# docs_fts_content

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=== Page 1 ===
Event: Call w/ SDNY re: discovery, Epstein investigation
Start Date: 2020-10-23 15:00:00 +0000
End Date: 2020-10-23 15:30:00 +0000
Organizer:
Location:
Class: X-PERSONAL
Date Created: 2020-10-22 17:07:46 +0000
Date Modified: 2020-10-22 17:07:46 +0000
Priority: 5
DTSTAMP: 2020-10-22 17:01:44 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00028476


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=== Page 1 ===
From: Gloria Allred
To:
)"
Cc:
)"
Subject: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein.
She is willing to fly to New York for the victim meeting on Oct. 23. May I call you at 5:45
P.M. to discuss ?
Date: Fri, 18 Oct 2019 21:02:17 +0000
Inline-Images: image001.jpg; image002.png
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
323-653-6530
www.amglaw.com
www.gloriaallred.com
ALLRED. MAROKO & GOLDBERG
2019
Best Lawyers
Martindale-Hubbell
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT 323-653-6530. Thank you.
EFTA00028804


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc: Christian Everdell
Laura Menninger
Jeff Pagliuca
Subject: U.S. V. Maxwell S2 20 Cr. 330 (ALN)
Date: Thu, 08 Apr 2021 02:25:25 +0000
Attachments: Reply_to_Govt_MDC_4-6_Letter.pdf;, ATT00001.htm
Good evening-
Attached is a courtesy copy of today's ECF filing.
Regards-
Bobbi
EFTA00029236


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
(USANYS)"
Cc:
(USANYS)"
)"
Subject: RE: US V. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
Date: Thu, 22 Apr 2021 19:06:28 +0000
Attachments: 2021-04-22_Govt_letter_re_GM_request_for_adjournment_v3.docx.rd.docx
Thanks
this is well done, and my edits are attached. As you'll see, I suggested
Happy to look at another version before filing, thanks very much.
From:
Sent: Thursday, April 22, 2021 1:32 PM
To:
is
(USANYS)
is
(USANYS)
Cc:
(USANYS)
>;
Subject: RE: US V. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
Draft response attached.
From:
Sent: Thursday, April 22, 2021 12:14 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
(USANYS)
Subject: FW: US V. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
FYI. Our response is due at 5 today.
From: Laura Menninger
Sent: Thursday, April 22, 2021 11:22 AM
To:
Cc:
is
is
(USANYS)
is
>; ; Jeff Pagliuca
is
>; 'Bobbi Sternheim
(
)'
>; Nicole Simmons
Subject: US V. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
Judge Nathan -
Pursuant to this Court's Order of April 20, 2021 (Dkt. 221), attached please find counsel's Letter Motion for an
Adjournment of the trial.
Counsel for Ms. Maxwell request redaction of their other clients' names and case numbers from this Letter Motion
pursuant to Rule of Professional Conduct 1.6 which prohibits lawyers from revealing confidential information related to a
client even where that information is publicly available. See In Re. Anonymous, 654 N.E. 2.d. 1128 (Ind. 1995) (lawyer
violated Rule 1.6 by disclosing information relating to representation of client, even though information "was readily
available from public sources and not confidential in nature"); In re Bryan, 61 P.3d 641 (Kan. 2003) (lawyer violated Rule
EFTA00027165

=== Page 2 ===
1.6 by disclosing, in court documents, existence of defamation suit against former client); State ex rel. Okla. Bar Ass'n V.
McGee, 48 P.3d 787, 791 (Okla. 2002) (a lawyer's duty of confidentiality attaches "to all information relating to the
representation, whatever its source").
Upon direction of the Court, counsel will file either the redacted or unredacted version of this letter on the public docket.
Best regards,
Laura Menninger
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
EFTA00027166


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=== Page 1 ===
From:
To:
Subject: FW: Request from The Daily Beast.
Date: Fri, 25 Oct 2019 18:10:28 +0000
From:
Sent: Friday, October 25, 2019 2:09 PM
To:
Cc:
Subject: FW: Request from The Daily Beast.
Most of this is pretty dumb, just running by you before declining on all.
From: Pervaiz Shallwani <pshallwani@gmail.com>
Sent: Friday, October 25, 2019 12:23 PM
To:
Subject: Re: Request from The Daily Beast.
One more if you can give guidance:
We were told
1. the representatives from SDNY also worked to debunk conspiracy theories, which the victims have
encountered online, related to Epstein's jailhouse suicide in August.
2. prosecutors continue to battle wild speculation on how the 66-year-old Epstein died, along with rumors that
he isn't dead at all.
3. "The U.S. Attorney's Office wanted to put to rest some of those conspiracy theories-that he was killed, that
he's still alive, there are people still talking about that. There are still people that think this was an absolute ruse
and he's sitting pretty in another part of the world."
4. Prosecutors wanted to meet with some of the victims to discuss whether or not they could be potential
witnesses in that ongoing investigation
On Fri, Oct 25, 2019 at 12:06 PM Pervaiz Shallwani <pshallwani@gmail.com> wrote:
Hey,
A few things we chatted about:
1. If you can give a nod on any of this: Representatives from the Manhattan U.S. Attorney's Office traveled to
Florida for an Oct. 15 meeting with several of Epstein's victims and their counsel. The staffers, who worked in
the victim services unit, held a similar meeting in New York on Oct. 23.
2. Where do things stand with forfeiture with Epstein's assets?
3. Dawn's new email address?
4. ANYTHING that can be done about getting emails from you guys. I have given 2 email addresses and the
only email I receive is the guidance email in the morning to one of my email accounts.
Thanks.
Pervaiz Shallwani
Brooklyn, NY 11213
EFTA00028289

=== Page 2 ===
- Senior Editor, Writer at The Daily Beast.
Former Food Writer - Restaurant critic & Host of "Feed Me" TV at Newsday; Reporter WSJ; co-host of The NY
Chow Report
Pervaiz Shallwani
Brooklyn, NY 11213
Facebook, Twitter, Instagram: @Pervaizistan
- Senior Editor, Writer at The Daily Beast.
Former Food Writer - Restaurant critic & Host of "Feed Me" TV at Newsday; Reporter WSJ; co-host of The NY
Chow Report
EFTA00028290


