mac.com
<bcsternheim@mac.com>;
is
>;
(USANYS)
i
Subject: RE: U.S. V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) -- Response to Government's Letter re: Birth Certificates
CAUTION - EXTERNAL:
Dear Chambers -
The government has provided its proposed redactions to the letter (see attached). The defense has no redactions to add.
We will await the Court's instructions as to filing the redacted letter on the public docket.
Regards,
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 707 7268
ceverdell@cohengresser.com
view
bio
www.cohengresser.com
New York Paris Washington DC London
CG
EFTA00023363

=== Page 2 ===
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
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.
From: Christian Everdell
Sent: Saturday, November 20, 2021 9:31 PM
To: 'Nathan NYSD Chambers'
Cc: 'Jeff Pagliuca' <jpagliuca@hmflaw.com>; 'Laura Menninger' <lmenninger@hmflaw.com>; bcsternheim@mac.com;
(USANYS)'
>;
Subject: U.S. V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) -- Response to Government's Letter re: Birth Certificates
Dear Chambers -
Attached please find Ms. Maxwell's response to the government's letter, dated November 11, 2021, regarding the self-
authentication of birth certificates of the alleged Minor Victims. Pursuant to our established protocol, we are submitting
the letter to the Court under temporary seal to allow the government to propose any redactions it deems necessary.
Respectfully submitted,
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 707 7268
ceverdell@cohengresser.com
view bio
www.cohengresser.com
New York
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
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.
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
EFTA00023364


c1: EFTA00021768
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021768.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
bop.gov>
bop.gov>
Cc:
(USANYS)"
Subject: Tartaglione MCC Video
Date: Tue, 14 Jan 2020 17:45:24 +0000
Attachments: 2020.01.13 - _Def_Mot_for_Hearing.pdf
FYI, attached is the motion that Bruce Barket filed seeking a hearing on the loss of the MCC video. We
plan to oppose and will keep you posted.
Co-Chief, Narcotics Unit
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York, New York 10007
EFTA00021768


c1: EFTA00021197
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021197.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: Epstein
Date: Fri, 09 Aug 2019 12:19:50 +0000
I got on the introductory call to
with
but I left her to run with SDFL documents. Check with her.
Associate U.S. Attorney, SDNY
On Aug 9, 2019, at 7:58 AM,
wrote:
Separately
the Miami Herald is reporting that
, the lone remaining prosecutor on the 2007
Florida prosecution is leaving SDFL. Have you heard back from
yet on his efforts to track down
whatever paper/hard copy materials she may have?
https://www.miamiherald.com/news/state/florida/article233668342.html
Sent from my iPhone
On Aug 9, 2019, at 6:26 AM, McEnany,
wrote:
Note the blurb that the Florida governor ordered an inv into the Palm Beach PD handling of Epstein
Begin forwarded message:
From: The Marshall Project <info@themarshallproject.org>
Date: August 8, 2019 at 7:41:03 AM EDT
To:
Subject: Swept up by ICE
Reply-To: The Marshall Project <info@themarshallproject.org>
The Marshall Project
EFTA00021197

=== Page 2 ===
Opening Statement
August 8, 2019
Edited by ANDREW COHEN
SUBSCRIBE TO OUR NEW
NEWSLETTER:
LIFE INSIDE
Life
Inside
Weekly essays by those who live
or work in the criminal justice
system, delivered to you.
PICK OF THE NEWS
Hundreds arrested in ICE raids at food processing plants in Mississippi.
Immigration agents Wednesday seized workers from seven work sites. BUZZFEED
Children were separated from their parents and each other as friends protested the
choreographed raids. THE WASHINGTON POST Several companies were targeted, including
Koch Foods, one of the biggest poultry processors in the nation. ASSOCIATED PRESS
Related: Officials say it might be the largest ever workplace sweep in a single state. THE
NEW YORK TIMES
Thoughts, prayers, inaction. Despite broad public support for universal background
checks for gun sales, GOP senators won't support legislation requiring them. THE
WASHINGTON POST A federal "red flag" law, encouraging states to take guns away from
people who pose a threat, may have a better chance of passage. ASSOCIATED PRESS
Meanwhile, the Trump administration has expanded access to guns through regulatory
actions. POLITICO Finally: White House rebuffed efforts by Homeland Security officials
to aggressively fight domestic terrorism. CNN
EFTA00021198

=== Page 3 ===
A litany of grief, heroism and lost futures: Short histories of the lives and
deaths of the shooting victims of El Paso. THE WASHINGTON POST The alleged El
Paso gunman gets a seasoned defense attorney as prosecutors, and maybe the feds too,
prepare for a capital case. EL PASO TIMES Related: Along with gun violence comes a
rise in false alarms and feelings of dread and anxiety. THE WASHINGTON POST Finally:
Meet Glendon Oakley, a soldier who helped children escape the El Paso massacre. TASK
AND PURPOSE
A real invasion, of guns heading south to Mexico. Gun-running Americans, who
smuggle somewhere between 700 to 800 firearms into Mexico every day, are a big part of
the reason why that country has high murder rates and low rates of successful law
enforcement operations aimed at undercutting drug cartels. Lax state laws in Texas make
the problem particularly acute there, or lucrative, depending on your point of view.
ROLLING STONE Related: Mexico launches terror probe aimed at American shooter.
SLATE
T Race, justice and death penalty bias. The North Carolina Supreme Court later
this month will hold hearings in a case about the state's Racial Justice Act, an historic
piece of legislation passed in 2009 that allowed death row inmates there to more
aggressively challenge their sentences based on allegations of racial bias in a jurisdiction
long known for it. Republican lawmakers repealed the law in 2013 and the question for
the justices now is whether men who were released from death row before 2013 may be
returned there. Jack Brook has our story, this time with a working link. THE MARSHALL
PROJECT
N/S/E/W
Cyntoia Brown goes free. Released from a women's prison in Tennessee Wednesday
morning, she spent 15 years for murdering a man she said was trafficking her for sex. Her
life sentence, imposed at age 16, was commuted in January. NASHVILLE SCENE A few
post-release obligations, including community service. THE TENNESSEAN TMP Context:
Cyntoia Brown and our twisted system. THE MARSHALL PROJECT
How the "felony murder" rule works in Ohio. Police shoot and kill a robbery suspect and
then charge his girlfriend with the murder, because, they say, she was in on his crimes.
EFTA00021199