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=== Page 1 ===
From:
To:
Subject: RE: United States V. Ghislaine Maxwell
Date: Sun, 28 Nov 2021 17:12:33 +0000
Thank you!
From:
Sent: Sunday, November 28, 2021 11:01 AM
To:
Subject: FW: United States V. Ghislaine Maxwell
Good luck!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, New York 10007
Tel:
From:
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>; USANYS-CRIMINAL PARALEGALS <USANYS-
CRIMINALPARALEGALS@usa.doj.gov>; USANYS-INVESTIGATORS <USANYS-INVESTIGATORS@usa.doj.gov>
Cc
Subject: United States V. Ghislaine Maxwell
opens
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
EFTA00029418

=== Page 2 ===
One Saint Andrew's Plaza
New York, NY 10007
EFTA00029419


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Cc:
)"
)"
)"
Subject: NTW 3500
Date: Mon, 27 Sep 2021 02:47:20 +0000
Attachments: 2021.10.11_Maxwell_Letter_re
Final.docx;
2021.10.11_Maxwell_Letter_re
Final.docx
,
Can you please (1) PDF the attached letters; (2) place the PDF of the letter re:
in each of their NTW
3500 folders; and (3) put the letter re
in a NTW 3500 folder (I believe we do not yet have a NTW 3500 folder for
). You can move these into Production 3 as
and I will start that review early this week. Let me
know if you have any questions.
Thanks!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00027578


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=== Page 1 ===
From:
To:
Subject: draft
Date: Thu, 20 Aug 2020 05:25:24 +0000
Attachments: 020-08-19,_GM,_letter_to_Judge_Nathan_re_unsealing_materials_1.docx
EFTA00028552


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=== Page 1 ===
From:
To:
Subject: disclosure letter (today)
Date: Mon, 13 Sep 2021 14:20:21 +0000
Attachments: 2021.09.13_Maxwell_Discovery_Letter.docx
See attached for your review. Should we be omitting
name from the signature block for letters she's not
reviewing? Probably, right?
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00027420


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=== Page 1 ===
From:
"
To:
Cc:
Subject:
Date: Thu, 26 Aug 2021 15:44:09 +0000
Attachments:
Cross_Ideas.docx
l'll print also.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00027387


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=== Page 1 ===
From: Alex Conlon
To:
)"
Cc: Roberta Kaplan
Subject: Transcript from yesterday's conference
Date: Thu, 12 Dec 2019 23:33:57 +0000
Attachments: Tr_12.11.19_Conference_Doe_v_Indyke_et_al,_19-cv-8673.pdf
Hi there,
Attached is the transcript from yesterday's conference that Robbie described in the call today.
Take care,
Alex
Alex Conlon I Kaplan Hecker & Fink LLP
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00027883


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=== Page 1 ===
From:
To:
Subject: 21-58 United States of America V. Maxwell "Defective Document CURED"
Date: Thu, 01 Apr 2021 14:55:35 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 04/01/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Docket Text:
CURED DEFECTIVE NOTICE OF APPEARANCE AS ADDITIONAL COUNSEL [33], on behalf of Appellant
Ghislaine Maxwell in 21-58, 21-770, FILED. [3068192] [21-58, 21-770]
Notice will be electronically mailed to:
Notice will be stored in the notice cart for:
Quality Control 1
EFTA00027356


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=== Page 1 ===
From:
To:
"
Cc:
"
Subject: RE:
V. Maxwell, et al., 15 Civ. 7433 (RWS)
Date: Tue, 05 Feb 2019 18:40:39 +0000
Importance: Normal
Attachments: 2019-02-05,_JE,_unsealing_application_and_order,_15_Civ_7433_(RWS).pdf
To the Chambers of Judge Sweet:
Please see the attached application and proposed order in connection with the above-captioned case, which the
Government respectfully requests be filed under seal for the reasons explained in the application.
Respectfully,
EFTA00029464


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=== Page 1 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
JPMorgan Chase Bank, N.A.
National Subpoena Processing Center
Attn: Records Custodian
7610W Washington Street / INI-4054
Indianapolis, IN 46231
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before
the GRAND JURY of the people of the United States for the Southern District of New York, at the United States
Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the
Southern District of New York, at the following date, time and place:
Appearance Date:
August 30, 2019
Appearance Time: 10:00 a.m.
to testify and give evidence in regard to an alleged violation of :
18 U.S.C. §§ 201, 371, 1001, 1346, 1519, 2
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
Please see attached rider. Personal appearance is not required if the requested records are (1) produced on or
before the return date to Assistant U.S. Attorney
of the United States Attorney's Office, 1 St.
Andrew's Plaza, New York, NY 10007. Tel:
, email:
, and (2)
accompanied by an executed copy of the attached Declaration of Custodian of Records. Ref No. 2019R01059.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
August 17, 2019
Geoffey
S.
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
DEPARTMENT IIIIII UNITED COURT
Assistant United States Attorney
FOR
One St. Andrew's Plaza
THE
RICT
YORK
New York, New York 10007
or
NEW
Telephone:
Email:
rev. 02.01.12
EFTA00027209

=== Page 2 ===
RIDER
(Grand Jury Subpoena to JPMC, dated August 17, 2019)
Ref. No. 2019R01059
REQUEST:
For the following account, and any other account controlled by the account holder of one of the below
accounts:
Please provide any and all documents, to include, but not limited to those identified below, for the period
January 1, 2019 until the present:
a. Account opening documents, including applications and signature cards;
b. Records of account holders for debit and credit cards liked to the accounts;
c. Account statements and ledgers;
d. Images of checks (both front and back) deposited in account;
e. Images of canceled checks (both front and back) drawn on account;
f. Images of cashier's checks (both front and back) and depositing bank account information;
g. Account deposit slips, withdrawal slips, debit & credit memos, and cash tickets;
h. Detailed wire transfer records, ACH transfer records (including routing/account numbers funds
transferred to/from), money orders, and traveler's check records;
i. All credit card and line of credit records, including, but not limited to: applications, monthly
statements, billing slips, and records evidencing the source of payment (copies of checks, ACH
records (including routing/account numbers funds transferred to/from), or cash received slips);
j. Customer information associated with the account, including name(s), address(es), telephone
number(s), e-mail address(es), and any other identifying or contact information.
INSTRUCTIONS FOR PRODUCTION OF DOCUMENTS:
1. All transactions-based information, include wire and ACH transfers, withdrawals/deposits,
charges/payments, and bank account activity should be provided in electronic spreadsheet
format (either Microsoft Excel or similarly compatible format). Specifically:
a. For wires and other types of transfers, the account holder name, account number, and bank
name of both the originator and beneficiary of the transaction should be clearly stated in
separate fields.
b. Cash and check transactions should be indicated within a transaction type field.
i. Check transactions should include the name of the payee in the recipient
field. Additionally, check images should be attached in graphic data files in a commonly
readable, non-proprietary format with the highest image quality maintained, and named in
a manner that uniquely associates them with the relevant transaction record(s).
ii. Cash withdrawals should be indicated with CASH written in the recipient field.
EFTA00027210

=== Page 3 ===
iii. Cash deposits should be indicated with CASH written in the sender/originator field.
c. Field headers should be included for each column of data, and a data dictionary or other
explanation of the contents of each column provided.
2. Where more than one account is being requested, each account's transaction records should be
returned in a separate file.
3. All document images are to be produced in electronic PDF format. Where images of checks,
deposit slips, withdrawal slips, or cash tickets are being produced, they should be produced no
more than two per page.
4. In lieu of an appearance you may comply with this subpoena by providing the requested
information, along with a business records certification pursuant to Fed. R. Evid. 803(6) to
Assistant U.S. Attorney
of the United States Attorney's Office, 1 St. Andrew's
Plaza, New York, NY 10007. Tel:
, email:
EFTA00027211

=== Page 4 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the
business named below, or I am otherwise qualified as a result of my position with the business named below to
make this declaration.
I am in receipt of a Grand Jury Subpoena, dated August 17, 2019, and signed by Assistant United States
Attorney
,
requesting specified records of the business named below. Pursuant to Rules 902(11) and
803(6) of the Federal Rules of Evidence, I hereby certify that the records provided herewith and in response to the
Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from
information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
-
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any form, of acts,
events, conditions, opinions, or diagnoses. The term "business" as used in Fed. R. Evid. 803(6) and the above declaration
includes business, institution, association, profession, occupation, and calling of every kind, whether or not conducted for
profit.
EFTA00027212

=== Page 5 ===
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
August 17, 2019
Re:
Grand Jury Subpoena
This letter describes the procedure for requesting reimbursement for subpoenaed records.
12 CFR part 219 (subpart A), issued by the Board of Governors of Federal Reserve System under section
1115 of the Right to Financial Privacy Act (12 U.S.C. $ 3415), sets the rates and conditions for reimbursement of
costs directly incurred by financial institutions in assembling or providing customer financial records to a
government authority pursuant to the Act. No costs are reimbursable if the records are those of a corporation or a
partnership comprised of more than five individuals.
If reimbursement is authorized, and the estimated billing to the government will exceed $500, advance
permission is necessary from
at
If the subpoenaed records indicated on the rider are eligible for reimbursement, please complete section B
of the enclosed form OBD-211, which will serve as your invoice, and return it with a copy of the subpoena to the
following address:
U.S. Attorney's Office - SDNY
Accounts Payable
86 Chambers Street, 3rd floor
New York, NY 10007
(212) 637-2662
Please send your invoice to the above address within 60 days of the submission of the subpoenaed records.
If no invoice is received within 120 days, funds will not be available to pay the invoice.
Thank you for your cooperation in this matter.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
By:
/s/
Assistant United States Attorney
Enclosure: OBD- 211
EFTA00027213


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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
Subject: FW: Subpoena to Interlochen Center for the Arts
Date: Thu, 13 May 2021 20:53:41 +0000
Attachments: Subpoena_Response.pdf
Reading through this now, but: you should take a look at the photos enclosed with her 1994 application. I definitely
anticipate we'll mark this as an exhibit.
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, May 13, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Attached is what went in the mail today.
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: Wednesday, May 12, 2021 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on this.
Thanks,
EFTA00029315

=== Page 2 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Monday, April 26, 2021 10:32 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm working on it and hope to have it complete and ready in the next couple of days.
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: Monday, April 26, 2021 at 9:28 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Could you please let us know when you expect to produce these materials?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, March 26, 2021 5:33 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Just confirming receipt. Also, I'm hopeful that we can have everything gathered by April 12th. However, l'll be out of the
office for the next week so it might be delayed. Will that be a problem?
EFTA00029316

=== Page 3 ===
In addition, and just for confirmation's sake, you are ok that we will make reasonable efforts to notify the
parents/students of the subpoena prior to compliance with the subpoena correct?
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, March 26, 2021 at 3:37 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
Thanks again for taking the time to speak with me this morning. As we discussed, I'm attaching a subpoena for additional
student records.
Thank you,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Sounds good. Yes, that is the best number.
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
EFTA00029317

=== Page 4 ===
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, March 25, 2021 at 4:40 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Thanks so much-let's plan to talk at 9:30 tomorrow morning, if that works for you. Is this the best number to reach you
then: 231-947-0400
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:32 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm available between 9am and 10am, and then again after 11am.
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, March 25, 2021 at 3:41 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
EFTA00029318

=== Page 5 ===
Hi Jeff,
Hope you're doing well. Are you available for a quick call tomorrow morning?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, January 7, 2021 11:10 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
231-947-0400
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, January 7, 2021 at 10:37 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff- what is the best number to reach you this morning? Thanks.
Sent from my iPhone
On Jan 5, 2021, at 3:21 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me.
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
EFTA00029319

=== Page 6 ===
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: Monday, January 4, 2021 at 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
That would be great, thanks. Would Thursday at 11:30 work for you?
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Sure. Does Wednesday or Thursday morning work?
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: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Are you available for a call sometime in the next few weeks? We have one or two follow up
questions that would be helpful to talk through.
Thanks,
EFTA00029320

=== Page 7 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, December 30, 2020 2:37 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
Sorry about the delay. Interlochen doesn't have any other documents regarding tuition payment information or
payments by Epstein or Epstein entities.
Let me know if you have any other questions.
Thanks,
Jeff Jocks
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: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
From:
Sent: Monday, November 16, 2020 3:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)
is
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
EFTA00029321

=== Page 8 ===
Hope you're doing well. I'm following up on our conversation from earlier this month to see if you have any updates on
the categories of documents we discussed.
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 11:15 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
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:
)"
i
(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 Maurene -
EFTA00029322

=== Page 9 ===
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
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
EFTA00029323

=== Page 10 ===
Hi Jeff,
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
H
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: "
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com>, "Donnini, George B." <donnini@butzel.com>
EFTA00029324

=== Page 11 ===
Cc:
)"
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
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.
EFTA00029325

=== Page 12 ===
From:
"
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
)"
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
EFTA00029326


c1: EFTA00028927
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028927.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
EXHIBIT P
EFTA00028927