=== Page 4 ===
THE NEW REPUBLIC TMP Context: Charged with murder without killing anyone. THE
MARSHALL PROJECT
A federal grand jury in Louisiana indicted nearly two dozen people, including five
guards at the state penitentiary at Angola, on drug-smuggling charges. (BATON ROUGE)
ADVOCATE
A Utah judge this week began to hear testimony from lawyers for a death row inmate
whose trial lawyer never called 16 witnesses who reportedly were prepared to offer
"mitigating" testimony during the penalty phase of his 2015 capital trial. SALT LAKE CITY
TRIBUNE
Florida's governor orders an investigation into the way local officials in Palm Beach
handled the Jeffrey Epstein case. MIAMI HERALD
COMMENTARY
Terror is as terror does. When it comes to hate and deadly violence, what's the
difference between white supremacists and Jihadis? THE NEW YORK TIMES Related: The
link between gun violence and misogyny is a deadly mix we cannot ignore. USA TODAY No
such thing as a "lone wolf" in the age of the internet. FIVETHIRTYEIGHT Time to shut
down 8chan, the internet message board where shooters go to announce their plans. THE
NEW YORK TIMES
El Paso to Trump: The hatred that led to gun violence didn't come from our city. EL
PASO TIMES But it did follow a long line of white supremacist and nativist attacks against
people of color in Texas. THE NEW YORK TIMES
Two ships passing in the night. Can the limitations of criminal proceedings ever be
compatible with the requirements of good scientific methods? By Radley Balko. THE
WASHINGTON POST
EFTA00021200

=== Page 5 ===
The People V. William Barr. When the Justice Department acts like a private law
firm for a president trying to avoid accountability to Congress. SLATE
ETC.
Survey of the Day: All you ever wanted to know, and more, about the state of Texas'
gun laws. Spoiler alert: Yearly gun sales doubled from 2013 to 2017. TEXAS TRIBUNE
Complaints of the Day: Police in Mesa, Arizona, aren't happy about the fact that they
have to undergo training to identify and reduce their racial bias. CBS NEWS
Open Letter of the Day: Dear Walmart, you have the power to do more to stop gun
violence like the type that shattered one of your stores in El Paso. THE NEW YORK TIMES
Funeral of the Day: For a dog named "Jake," who lived and died looking for drugs in
Alabama prisons. The ceremony was elaborate, and costly, and raises questions about the
way prison officials mistreat or disrespect the families of inmates who die in custody.
AL. COM
Want less email? Update your preferences.
This email was sent to john.mcenany@usdoj.gov
why did / get this? unsubscribe from this list update subscription preferences
The Marshall Project 156 West 56th Street - Suite 701 New York, NY 10019 USA
EFTA00021201


c1: EFTA00022344
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022344.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(NY) (FBI)"
To:
)"
Cc:
)"
"
)"
Subject: Re: Epstein search warrant documents
Date: Thu, 04 Jun 2020 17:10:00 +0000
Attachments: All_NY_seizure_evidence.xlsx
Hey
,
Wanted to get this to you. This spreadsheet contains all evidence seized in NY. Let me know if you have any
issues/concerns.
Thanks,
From:
Sent: Wednesday, June 3, 2020 9:37 AM
To:
is
(NY) (FBI)
Cc:
is
Subject: RE: Epstein search warrant documents
No problem-totally understood. Be safe.
From:
Sent: Wednesday, June 3, 2020 2:15 AM
To:
is
(NY) (FBI)
Cc:
>;
)
Subject: Re: Epstein search warrant documents
Hey
,
Both myself and
were pulled this week to assist with the riots and looting currently happening in
Manhattan. Hopefully this does not go on for too long. When we return to the office we will be sure to fill in
those blanks for you and hopefully, once again get back on track.
Be safe.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
EFTA00022344

=== Page 2 ===
From:
Sent: Tuesday, June 2, 2020 2:18 PM
To:
is
(NY) (FBI)
Cc:
is
Subject: FW: Epstein search warrant documents
Hi
and
Any chance you'd be able to help fill in the attached chart with the specific location in the NY mansion where each device
was recovered (similar to the chart you sent me for the USVI devices), please? Once I get that, I can put together the
revised warrant.
Thanks,
EFTA00022345


c1: EFTA00021251
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021251.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: SDNY NEWS CLIPS, NOVEMBER 5, 2020
Date: Thu, 05 Nov 2020 23:05:01 +0000
BRIAN KOLFAGE, ET AL.
NYDN: https://www.nydailynews.com/new-york/ny-timothy-shea-bannon-we-build-the-wall-venue-20201105-
Ic5q6umalzekhdrzyzwd6ppr5u-story.html
NINE TREY
AP: https://apnews.com/article/new-york-kidnapping-courts-manhattan-4cb0bd6bd7b0a9848d992b1efc77041d
PEOPLE: https://people.com/music/tekashi-6ix9ine-kidnapper-sentenced-to-24-years-prison/
MATTERS OF INTEREST
VANITY FAIR: https://www.vanityfair.com/nevs/2020/11/william-barr-armed-agents-ballot-counting
NYT: https://www.nytimes.com/2020/11/04/nyregion/nyc-presidential-election-protests.html
NYT: https://www.nytimes.com/2020/11/05/nyregion/james-kobel-nypd-racism.html
CITY & STATE: https://www.cityandstateny.com/articles/personality/personality/westchesters-next-da-tackling-police-
corruption.html
REUTERS: https://www.reuters.com/article/us-bombardier-sfo-investigation/uks-sfo-probes-bombardier-for-
suspected-bribery-corruption-in-indonesia-idUSKBN27L22W
JD SUPRA: https://www.jdsupra.com/legalnews/fincen-invites-comments-on-anti-money-86611/
YAHOO NEWS: https://news.yahoo.com/abusive-bronx-man-held-girlfriend-230600844.html
LA TIMES: https://www.latimes.com/opinion/story/2020-11-05/trump-policing-panel-broke-the-law
NEWSWEEK: https://www.newsweek.com/doj-uk-police-evidence-prince-andrew-jefrey-epstein-biographer-claims-
1544757
PROPUBLICA:https://www.propublica.org/article/whether-the-gop-can-stop-voters-from-legally-fixing-rejected-mail-
in-ballots-could-decide-the-election
WSJ:https://www.wvsj.com/articles/facebook-takes-down-group-organizing-protests-of-vote-counting-11604603908
EFTA00021251


c1: EFTA00022432
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022432.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: SDNY investigation
Date: Thu, 06 May 2021 20:00:56 +0000
Thanks very much. If 4:30 works, I can call you then. Which number is best to reach you?
From: Quigley, Brendan
Sent: Thursday May 6. 2021 3:32 PM
To:
Cc:
Subject: RE: SDNY investigation
Sure. I am around the rest of the afternoon today. Tomorrow is a bit rougher, but I could talk first thing (like 9) or late
afternoon.
Brendan F. Quigley [bio]
Partner
Baker Botts LLP
From:
Sent: Thursday, May 6, 2021 12:48 PM
To
Cc
Su
[EXTERNAL EMAIL]
Hi Brendan,
Hope you're doing well. Do you have time this afternoon or tomorrow for a quick call about this case?
Thanks,
From:
Sent: Friday, June 5, 2020 3:35 PM
EFTA00022432

=== Page 2 ===
To:
Cc:
Subject: Re: SDNY investigation
Appreciate the courtesy. Please do not pass on our contact info. That said, feel free to contact us if anything comes up in
your investigation.
Thank you. Hope you guys are all hanging in okay.
Brendan F. Quigley
On Jun 5, 2020, at 3:19 PM,
vrote:
[EXTERNAL EMAIL]
Brendan,
An attorney for an individual who has an active civil case in connection with Epstein has reached out to us to ask if we
know the current counsel for
I assume that the attorney is seeking to serve a request or subpoena for
documents and/or testimony, though we haven't asked specifically.
I don't think we ordinarily engage on that type of question, but given that we have been in touch with you in connection
with our interview of
if you'd like we can pass along your contact info, so that the attorney goes to you
rather than attempting to contact or serve
directly. And if not, of course no problem, and we'll just let him
know that we're not able to comment one way or the other on the status of any counsel. Whatever you prefer.
Thanks, and hope you're well these days.
From:
Sent: Friday, February 07, 2020 18:36
To
Cc
Subject: RE: SDNY investigation
Thank
From:
Sent: Friday, February 7, 2020 6:13 PM
To: Ouiglev. Brendan
Cc:
Subject: RE: SDNY investigation
[EXTERNAL EMAIL]
Brendan,
EFTA00022433

=== Page 3 ===
As promised, attached please find a copy of the proffer agreement signed today.
thanks,
Confidentiality Notice:
The information contained in this email and any attachments is intended only for the recipient[s] listed above and may be privileged
and confidential. Any dissemination, copying, or use of or reliance upon such information by or to anyone other than the recipient[s]
listed above is prohibited. If you have received this message in error, please notify the sender immediately at the email address
above and destroy any and all copies of this message.
EFTA00022434


c1: EFTA00020996
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020996.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Epstein
Date: Mon, 26 Aug 2019 21:37:18 +0000
I'm sorry I didn't get this earlier--I'm unfortunately on trial this week--but I understand you spoke to
and/or
Thanks for being in touch, and I hope all goes well tomorrow.
thanks again,
Original Message
From:
Sent: Monday, August 26, 2019 12:40
To:
Subject: Epstein
Hi, This is
attorney,
Please give me a call regarding tomorrow
Sent from my iPhone
EFTA00020996


c1: EFTA00022516
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022516.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
(
)"
Cc:
)"
)"
Subject: Rule 17 subpoenas
Date: Mon, 03 May 2021 19:12:31 +0000
Attachments: 2021.04.16_AJN_opinion - Dkt._207.pdf; 2021.03.30_BSF_Ltr_Motn.pdf;
2021.04.05_BSF_Reply_re_Maxwell_Rule_17(c)_Subpoena_[Government_Proposed_Reda
ctions].pdf; 2021-05-XX_Letter_to_AJN_re_Requests_9-11_v3.docx;
2021.04.02_Defts_Resp_to_BSF_Ltr_Motn_to_Quash_Rule_17_Sub_[Government_Propos
ed_Redactions].pdf
Hey
We owe Judge Nathan a letter tomorrow about our views on three of Maxwell's subpoena requests. Attached is a draft
response.
For your reference, I've also attached (1) Judge Nathan's order, and (2) the letters on the subject from Maxwell and Boies
Schiller.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00022516


c1: EFTA00023356
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023356.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
)"
Subject: FW: 20cr330, US V. Maxwell
Date: Fri, 19 Nov 2021 18:32:58 +0000
Attachments: 20cr330_Temp_Sealed_Mem._Op_&_Order_11.19.21.pdf
Sealed opinion on MV-3.
From: Nathan NYSD Chambers
Sent: Friday, November 19, 2021 1:30 PM
To: Jeff Pagliuca
>; Laura Menninger
is
bcsternheim_mac.com
is
)
>;
)
>;
(USANYS)
is
Subject: 20cr330, US V. Maxwell
Counsel:
Per this Court's Order at Dkt. No. 477, please see the attached Memorandum Opinion & Order.
Please confirm receipt.
Sincerely,
Chambers of the Hon. Alison J. Nathan
EFTA00023356


c1: EFTA00020622
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020622.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: BOBBI C STERNHEIM
To:
(USANYS)"
Cc:
)"
=
i
, Christian Everdell
Laura Menninger
, Jeff Pagliuca
Subject: Re: [EXTERNAL] Proposed Jury Questionnaires
Date: Sat, 09 Oct 2021 22:00:23 +0000
Attachments: JOINT_Proposed_Jury_Questionnaire_.docx, ATT00001.htm;
JOINT_Proposed_Voir_Dire_Sent_.docx;ATT00002.htm
Joint Proposed Jury Questionnaire and Voir Dire Questions attached.
Regards-
Bobbi
EFTA00020622