=== Page 2 ===
Log
Privilege
Doc
ID
Email Sent Date
Email From
Email To
CC Address
Subject Matter
Type of Privilege
Action
Page Count
Type
Plaintiff has objected that Defendant's requests are overly
broad and unduly burdensome, as individually logging all
privileged responsive documents would be overly
burdensome. Plaintiff contends that requests targeting
such privileged information are not reasonably calculated
to lead to the discovery of admissible evidence, are not
important to resolving the issues, are not relevant to any
party's claim or defense, are not proportional to the needs
of the case, and creates a heavy burden on Plaintiff that
The law enforcement
outweighs its benefit. Therefore, Plaintiff has employed
entity,
The law enforcement entity,
categorical logging pursuant to Local Civil Rule 26.2(c).
Email and letter
David Boies, Stan
David Boies,
This categorical entry is regarding correspondence re the
communications re law
Pottinger, Sigrid
Stan Pottinger, Sigrid
currently ongoing criminal investigation of Defendant and
enforcement
McCawley, Paul Cassell,
McCawley, Paul Cassell, Brad
approx. 57
others.
153
investigation
Brad Edwards
Edwards
Public Interest
Withheld
documents
EFTA00028928


c1: EFTA00027380
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027380.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
Subject: RE: Epstein FOIA Next Steps - Noel Team
Date: Tue, 13 Apr 2021 17:27:44 +0000
Right now I have a call with
at OIG about this case at 10, but I can see if I can move that if 10 is the only time
that works for everyone. Thanks.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 1:27 PM
To:
(USANYS)
>;
(USANYS)
>;
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
Tomorrow morning fairly booked for me, but do have 10-10:30 if that's better for everyone.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 1:26 PM
To:
(USANYS)
V.
(USANYS)
is
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
This afternoon isn't ideal. I can do 6pm if absolutely necessary, but I would prefer any time tomorrow morning.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 1:10 PM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
Doesn't work for me. Could you do 6pm?
Original Appointment
From:
(USANYS)
Sent: Tuesday, April 13, 2021 1:09 PM
To:
(USANYS);
(USANYS);
(USANYS)
Subject: Epstein FOIA Next Steps - Noel Team
When: Tuesday, April 13, 2021 4:00 PM-4:30 PM (UTC-05:00) Eastern Time (US & Canada).
Where:
:
,
please let me know if this time doesn't work
has availability tomorrow as well. Thanks.
Please use dial in
with passcode
EFTA00027380


c1: EFTA00027097
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027097.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: my questions
Date: Mon, 12 Aug 2019 18:32:32 +0000
Let me know if there's guidance you'd like for me to give her, seems like an awfully strong statement?
From: Orden, Erica <Erica.Orden@cnn.com>
Sent: Monday, August 12, 2019 12:53 PM
To:
Subject: my questions
Is it fair to say prosecutors saw the case not only as a way to bring Epstein to justice but as a rebuke to the NPA?
Who is
attorney?
Erica Orden
Reporter, CNN
@eorden
EFTA00027097


c1: EFTA00027884
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027884.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
1
JCB3DOEC
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
2
X
3
JANE DOE,
4
Plaintiff,
New York, N.Y.
5
V.
19 CV 8673 (KPF)
6
DARREN K. INDYKE, et al.,
7
Defendants.
8
X
Conference
9
December 11, 2019
11:30 a.m.
10
Before:
11
HON. KATHERINE POLK FAILLA,
12
District Judge
13
14
APPEARANCES
15
16
KAPLAN HECKER & FINK LLP
17
Attorneys for Plaintiff
BY: ROBERTA KAPLAN
18
ALEXANDRA CONLON
KATE L. DONIGER
19
LOUIS FISHER
20
TROUTMAN SANDERS LLP
Attorneys for Defendants
21
BY: BENNET J. MOSKOWITZ
CHARLES GLOVER
22
23
24
25
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00027884

=== Page 2 ===
2
JCB3DOEC
1
THE DEPUTY CLERK: In the matter of Doe V. Indyke.
2
Counsel, please state your name for the record beginning with
3
plaintiff.
4
MS. KAPLAN: Good morning. Roberta Kaplan for
5
plaintiff from Kaplan Hecker & Fink. I am here with my
6
colleagues Kate Doniger, Alex Conlon, and Louis Fisher.
7
THE COURT: Good morning.
8
MR. MOSKOWITZ: Good morning. Bennet Moskowitz,
9
Troutman Sanders LLP, counsel for the co-executors of the
10
Estate of Jeffrey D. Epstein.
11
MR. GLOVER: And Charles Glover of the same firm.
12
THE COURT: First of all, I thank you very much for
13
your indulgence. As you could see, we did not know until we
14
knew that plaintiff in our prior case did not speak English.
15
He was comfortable with the dates of a conference and not more
16
than that. So I appreciate your patience.
17
Let me begin by noting that I'm surprised we are
18
having this conference, even though I am the one who convened
19
it. And that is because what I thought made sense from an
20
efficiency perspective was to have the discovery assigned to a
21
single magistrate judge, and which is what was done. The
22
reason that I'm having this conference, and Judge Freeman is
23
not, is it does not appear that the discussion of motions to
24
strike or motion practice is occurring in all of the cases.
25
And so for those in which it is happening, those judges have
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00027885

=== Page 3 ===
3
JCB3DOEC
1
decided to talk about it.
2
I'm asking in the first instance to speak with
3
Mr. Moskowitz, unless he wants to pass the mic over to
4
Mr. Glover.
5
Mr. Moskowitz, I had understood, from a very sort of
6
peripheral perspective, that the focus of your clients was on
7
setting up a fund to perhaps fund the settlement of these
8
claims. Am I correct?
9
MR. MOSKOWITZ: That's absolutely correct.
10
THE COURT: I'll ask you to stand only because there
11
is a monitor in front of you.
12
MR. MOSKOWITZ: I prefer it. Thank you. That's
13
absolutely correct. That is still a major focus of my clients.
14
In fact, it's full steam ahead. I understand that, as has been
15
described when we were before Judge Freeman and before then, I
16
understand that the administrators-to-be, Ken Feinberg,
17
,
Camille Biyos, all leading people in the field of
18
claims administration, has been in touch with or have reached
19
out to various plaintiffs' counsel. And the administrators are
20
working on the protocol, which is basically the nuts and bolts
21
of that program.
22
It's our hope and expectation that all plaintiffs will
23
give it a shot. It doesn't require anything in terms of
24
waiving any rights. They can go through the whole claims
25
process, get an independent determination -- the estate doesn't
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00027886