c1: EFTA00022177
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022177.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(
)"
Subject: RE: Decision on motion to strike
Date: Sun, 07 Nov 2021 15:12:38 +0000
Will do!
From:
(
)
Sent: Sunday, November 7, 2021 10:06 AM
To:
)
Subject: RE: Decision on motion to strike
Let's put this language in our letter! Maybe in the paragraph I added at the end about checking ID's at the door? I think
this is an important point.
First, as the Indictment itself makes clear, the defendant's and Epstein's interactions with Minor Victim-3 were part
of a broader scheme and agreement to entice and transport minor victims with intent to commit illegal sex acts.
Even if Minor Victim-3 was not ultimately transported as a minor, the core of a conspiracy is an agreement to
engage in criminal conduct; there is no legal requirement that the agreed upon crime be completed.
Because a conspiracy does not require the completion of a substantive crime, it does not matter whether Minor
Victim-3 was ever in fact transported as a minor, or whether the elements of the substantive crimes of
transportation an enticement are satisfied as to her. See Salinas, 522 U.S. at 65.
From:
Sent: Sunday, November 7, 2021 10:00 AM
To:
(
)
Subject: RE: Decision on motion to strike
Sure thing. The discussion starts on page 184 of the PDF (157 of the pagination).
From:
(
)
Sent: Sunday, November 7, 2021 9:58 AM
To:
)
Subject: RE: Decision on motion to strike
thanks, would you mind also sending me our brief on this?
From:
Sent: Sunday, November 7, 2021 9:49 AM
To:
(
)
Subject: Decision on motion to strike
Hey
Attached is Judge Nathan's first decision denying the pretrial motions. The (very brief) discussion of MV-3 starts on page
26.
Thanks,
EFTA00022177

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00022178


c1: EFTA00023387
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023387.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Letter to AJN re prosecution team
Date: Fri, 25 Jun 2021 15:33:02 +0000
Attachments: 2020-10-07_GM_letter_to_Judge_Nathan_re_discovery_from_other_agencies_(FINAL).pdf
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00023387


c1: EFTA00021375
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021375.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: Motions to Suppress
Date: Sat, 20 Feb 2021 23:02:03 +0000
Embedded: RE: _Motions_to_Suppress.msg
Sender:
Subject: RE: Motions to Suppress
Message-Id:
<DM2P110MB012196CAFC53849BE6AC2BDB89839@DM2P110MB0121.NAMP110.PROD.OUTLOOKO
OM>
To:
EFTA00021375


c1: EFTA00020535
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020535.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
)"
Cc:
(USANYS)
Subject: DAILY BEAST: Manhattan D.A. Cy Vance Finally Got Harvey Weinstein, but He's Still Letting
Women Down
Date: Fri, 06 Mar 2020 15:28:01 +0000
Manhattan D.A. Cy
Vance Finally Got
Harvey Weinstein, but
He's Still Letting Women
Down
The prosecutor who says in 2020 that "rape is rape and sexual assault is sexual assault,"
signed a memo on behalf of NY's DAs in 2013 opposing a bill that would've made that so.
ALEXIS GRENELL
Updated Mar. 06, 2020 7:00AM ET / Published Mar. 05, 2020 4:54AM ET
Marissa Hoechstetter was sitting at her desk on the morning of June 28, 2018, when a blind number
appeared on her cell phone. She picked up and her stomach dropped: "This is Cyrus Vance calling from
Manhattan."
A week earlier, after repeatedly requesting to speak to the Manhattan District Attorney, Hoechstetter
had had a one-hour conversation with one of his top deputies regarding the obstetrician who'd licked
her vagina and sexually assaulted at least 18 other patients. The conversation was about the settlement
the DA's office reached with Dr. Robert Hadden in 2016 to surrender his medical license and plead
EFTA00020535

=== Page 2 ===
guilty to a single felony count of third-degree criminal sexual act and misdemeanor forcible touching in
exchange for prosecutors agreeing not to prosecute the other crimes they were aware of, or pursue
prison time, even though they had grand jury testimony from victims-including Evelyn Yang-eager
to go to trial. The assistant DA who'd called Hoechstetter-the same one who Vance later said "made a
mistake" in asking to downgrade Jeffrey Epstein's sex offender status in 2011, which a judge denied-
successfully negotiated for Hadden to receive a lesser sex offender status than guidelines indicated,
keeping his name out of a publicly accessible database.
Unsatisfied with both the outcome and the deputy, Hoechstetter continued to send emails requesting
to speak to the man himself. When he finally called, she cut right to the chase: "My biggest issue, and
the thing that I believe matters the most is the discretion that you have." Noting that the public might
not be aware of how many cases get resolved via plea deal as opposed to at trial, she added, "I think
there are people who are negotiated with more frequently."
That's the central issue for #MeToo: Whose humanity counts more? Quid pro quo corruption
sometimes tilts the scales of justice, but perhaps more salient is the institutional sexism that weighs a
man's right to reputational preservation as a factor in determining justice.
When it comes to that, Vance has at times seemed eager to lose, preemptively surrendering his power
in anticipation of even the most ridiculous defense. A senior prosecutor recently told the New York
Times that the Hadden case was "not a slam dunk" because his defense would have exploited the
"serious proof issues" given that pregnant women don't have a clear view of their own genitals. That's
like saying that if a proctologist touches a man with his tongue the patient is an unreliable witness
because he can't see his own rectum.
Hoechstetter shared with me the transcript of her conversation with Vance, which she received in
response to a freedom of information request to his office. The clear motivation for his call, years after
Hadden's case had been settled, was a BuzzFeed story featuring Hoechstetter and drawing national
attention to the case. Over the course of 40 minutes, Vance was respectful but also tone-deaf,
acknowledging how "upsetting" Hoechstetter's assault must have been, as if the miscarriage of justice
is a matter of hurt feelings. Throughout, Hoechstetter was direct and collaborative, while holding
Vance to account for the decision-making in her case. He lamely offered to send someone to speak
about sex crimes at the women's college where she works.
A deputy later described Hoechstetter as "crying toward the end."
Except she didn't.
EFTA00020536

=== Page 3 ===
"I was so proud of myself for not crying," Hoeshstetter told me. "So then when I got the documents and
I saw how they were talking about me, 'who's going to call her back, make her feel heard' or whatever,
and then this note that she was crying at the end really upset me. And I do cry, believe me, but I wasn't
crying then and it felt like this reference that labeled me a victim. 'Oh, that's how you deal with those
people."
Fast-forward to 2020 and Evelyn Yang, no longer just some Manhattan mom but the wife of a
presidential candidate with a megaphone, sounding off on CNN about Hadden and her outrage over
the deal. "It's like getting slapped in the face and punched in the gut," she said. "The DA's office is
meant to protect us, is meant to serve justice, and there was no justice here."
All of sudden Vance is doing more than just placating victims in private phone calls, announcing last
week that the office will reopen Hadden's case.
"We admire the courage of the survivors who have recently shared their stories," a spokesman said.
"Their voices will be heard, and the abuse they suffered will be thoroughly investigated."
Vance has changed his tune on Weinstein too, declaring victory Monday by praising the survivors who
came forward, without ever acknowledging his own failure to prosecute the movie mogul in 2015 when
Ambra Battilana-Gutierrez recorded him admitting and apologizing for assaulting her.
A few days later Vance managed to cede that, "we were looking at that case with 2015 eyes. We weren't
looking at that case with 2019 eyes." The only difference being that five years ago, the then assistant
DA who first interviewed Battilana-Gutierrez (which somehow included asking her if she'd ever been a
prostitute)-and who retired in the middle of the Weinstein trial after much scrutiny-could blow off a
22-year-old crime victim and no one would know or care.
Going on about Weinstein, Vance continued to re-write history, saying, "Rape is rape, and sexual
assault is sexual assault." But back in 2013 he signed a memo on behalf of the District Attorneys
Association of the State of New York opposing a bill that would've made that legally true. Rape in New
York is still defined as vaginal penetration, while forced oral and anal sex is defined as a criminal sex
act requiring only that the prosecution prove genital "contact." The problem came to a head in 2011
when a jury convicted a cop of sexually assaulting Lydia Cuomo, a Bronx teacher on her way to work,
but acquitted him of rape because they weren't sure whether or not he'd actually penetrated her. So
Assemblymember Aravella Simotas, introduced the "rape is rape" bill in 2013 which would consolidate
the crimes under the rape statute and change the elements necessary to prove rape from genital
"penetration" to "contact." Vance's letter argued that it could reduce consecutive sentencing options
for judges, and suggested creating "oral rape" and "anal rape" to address concerns about language.
EFTA00020537

=== Page 4 ===
Seven years later, Simotas is still completely exasperated: "The whole argument about consecutive
sentencing is a red herring. So long as the prosecutors do their job then they can get consecutive
sentences. Changing the definition doesn't change the fact that prosecutors have to do their job. It
doesn't change specific pleading. As long as you explain the elements that you're trying to prove you're
fine. We're not merging the whole code. Just describe the acts and describe the numbers in the penal
code in your charging document."
But just doing the job is exactly where Vance seems to have so much trouble when it comes to powerful
and privileged men, and why it's galling to watch him praise survivors for their willingness to come
forward like they haven't been there all along begging him to do something.
It may be 2020, but he still doesn't get it.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I
Press Office: (212) 637-1020
EFTA00020538


c1: EFTA00020947
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020947.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Re: VW Update draft
Date: Fri, 19 Jul 2019 21:30:14 +0000
You got it, thanks!
Sent from my iPhone
On Jul 19, 2019, at 5:23 PM,
)
wrote:
Hey thanks very much - let's do:
July 19, 2019 update:
On July 18, 2019, a status conference was held in the case of United States V. Jeffrey Epstein, 19 Cr. 490
(RMB). The court announced its ruling that the defendant will be incarcerated pending trial. The next
conference, which is expected to address scheduling and administrative matters, is scheduled for Wednesday,
July 31, 2019, at 11:30 a.m. before the Honorable Richard M. Berman, United States District Judge for the
Southern District of New York, Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New
York, New York, in Courtroom 17B.
thanks again, and have a great weekend!
From:
(USANYS)
Sent: Friday, July 19, 2019 09:01
To:
Subject: VW Update draft
July 18, 2019 update:
On July 18, 2019, the court announced its ruling that Jeffrey Epstein must remain in custody pending trial.
The first pretrial conference in United States V. Jeffrey Epstein, 19 Cr. 490 (RMB) is scheduled for Wednesday,
July 31, 2019, at 11:30 a.m. before the Honorable Richard M. Berman, United States District Judge for the
Southern District of New York, Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New
York, New York, in Courtroom 17B.
Sent from my iPhone
EFTA00020947


c1: EFTA00020991
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020991.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 20-3061 United States of America V. Maxwell "Appendix FILED"
Date: Thu, 24 Sep 2020 23:49:28 +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 09/24/2020
Case Name: United States of America V. Maxwell
Case Number: 20-3061
Document(s): Document(s)
Docket Text:
APPENDIX, volume 1 of 2, (pp. 1-123), on behalf of Appellant Ghislaine Maxwell, FILED. Service date
09/24/2020 by CM/ECF.[2938280] [20-3061]
Notice will be electronically mailed to:
Ms.
, Assistant U.S. Attorney:
Ty Gee, -: tgee@hmflaw.com, sklipp@hmflaw.com, nsimmons@hmflaw.com, nhickam@hmflaw.com,
amacphail@hmflaw.com
Adam Mueller, -: amueller@hmflaw.com, sklipp@hmflaw.com, nsimmons@hmflaw.com
Laura Menninger, -: lmenninger@hmflaw.com
Gerard Whidbee, Deputy Clerk: Gerard_Whidbee@ca2.uscourts.gov
Notice will be stored in the notice cart for:
Gerard Whidbee, Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Appendix FILED
Original Filename: Appendix Vol. 1 (001-123) PUBLIC FINAL.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=09/24/2020] [FileNumber=2938280-0]
EFTA00020991

=== Page 2 ===
[5cbbb7d70b77592e8a656e38a168593487f4870b5e1154818863dd5ec1c3e4b9e7dc5f10434f8f7a69be7e427d29f
40cdbf3c927fb0424875cfdd5160c6457fe]]
EFTA00020992


c1: EFTA00022511
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022511.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
STATE
STATES
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
May 3, 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 discovery materials
are stamped with control numbers SDNY_GM_02753399 through SDNY_GM_02753431.
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. An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
SDNY GM 02753399
SDNY GM 02753431
Photographs
Confidential
EFTA00022511