=== Page 4 ===
4
JCB3DOEC
1
control the program administrators or designers -- and if given
2
plaintiff doesn't like that determination, they can say, you
3
know what, I don't like this, I am going back to concentrate on
4
my litigation.
5
I too, although, you know, I'm hoping people come
6
around, and I'm disappointed as of now no one has come to us
7
and said I am going to give it a shot, let's stay the
8
litigation in the meantime. But it's not required. The
9
administrators aren't requiring that.
10
THE COURT: This is the fork in the road where you and
11
I diverge. I would have thought given your focus was on
12
setting up a fund for claims administration you would not be
13
focusing on motions to strike, which to me seemed to be a --
14
not a distraction, but a detour in the path to resolution of
15
the case.
16
MR. MOSKOWITZ: I see. If I can, I gather, but I'll
17
ask the question, your Honor is wondering that based on your
18
Honor's understanding of what the law is, on whether what we
19
are talking about here is, as Ms. Kaplan asserted in her letter
20
a motion to strike, or as I'll gladly briefly go over is
21
actually, no, a motion to dismiss.
22
And the reason we made the motion is because I would
23
have loved to push the time out more. But plaintiff's counsel
24
wasn't willing to do that. We have preserved our rights. A
25
critical threshold issue for us, I have six points to briefly
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00027887

=== Page 5 ===
5
JCB3DOEC
1
touch upon, I'll be very quick, that will address that.
2
But, it's very important to us that we be able to move
3
to dismiss, which is what it is, the punitive damages claims.
4
THE COURT: Okay. But, that wouldn't get rid of all
5
of the claims.
6
MR. MOSKOWITZ: No.
7
THE COURT: I am trying to figure out why expend -- I
8
am not using the term waste -- why expend the resources when,
9
at some point, perhaps, we can have a discussion about whether
10
or not Virgin Islands permits law permits punitive damages or
11
not.
12
I am just trying to understand, because things were
13
going so well, I thought. You've had your initial conference
14
before Judge Freeman, there are discussions that I imagine were
15
going on. There was, I presume, the establishment of protocols
16
for discovery. And this, again, just seems like something that
17
is inconsistent with everything that's been going on before
18
her.
19
So perhaps I need to hear some or all of your six
20
points and I will listen to you.
21
MR. MOSKOWITZ: Sure. Well, plaintiff's counsel
22
generally, not all of them, but plaintiff's counsel here today
23
included has made it clear to us that they are not yet sold,
24
that's my wording, on the program. And unless and until they
25
tell us otherwise, they are moving full steam ahead with their
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00027888