=== Page 2 ===
Page 2
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,
AUDREY STRAUSS
United States Attorney
by:
Assistant United States Attorneys
EFTA00022512


c1: EFTA00020625
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020625.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Fwd: Epstein
Date: Thu, 25 Jul 2019 02:29:07 +0000
See below. I'm not sure, as they plan to report it, how much we could push back but happy to discuss if you
disagree.
Sent from my iPhone
Begin forwarded message:
From
Date: July 24, 2019 at 10:25:31 PM EDI
To:
Cc
Subject: Epstein
NBC 4 will run a story about Epstein tonight at 11-that he was either attacked or attempted to hurt himself.
National NBC will pick it up tonight/tomorrow. I declined to comment and didn't confirm anything.
EFTA00020625


c1: EFTA00021065
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021065.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Emerald Coast Crime Stoppers
P3 INTEL
EMERALD COAST
CRIME
Confidential
STOPPERS
Fort Walton Beach, Florida 32549-2335
Law Enforcement Use Only
850-863-TIPS
8
emeraldcoastcrimestoppers.com
Offense Type: Sexual Assault
Tip ID: 214-W14227
Delivered To: Crestview Police Department
Created: 2019/08/23
Follow-Up By: 2019/09/22
Time: 1:29 PM
Narrative
is listed as a Passenger on Ebstien's plane August 1, 1997. The flight log from Case 18-
2868 Document 278 08/09/2019 page 341 of 648
General Information
Offense Type: Sexual Assault
City, State (required): Crestview, FL
How did you hear about our program? Internet
Links to any online news stories you are reporting in reference to. (copy/paste the URL if
possible):
Case 18-2868, Document 278. 08/09/2019. 2628230. Page341 of 648
INVOICE
of
Bereats, Processions,
-
I |
- Lanings
IVH
-
1
61159B
N908JE
FBI
TEB
99
10
"
11
CMH
SAF
999
1/1
20
7
16
11.
#
PBISOF
PSI
3
22
--
DFW
How
30
23
14
M
TEB
HPN
30
24
-
:
DFW
cos
3
13
C-421B
N908GM
ZIP
THE
57
4/4
7
15
#
$
200
50
1/1
2
PLU
-
5
SAP
ZOR
St
+
9
61159B
N90836
TVC
kirt.
27
10
"
"
TEB
was
13
IN
-
PBI
CONSIDENTIAL
TGB
1019
17
"
POI
MVY
$
25
17
$
MVY
TEB
you
1/1
1
20
,
TEB
SAF
F17
39
23
$
15
SAF
TEB
35
w
24
un
"
TEB
FOR
my
i/i
S
24
M
=
FOR
MVY
4
25
"
MVY
PBI
Wa
1/1
26
15/
14
396
David Rodge
brint
I
0690
70089
Please use the Tip ID 214-W14227 along with the Disposition ID number 4404229 when completing the
disposition form located at https://www.p3tips.com/dispo.
EFTA00021065


c1: EFTA00022170
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022170.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
U.S Department of Justice
Certification of Identity
FORM APPROVED OMB NO. 1103-0016
EXPIRES 10/31/13
Privacy Act Statement. In accordance with 28 CFR Section 16.41(d) personal data sufficient to identify the individuals submitting requests by
mail under the Privacy Act of 1974, 5 U.S.C. Section 552a, is required. The purpose of this solicitation is to ensure that the records of individuals
who are the subject of U.S. Department of Justice systems of records are not wrongfully disclosed by the Department. Requests will not be
processed if this information is not furnished. False information on this form may subject the requester to criminal penalties under 18 U.S.C.
Section 1001 and/or 5 U.S.C. Section 552a(i)(3).
Public reporting burden for this collection of information is estimated to average 0.50 hours per response, including the time for reviewing
instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of
information. Suggestions for reducing this burden may be submitted to the Office of Information and Regulatory Affairs, Office of Management
and Budget, Public Use Reports Project (1103-0016), Washington, DC 20503.
Full Name of Requester
I
Michael C. Miller
Citizenship Status
2 United States
Social Security Number 3
Current Address
1114 Avenue of the Americas, New York, NY 10036
Date of Birth
Place of Birth
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct, and that I am the person
named above, and I understand that any falsification of this statement is punishable under the provisions of 18 U.S.C. Section 1001 by a fine of
not more than $10,000 or by imprisonment of not more than five years or both, and that requesting or obtaining any record(s) under false
pretenses is punishable under, the provisions of 5 U.S.C. 552a(i)(3) by a fine of not more than $5,000.
Signature 4
Date
8/23/2019
OPTIONAL: Authorization to Release Information to Another Person
This form is also to be completed by a requester who is authorizing information relating to himself or herself to be released to another person.
Further, pursuant to 5 U.S.C. Section 552a(b), I authorize the U.S. Department of Justice to release any and all information relating to me to:
Print or Type Name
1
Name of individual who is the subject of the record(s) sought.
2
Individual submitting a request under the Privacy Act of 1974 must be either "a citizen of the United States or an alien lawfully
admitted for permanent residence," pursuant to 5 U.S.C. Section 552a(a)(2). Requests will be processed as Freedom of Information Act
requests pursuant to 5 U.S.C. Section 552, rather than Privacy Act requests, for individuals who are not United States citizens or aliens
lawfully admitted for permanent residence.
3
Providing your social security number is voluntary. You are asked to provide your social security number only to facilitate the
identification of records relating to you. Without your social security number, the Department may be unable to locate any or all records
pertaining to you.
4
Signature of individual who is the subject of the record sought.
FORM DOJ-361
EFTA00022170


c1: EFTA00023097
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023097.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA
:
NOLLE PROSEQUI
:
-v.- -
:
19 Cr. 830 (AT)
:
TOVA NOEL and
:
MICHAEL THOMAS,
:
:
Defendants.
:
:
X
1.
The filing of this nolle prosequi will dispose of
this case with respect to TOVA NOEL and MICHAEL THOMAS, the
defendants.
2.
On or about November 19, 2019, a grand jury sitting
in this District returned Indictment 19 Cr. 830 (AT), which charged
TOVA NOEL and MICHAEL THOMAS, the defendants, with committing
offenses against the United States, to wit, conspiring to knowingly
defraud the United States and to knowingly make and use a false
writing or document, in violation of 18 U.S.C. $ 371, and knowingly
making and using a false writing or document, in violation of 18
U.S.C. $ 1001.
3.
On or about May 20, 2021, TOVA NOEL and MICHAEL
THOMAS, the defendants, entered into deferred prosecution
agreements with the Government. Under the agreements, prosecution
was deferred for a period of six months during the term of NOEL's
and THOMAS's good behavior, completion of community service, and
EFTA00023097