=== Page 6 ===
6
JCB3DOEC
1
litigation. So we are basically having to react to that.
2
In terms of making motions, your Honor is correct,
3
we've again, if we had it our way, we wouldn't have to engage
4
in this practice on either side. We would stay everything.
5
But we're here, and the reason moving to dismiss punitive
6
damages in this case is so important to us and worth the time
7
and energy now we are already halfway there to briefing and
8
having this issue decided is two fold.
9
Number one, the scope of discovery, ever since the
10
2015 amendments, now expressly as I think it did previous to
11
that contemplates that the amount in controversy is directly
12
relevant to the scope of discovery. This is a very different
13
case, from our perspective, because no punitive damages are
14
available than plaintiff, if they do, we think incorrectly
15
believe punitive damages are available.
16
People, as I'm sure your Honor is aware, make very
17
large claims for punitive damages. That's out of the case and
18
should be as a threshold.
19
The second is going to the claims program, or any
20
other settlement because, you know, Judge Freeman asked me
21
this, well, can someone talk to you about settlement separate
22
from the claims program. Absolutely. They all have my phone
23
number. Nothing is off the table. We hope everyone will give
24
that claims program a shot. Why wouldn't you. I don't see
25
why. In the meantime, if someone wants to talk about
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settlement, fine.
2
How can the parties in this case see eye to eye if
3
plaintiffs, again, I think clearly and incorrectly say and we
4
are entitled to X millions punitive versus we are saying we are
5
talking about compensatory damages. Let's have a discussion
6
about that.
7
THE COURT: Let's be clear. Assuming, as you'd like me
8
to do, the exclusion of punitive damages, the claim's not going
9
to be for ten dollars. It is going to be for millions upon
10
millions of dollars. And do you really think the scope of
11
discovery is going to change, given the nature of the damages
12
sought and the nature of the claims raised?
13
MR. MOSKOWITZ: Well, I do -- part of the clarity that
14
I don't have, which I welcome to get, not trying to make my own
15
questions, don't have clarity on how much is plaintiff claiming
16
is owed to her in terms of punitive versus compensatory
17
damages. It's not clear to me from the complaint. I haven't
18
heard that yet, so it's hard for me to answer that question.
19
But, I'm happy to answer questions in the order that your Honor
20
desires.
21
There is one other, I mentioned I had these six
22
points. It Is often the case we don't come in and do things
23
how I want. I want to raise another critical threshold issue
24
that came up entirely because of what was in the contents of
25
plaintiff's counsel's response to my letter, and that is if
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they are correct that USVI law applies, this action is time
2
barred. Every cause of action that is asserted in their
3
complaint says it is timely because of the New York Child
4
Victims Act. Well, it stands to reason that if U.S. Virgin
5
Islands law applies in this case, then the plaintiff cannot
6
avail herself of the New York Child Victims Act. That is
7
certainly something that I also now need to brief, and would,
8
like I said, that's a key threshold issue even more so than
9
punitive damages. There can be no case if there is no New York
10
Child Victims Act applying. It's time barred.
11
THE COURT: Not to put words in your mouth, but what
12
I'm understanding is that you believe your premotion letter is
13
not inconsistent with your desire to have a claims resolution
14
process. It is, rather, something you feel is thrust upon you
15
by the fact that today, not all of the plaintiffs' counsel are
16
interested in participating in the program that you're setting
17
up.
18
MR. MOSKOWITZ: Yes. Let me clarify that, too.
19
That's correct, but various plaintiffs' lawyers have indicated
20
to me that they are interested. In fact, and a big issue
21
before Judge Freeman was various plaintiffs' lawyers reached
22
out to me and others that represent the executors before these
23
actions got filed in the case, certainly before they began in
24
earnest, to say they wanted a kind of claims program. It was
25
something we were already thinking about on our end. This was
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not something that was just thrust out here.
2
I don't want to rehash during Judge Freeman's hearing
3
there was a disagreement about the way it's unfolded, etc., and
4
that's not why we're here.
5
Your Honor is correct, having the final motion to
6
dismiss now, I wish we could put it off for three months and
7
see if the claims program works and save the dockets, but here
8
we are. And again, we think that punitive damages and now
9
again USVI law applies as being time barred. These are key
10
issues we can't avoid. These are straightforward legal issues.
11
These will not be 50-page briefs. The motions I filed in other
12
cases have all been on the concise side I'll call it, which I'm
13
sure is something your Honor would appreciate. This can be
14
done on a relatively short time frame.
15
These are threshold issues. Certainly the time bar
16
aspect, and I still argue the punitives and subject to I'd love
17
to know what is plaintiff asking for in terms of punitive
18
damages.
19
Based on a collective, not in this case, what I've
20
heard from the plaintiffs' side is, for example, there is one
21
case out there where two plaintiffs, not this firm, claim $100
22
million. They don't say what part is which, they don't even
23
allege they were underage at the time of the alleged harms to
24
them, but we have the complaint at the time. We request $100
25
million or another amount to be determined. That tells me we
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need to set clarity where we can on the front end to make
2
things more efficient going forward.
3
THE COURT: Thank you.
4
Ms. Kaplan, I'll hear from you in response.
5
MS. KAPLAN: Yes, your Honor. So, I think I heard
6
Mr. Moskowitz say that various plaintiffs' lawyers are not yet
7
sold on the proposed settlement process.
8
THE COURT: That's the word that was used, yes.
9
MS. KAPLAN: That might be the understatement of the
10
day, your Honor. First of all, there is no fund. In response
11
to questions from the plaintiffs, Mr. Moskowitz responded by
12
saying that no amount of money is actually being set aside by
13
the estate to settle these claims. That is something that is
14
very, very concerning to the plaintiffs. It's one thing to
15
agree to participate in a fund when you know that, say, 300 or
16
400 million of the 577 million in the estate is being set
17
aside. But they have said that no amount is being set aside.
18
They just want to settle claims, presumably, so they can settle
19
as low as possible and have the rest for the estate. That's a
20
huge problem. It is going to be a huge problem for the
21
plaintiffs' lawyers.
22
Number two, as Judge Freeman admonished Mr. Moskowitz
23
when we met, settlement is a two-way street. There has to be
24
consultation. The settlement -- the discussions that
25
Mr. Moskowitz referred to, I was part of those, and I said to
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the estate that the plaintiffs needed to be involved. That
2
these women who, many of whom, like my client, were horribly
3
abused as young children, have to have agency. And they have
4
to help pick the administrator, be involved in who the
5
administrator is. None of that has happened.
6
Mr. Moskowitz and the estate picked Ken Feinberg on
7
their own. There was no consultation with us. We have now
8
asked them to put on an administrator on a panel that the
9
plaintiffs select. We've gotten no answer to that.
10
With all respect, your Honor, I'm someone who has
11
settled cases for decades in this district. This does not look
12
to me like a case that's going to settle.
13
If your Honor would like, I can move on to the merits
14
issues.
15
THE COURT: Please.
16
MS. KAPLAN: With respect to this motion, whether it's
17
styled as a motion to dismiss under 12 (b) (6) or a motion to
18
strike under 12 (f), I've made those motions, I've always made
19
them as 12 (f) motions. I've never won one, but I've made them.
20
However it's styled, your Honor said the fundamental important
21
point here, which is not that it doesn't dismiss one claim, it
22
dismisses no claims. We have compensatory damage sought in
23
connection with all four of our claims. They have no motions
24
to dismiss compensatory damage. They have no motion to dismiss
25
any of the four underlying tort claims.
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For that reason, your Honor, there is really no reason
2
not to get started. We are happy to have a conference with
3
Judge Freeman, but the problem is the cases are in all
4
different kind of configurations. There are many cases that
5
don't require even responses until late January. There are
6
cases with different defendants. There are cases with federal
7
trafficking statutory claims. This is a simple diversity
8
claim, common law claim. We are ready to get started. We
9
don't think we should be delayed.
10
With all respect to the Southern District, the way
11
this has been set up where there is one magistrate but I think
12
at least nine, maybe a dozen different judges now, give the
13
plaintiffs all the disadvantages of consolidation and none of
14
the advantages of consolidation. Because various issues are
15
being decided by various district court judges, most of the
16
judges are deciding pseudonymity. Your Honor has deferred that
17
to Judge Freeman. It's kind of a big mess.
18
We understand that Judge Freeman has jurisdiction over
19
discovery. We would just like to start, and maybe if we could
20
set a trial date today that would help get that underway.
21
THE COURT: I'm not setting a trial date today.
22
MS. KAPLAN: Let me talk about the scope of discovery.
23
I will hereby make representation there is nothing about the
24
damages claim that will affect the scope of discovery.
25
We expect this case will have at most four witnesses.
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Maybe five. Our plaintiff, the two women who booked
2
meetings -- that's not a right term. But massages with
3
Mr. Epstein. I expect both of those women to take the Fifth,
4
so that won't take very long, and maybe two experts.
5
In terms of the documents that we are seeking, your
6
Honor, again, it will be very limited. We don't know if they
7
have written evidence about our client. We understand that
8
these transactions were done in cash. I don't know if they
9
kept records of who he met with when. Obviously, if he has
10
that record, we'd like it. We don't expect a lot of documents
11
from the plaintiff.
12
And I should also add that we have opened a
13
conversation with the U.S. attorney's office for the Southern
14
District who may have one or two documents that corroborate our
15
client's claims. They are thinking about how they can get
16
those to us subject to grand jury requirements. And obviously
17
the minute we get them, we will share them with the estate.
18
The final issue, your Honor, has to do with choice of
19
law and time bar. The issues are distinct. So whether Virgin
20
Islands law applies to issues relating to what you can get from
21
the estate, whether that's an estate choice of law issue, is
22
entirely different from the question of what state substantive
23
law applies to the underlying torts.
24
I think there can be no question that given this
25
happened on the streets of New York City, in his mansion, that
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1
the law, the substantive law of tort applies New York law, and
2
we clearly get the benefit of the New York statute on that.
3
With respect to the estate and whether or not he
4
purposefully availed himself two days before his death of the
5
benefits Virgin Islands law, which he presumably thought was
6
going to be an advantage to Mr. Epstein, and in fact it has
7
been. It is incredibly difficult for us to deal with the
8
Virgin Islands court, to get Virgin Island lawyers to file
9
papers. There are 100 advantages to the estate being in the
10
Virgin Islands.
11
Having sought those advantages, they don't get to pick
12
and choose and say for purposes of the punitive damages, we
13
want New York law to apply. We're happy to brief that issue.
14
Courts in the Southern District in civil cases apply different
15
laws to different issues of cases in a single case all the
16
time. There is nothing out of the ordinary about that, and
17
there is no rule that requires that one state's law applies to
18
all issues in the case, particularly when you have a
19
particularized issue about estate law like this.
20
I am happy to address anything else your Honor would
21
want to address.
22
Couple more points. Again, we don't think that