=== Page 2 ===
satisfactory compliance with the terms of the agreement. The United
States Pretrial Services Office has informed the Government that
NOEL and THOMAS have complied with the terms of the agreement
during the period of deferral, which expired on November 20, 2021.
4. In light of the foregoing, the Government
recommends that an order of nolle prosequi be filed as to TOVA
NOEL and MICHAEL THOMAS, the defendants, with respect to Indictment
19 Cr. 830 (AT).
Assistant United States Attorney
Dated:
New York, New York
November , 2021
2
EFTA00023098

=== Page 3 ===
Upon the foregoing recommendation, I hereby direct, with
leave of the Court, that an order of nolle prosequi be filed as to
defendants TOVA NOEL and MICHAEL THOMAS with respect to Indictment
19 Cr. 830 (AT).
United States Attorney
Southern District of New York
Dated:
New York, New York
November _' , 2021
SO ORDERED:
HONORABLE ANALISA TORRES
United States District Judge
Southern District of New York
Dated:
New York, New York
, 2021
3
EFTA00023099


c1: EFTA00021713
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021713.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: BOBBI C STERNHEIM
Cc:
Subject: Re: Ghislaine Maxwell 02879-509
Date: Fri, 08 Jan 2021 18:15:18 +0000
Good afternoon Bobbi:
As you noted Ms. Maxwell has continuously been produced in advance of
12:30 PM. In addition, I would like to note that while Ms. Maxwell was
produced after the scheduled time (twice), the additional time was
provided to compensate for the delay. Please understand that while we
are working to ensure all inmates are produced for their court and legal
calls, there are institutional emergencies that require additional
assistance, causing staff to slightly deviate from time frames.
Should you request a copy of the incident report, Ms. Maxwell may
provide you with it, however I cannot. I can further assure you that
the daily searches are consistent with BOP Program Statement $ 552.06,
Searches of Housing Units, Inmates, and Inmate Work Areas. It is my
understanding that gloves and masks were recently brought to the unit.
Any further concerns you have indicated will be reviewed and addressed
accordingly if need be.
Thank you for your time and patience in this matter,
BOBBI C STERNHEIM
1/7/2021 9:50 PM
For the past two days, Ms. Maxwell has not been on time for the daily
12:30 VTCs. Yesterday, she arrived at 12:59; today she arrived at
12:47. Until yesterday, Ms. Maxwell appeared in advance of 12:30. We
appreciate
's assistance in facilitating Ms. Maxwell's
appearance, but no explanation has been provided for these delays..
Each delay limits the time Ms. Maxwell can confer with counsel. We hope
this will not be repeated and is not retribution for complaints made by
counsel.
We learned today that the complaint report issued to Ms. Maxwell
earlier this week has now been revised. I renew my request for the
original report and request a copy
of the updated report.
This morning at 6:40 am, the team leader ordered Ms. Maxwell to clean a
toilet, providing a few paper towels,
but no gloves, sending a clear message that Ms. Maxwell should clean
the toilet bare handed, despite having cleaned the toilet the night
EFTA00021713

=== Page 2 ===
before. Gloves were provided only upon request by Ms. Maxwell. Per the
A&O Handbook, sanitation duties commence at 7:30 am for pretrial inmates
(See A&O, p.4). We request that Ms. Maxwell be permitted to perform
sanitation duties in the evening when returned to her isolation cell.
Further, the team leader ordered Ms. Maxwell to clean crumbs from her
bed. Lest she face another charge of being untidy, Ms. Maxwell
attempted to comply but there were no crumbs - just stains on the
blanket issued to her. This is another example of the petty
officiousness displayed by the present team.
The ear searches continue. Routinely, in connection with open mouth
searches, guards run fingers through Ms. Maxwell's hair and behind her
ears, at times before she gets a chance to put on her face mask.These
searches - conducted within 6 inches of Ms.Maxwell's face- continue to
increase her risk of exposure to COVID. The number of daily searches of
Ms. Maxwell, an isolated inmate under constant surveillance by multiple
guards, seems excessive and unnecessarily violative..
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
- 4th Floor
New York, NY 10011
Main:
Cell:
Fax:
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.
EFTA00021714


c1: EFTA00020940
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020940.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
MARTIN G. WEINBERG, P.C.
ATTORNEY AT LAW
20 PARK PLAZA, SUITE 1000
EMAIL ADDRESSES:
BOSTON, MASSACHUSETTS 02116
FAX
NIGHT EMERGENCY:
August 1, 2019
By Electronic Mail
Assistant United States Attorneys
U.S. Attorney's Office for the
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Re:
United States V. Jeffrey Epstein, No. 19-cr-00490
Supplement to Defendant's First Request for Discovery
Dear
We write to supplement our first request for discovery that was electronically mailed to you
on July 26, 2019 that sought the preservation and production of documents relating to the NPA
and issues arising from the NPA. We wanted to particularize certain requests that were
applicable to the United States Attorney's Office (hereinafter "USAO") for Southern District of
Florida and the FBI Office that were working with them as follows:
To request that AUSA
who was the lead prosecutor investigating Mr.
Epstein in 2006-8 produce or in the alternative agree to preserve any and all documents,
communications whether emails from any and all email accounts from which she was sending or
receiving relevant emails, texts, letters, papers, voice messages, tapes or any other information
that:
1. Relate to any investigation and any interviews conducted by the USAO for the
Southern District of Florida and/or the USAO for the Southern District of New York
and FBI agents from either or both offices in 2008 in and around New York City,
including, but not limited to an interview of a
and/or communications
with
any other potential witness,
and any other
EFTA00020940