23
discovery in this case should take very long, given the limited
24
number of documents and witnesses. We would be willing to
25
waive a jury trial, your Honor, to help expedite things. And
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again, we are very much eager to get things to happen here as
2
quickly as possible. Our client has lived with this for many,
3
many years, she's really desirous of putting this behind her,
4
and I'm sure your Honor can appreciate that.
5
THE COURT: Just before you sit down. I am
6
understanding, as you began this discussion, the problems that
7
you see and that your client sees in the process that's been
8
identified by defense. I am assuming you've had the
9
discussions with them, because you've told me that you have,
10
regarding increased plaintiff involvement in the administration
11
process.
12
If they agreed, might you change your mind about the
13
futility or not of the claims administration process?
14
MS. KAPLAN: I think if they were willing to have a
15
panel of administrators, at least one of whom, maybe there
16
would be two, Mr. Feinberg is the one chosen by the plaintiffs
17
and a third neutral, I certainly would be open to
18
participating. But I am not open in participating in something
19
that's been done entirely by them, completely in secret, by
20
someone they chose, and without denominated amounts that they
21
are setting aside.
22
THE COURT: There's two stumbling blocks. One is the
23
composition of the panel and the other is the need for some
24
defined amount.
25
MS. KAPLAN: It is very hard for the plaintiffs to
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1
figure out what they can expect without understanding what the
2
denominator is, if you will.
3
THE COURT: Understood. Thank you. Mr. Moskowitz.
4
MR. MOSKOWITZ: Thank you. Your Honor, it's
5
interesting. First, as to the motion, we think we have a
6
fundamental right to make and intend to make. Plaintiff's
7
counsel does not dispute that under New York law, punitive
8
damages are not available. USVI law appears to me to be in
9
accord with that. By the way --
10
THE COURT: No. Let me understand why you think it's
11
in accord. I found it, I found it an interesting issue. I
12
didn't see much in the way of cases in the Virgin Islands that
13
dealt with the issue. I thought I understood that the Virgin
14
Islands law tends to be accepting of common law and the law of
15
other jurisdictions that doesn't seem to conflict.
16
MR. MOSKOWITZ: What you'll find is many Virgin
17
Islands cases, and I will tell you I'm not -- I can brief it,
18
but I cannot tell you now the current state of Virgin Islands
19
law with respect to restatement. You will find cases,
20
including from as recent as 2009, that refer to the restatement
21
on the issue of punitive damage against an estate, and the
22
restatement as well as the majority of U.S. jurisdictions,
23
because we looked into this, are in accord.
24
THE COURT: So this will be Section 908 and Section
25
926?
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SPEAKER: I believe that's correct. I don't have it
2
in front of me. I'm happy to pull that if I can after I finish
3
speaking. But, there is Hamilton V. Dowson Holding, 51 VI 619,
4
628 (DVI 2009); there is Booth V. Bowen, 2008 WL 220067, at *5
5
(DVI Jan. 10, 2008).
6
Candidly not Supreme Court USVI cases, but they are
7
the authority that you will find on this issue in the USVI, and
8
they are supportive of that restatement position. Which is not
9
surprising. When someone's dead, you are not trying to punish
10
them. Others would argue what about deterrence. The few cases
11
I found work in our favor saying deterrence doesn't work like
12
that. When someone is alive thinking if they die perhaps their
13
estate will be impacted by this. This is not some obscure
14
position. This is statutory law in a lot of places, including
15
New York.
16
In terms of the time issue, plaintiff's counsel also
17
doesn't deny that if U.S. -- if New York law doesn't apply to
18
that issue, this action is time barred. I'm surprised and I
19
agree with Ms. Kaplan, this should be briefed. It should be
20
briefed now. I am surprised to hear that it's routine that you
21
get to pick and choose from one part of the case that X law
22
applies --
23
THE COURT: I think that's an overstatement of what
24
her argument was. I didn't hear the word "routine" mentioned
25
at all. I have had cases, I'm sure you have as well, even
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basic contract cases where there are certain provisions that
2
are subject to one jurisdiction of law and other claims that
3
could be made on the same contract that would be under a
4
different jurisdiction of law.
5
MR. MOSKOWITZ: What I've seen, your Honor, is splits
6
between procedural law and substantive law. We are talking
7
about two very substantive issues here. Availability of a kind
8
of damages and a right to revive a claim under New York
9
statutory law that's part of a new trend but is,
10
notwithstanding that, it relates to a reviving statute of
11
limitations, gives it new vested substantive right to people to
12
bring a claim that was otherwise previously time barred.
13
THE COURT: To be clear, when you call it new trend,
14
I'm sure you mean the law that actually provides for it. It's
15
not like someone just woke up and decided let's do this.
16
MR. MOSKOWITZ: Correct.
17
THE COURT: Do you really think the tort issues in
18
this case would be decided by Virgin Islands law?
19
MR. MOSKOWITZ: No. That's why we were surprised to
20
hear that in the response to our letter, which is why we came
21
here, point number one was going to be that surprised us. But
22
because of that suggestion, we number one need to brief it,
23
because, as I said, and as has been denied, if USVI law applies
24
wholesale or even to the two issues we are talking about, the
25
action is time barred. Certainly that's a threshold issue that
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needs to be decided now.
2
THE COURT: I understand. I wouldn't be -- I wouldn't
3
be so sure that it is time barred.
4
I guess my question is, if you are hellbent on
5
bringing this motion -- that's the legal term --- and it appears
6
that you are, is it your belief that I should not have
7
discovery while the motion is pending because, at most, well,
8
you think possibly that instead of hitting the single of
9
getting rid of punitive damages, you would hit the home run of
10
getting rid of the case in its entirety?
11
MR. MOSKOWITZ: Certainly something we would brief.
12
Having heard it for the first time, in the response to our
13
letter, and not wanting to do something which I don't like when
14
other people do, which is seek leave to submit an unauthorized
15
reply to your Honor, it's something we think needs to be dealt
16
with now. But we think both issues need to be dealt with now.
17
THE COURT: Let's step back. While your motion is
18
being briefed, which, by the way, I haven't allowed just yet,
19
what is the status of discovery?
20
MR. MOSKOWITZ: So, number one --
21
THE COURT: What do you think it should be?
22
MR. MOSKOWITZ: Oh sure. If it is limited, all the
23
more reason not to get going with it now. Nothing is going to
24
change in six weeks that's going to impact the plaintiff's
25
rights. Look, I get it --
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THE COURT: What is the six weeks that you are
2
thinking?
3
MR. MOSKOWITZ: Sorry. That was a ballpark
4
guesstimation, if we're briefing, I don't know how long it will
5
take to brief --
6
THE COURT: You haven't figured out my schedule yet,
7
which is not six weeks, but okay, nice try.
8
MR. MOSKOWITZ: Noted. And some judges look at me the
9
other way if you say three weeks versus nine. Good to know.
10
But in terms of discovery, Magistrate Freeman, number
11
one, has ordered the parties to report back to her on
12
January 10 including about the claims program and discovery.
13
So that issue's to be determined. I am hoping we can come to
14
some agreement. I know Judge Freeman threw out some ideas on
15
the transcript, I don't have that transcript in front of me.
16
She was in good control of that issue.
17
If I can, I'd like to take a brief moment to set some
18
things clear about the claims program. It's the opposite of
19
what plaintiff's counsel has asserted. That's correct, we
20
haven't said only X million is devoted. What we have said in
21
writing numerous times there is no aggregate cap on the amount
22
that the independent administrator can deem appropriate to pay
23
to people. If you say 10 million is in it, then it's 10
24
million spread across however many joined. We are saying, no,
25
we want people to join this program. Everything we are doing
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1
is we want people to join.
2
Choosing Ken Feinberg. Ms. Kaplan did express extreme
3
interest in having one person and one person only who was not
4
Ken Feinberg. We vetted and interviewed many people, including
5
that person. We made our own decision, that's true. Ken
6
Feinberg has impeccable credentials. And this notion of
7
appointing someone to a panel, this is not arbitration or
8
mediation. This is an independent claims program.
9
The estate -- we have no control at the end of the day
10
over when Ms.
,
who is the designer and administrator of
11
the fund, when she makes a determination that I think this
12
person should get X, we can't veto that. We can't impact that.
13
All we can do is, when we hear about a claim, is say here's
14
what we know about this claim that we think you should know
15
about, and Ms.
,
just like she gets whatever evidence
16
claimants make, can do what she wants with it. She can find
17
what we say not important. And she makes a determination.
18
So I am hearing this notion like we put two people,
19
two or three people up there, first of all, it's one. And she
20
is independent. I mean, these people have, that we've
21
selected, and we were so careful about it. I am just shocked,
22
and this is perhaps the only case where I've heard repeated
23
objections to Ken Feinberg being --
24
THE COURT: I know who he is.
25
MR. MOSKOWITZ: Right. So candidly, I hear words get
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1
thrown out. I'm honestly mystified by that. Who else better
2
to ensure a successful claims program. It is not like we went
3
out and hired our cousin. These are the leading people.
4
, not as well known, worked on the 9/11 Fund for
5
many, many years, just left the fund to do this program. She's
6
very compassionate. She cares. They want this program to work
7
and so do we. Various plaintiffs have told me they are
8
interested too.
9
THE COURT: To be clear, you don't have to sell me on
10
it because I'm not participating one way or the other.
11
Whatever PR work you are doing has failed, because here we are.
12
And we are at motions practice and we are going with litigation
13
because the efforts to sell folks on the claims resolution
14
proceeding have not worked.
15
MR. MOSKOWITZ: I don't think that's correct, your
16
Honor. The time to sign up hasn't opened yet.
17
THE COURT: All right. Why are you bringing this --
18
is it because there is otherwise a response due that you are
19
not waiting to hear whether the folks at the front table are
20
joining in the process or not?
21
MR. MOSKOWITZ: I'm sorry. I don't think I understood
22
the question.
23
THE COURT: You just said to me now that people do not
24
have to elect to participate or not participate today, they
25
have a period of time. Correct?
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1
MR. MOSKOWITZ: Correct.
2
THE COURT: Is that period of time the 10th of January
3
or some date sooner than that?
4
MR. MOSKOWITZ: I'm not certain. I know the protocol
5
comes out very soon. Like in days or a week or SO. And then
6
shortly thereafter, it is a matter of months, so I don't have
7
the exact date. But it's soon, it's very soon, it's not months
8
from now.
9
THE COURT: My understanding is that, first of all,
10
you'd like more plaintiffs and their counsel to participate in
11
the program. But, in the absence of that, you need to do
12
something, and if it's to proceed with the litigation, you will
13
proceed with the litigation.
14
I was trying to understand, and I was trying to
15
understand when I began this conference, why it was that you
16
were bringing the motion now, if you are in the process of
17
trying to persuade, encourage, entice people to participate in
18
the claims resolution process. And I am assuming it is because
19
otherwise you are going to be in default, and you have to do
20
something.
21
MR. MOSKOWITZ: That's right. I would have loved
22
again to put off the date. But this to us, and I have cases,
23
Judge Batts, Judge Buchwald, Judge Sweet, it is a motion to
24
dismiss. We had to move. We had to respond to the complaint,
25
and this is an important motion for us to make.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00027906