=== Page 2 ===
representative of any USAO for the Southern District of New York between January 1
- June 30, 2008. This request includes any communications prior to or during AUSA
March 2008 trip to New York and any communications that resulted from
the trip.
2. Relate to her communications with her victim witnesses either directly or through
their counsel wherein she discussed their right to confer with a USAO other than the
Southern District of Florida.
3. Relate to any communications with the USAO for the Southern District of New York
or FBI agents working with them at any time from 2007-2019.
4. Relate to the providing of any investigatory information or evidence to the USAO for
the Southern District of New York or FBI agents working with them at any time from
2007-2019.
Very truly yours,
Reid Weingarten
Martin G. Weinberg
Michael Miller
Martin G. Weinberg, P.C.
Steptoe & Johnson LLP
EFTA00020941


c1: EFTA00020532
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020532.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
(Rev. 01-31-2003)
FEDERAL BUREAU OF INVESTIGATION
Precedence: PRIORITY
Date: 12/06/2006
To: Albuquerque
Santa Fe RA
San Juan
St. Thomas RA
From: Miami
Squad PB-2, PBCRA
Contact: SA
b6
b7c
Approved By:
Drafted By:
Case ID #: 31E-MM-108062 (Pending)
Title: JEFFREY EPSTEIN;
WSTA CHILD PROSTITUTION
Synopsis: To set leads for captioned investigation.
Details: On 07/24/2006 the Federal Bureau of Investigation
(FBI), Palm Beach County Resident Agency (PBCRA), began
investigating Jeffrey Epstein, a part-time resident of Palm
Beach, along with
* PBCRA obtained information from
the City of Palm Beach Police Department (PBPD)
Epstein
Following the receipt of the case files from the PBPD,
PBCRA began interviewing
b6
who reported a similar
b7c
series of events. In particular,
described how contact
b7D
was made via telephone, primarily
340
01.EC
31E- MM- 108062-4
CONFIDENTIAL
SDNY_GM_02050812
EFTA00020532

=== Page 2 ===
To: Albuquerque From: Miami
Re: 31E-MM-108062, 12/06/2006
b6
b7c
b7D
met by Enstein
and some
On most
instances, Epstein
example,
Epstein
During the course of PBPD's investigation, a search
warrant for Epstein's home was obtained and executed. Many of
Epstein's belongings were removed from the home prior to the
execution of the search warrant - for example, the computer
processing units (CPUs) were removed from the house but the
computer screens, keyboards, cords, etc. were left behind. The
missing CPU's were never recovered.
During the search, several telephone message pads were
recovered. These message pads show messages taken from several of
the girls who were interviewed and admitted to engaging in sexual
massages or other sexual activity with Epstein. The messages
contained text such as "I have a female for him" and "has girl
for tonight." Some of the messages from the girls were addressed
to Epstein and others were addressed to
Additional messages recovered during the search
contained text confirming appointment times.
During the PBCRA's investigation,
that
would contact
2
CONFIDENTIAL
SDNY_GM_02050813
EFTA00020533

=== Page 3 ===
To: Albuquerque From: Miami
Re: 31E-MM-108062, 12/06/2006
The investigation revealed that prior to
the flights to Palm Beach,
would contact some of
via cell phone The massage pads show evidence that
b6
b7c
b7D
In addition to the home in Palm Beach, Epstein also
maintains a residence in the U.S. Virgin Islands, New York and
New Mexico.
To date, the PBCRA continues to develop witnesses and
victims from across the United States. Due to the media coverage,
unknown status of the state investigation, vulnerability of the
young female victims, and political influences, the AUSAs and
Case Agents have a target date of January 2007 for indictment.
Based on the ongoing criminal investigation, the PBCRA
is requesting the assistance in establishing Epstein's criminal
activity utilizing interstate commerce and the travel in
interstate commerce to engage in illicit sexual conduct and
prostitution. Prior to conducting captioned leads, it is
requested that the lead agent (s) contact SA
FBI Miami, West Palm RA,
or SA
for investigative direction and
questions.
3
CONFIDENTIAL
SDNY_GM_02050814
EFTA00020534


c1: EFTA00021372
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021372.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Question re Epstein Relativity Database
Date: Wed, 17 Feb 2021 14:19:27 +0000
Embedded: RE:_Question_re_Epstein_Relativity_Database.msg
Sender:
Subject: RE: Question re Epstein Relativity Database
Message-Id:
<BN1P110MB01950E9770EFFC3EC93D650DF8869@BN1P110MB0195.NAMP110.PROD.OUTLOOK.COMI
>
To:
EFTA00021372


c1: EFTA00020659
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020659.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
)"
)"
Cc:
(USANYS) [Contractor]"
(USANYS)"
Subject: RE: BOP statement on Epstein
Date: Thu, 25 Jul 2019 15:48:02 +0000
Inline-Images: image001.png
Also this: ttps://abcnews.go.com/US/nillionaire-convicted-sex-ofender-jeffrey-epstein-put-suicide/story?id-64562129&cidesocial_twitter_abor-
From:
(USANYS)
Sent: Thursday, July 25, 2019 11:43 AM
To:
(USANYS)
>;
(USANYS)
>;
is
is
Cc:
(USANYS)
is
(USANYS)
Subject: BOP statement on Epstein
Just saw this tweet:
EFTA00020659

=== Page 2 ===
Jeffrey Epstein is currently housed at MCC New York and not in a local hospital as has been
reported. As with all inmates, for privacy and security reasons, we do not share information on an
inmate's medical status or their conditions of confinement.
View original
Flag media
Adam Klasfeld Retweeted
Josh Gerstein
@joshgerstein
12m
JUST IN: This statement from the federal Bureau of Prisons re Jeffrey
Epstein. (The MCC is the Metropolitan Correctional Center in
Manhattan.)
3
6
9 000
Public Affairs
U.S. Attorney's Office for the Southern District of New York
Email:
Website: www.justice.gov/usao-sdny
Facebook: https://www.facebook.com/usaosdmy
Follow us on Twitter: @SDNYnews
EFTA00020660


c1: EFTA00021019
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021019.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
20 Cr. 330 (AJN)
V.
:
:
NOTICE OF MOTION
GHISLAINE MAXWELL,
:
Defendant.
:
ORAL ARGUMENT REQUESTED
:
:
X
DEFENDANT GHISLAINE MAXWELL'S NOTICE OF MOTION FOR A SEVERANCE
OF AND SEPARATE TRIAL ON COUNTS FIVE AND SIX OF THE SUPERSEDING
INDICTMENT
(Pretrial Motion # 5)
PLEASE TAKE NOTICE that, upon the accompanying memorandum of law, Defendant
Ghislaine Maxwell, through counsel, hereby moves for a severance of and separate trial on
Counts Five and Six of the Superseding Indictment.
Dated: January 25, 2021
New York, New York
EFTA00021019

=== Page 2 ===
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone: 212-243-1100
Attorneys for Ghislaine Maxwell
1
EFTA00021020