=== Page 24 ===
24
JCB3DOEC
1
Yes, in fact, the last time we adjourned the date, it
2
was without consent. We've been saying since the start, hey,
3
let's save resources on both sides. Let's get the claims
4
program going.
5
Again, I do want to be clear, it's not been -- I know
6
your Honor said maybe it was a PR failure. I don't think
7
that's the accurate way to look at it. Again, we've heard
8
various plaintiffs express that they are very interested. Time
9
to actually make that public -- or sorry, not public. Make
10
that official hasn't happened yet.
11
THE COURT: Okay. Ms. Kaplan, are you not going to
12
join in? I just want to know.
13
MS. KAPLAN: I think it's very unlikely, your Honor.
14
They keep referring to them as independent. I don't know how
15
they properly use that adjective to describe Mr. Feinberg and
16
his colleague Ms.
here. They were chosen by the
17
estate, they are being paid for by the estate, there was no --
18
not only was there no participation by us, but any opportunity
19
for us to weigh in on that was declined. And they have a
20
fiduciary duty not to our clients, but to the estate. That's
21
not independent under any definition of the word.
22
And what I am hearing from him frankly causes me
23
greater concern. This protocol, this is what we've heard all
24
along. I don't know, maybe a week. Maybe two weeks. Maybe
25
three weeks. We were supposed to participate in the protocol.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00027907

=== Page 25 ===
25
JCB3DOEC
1
What's he talking about?
2
So we have very, very low confidence in the process,
3
in the integrity of the process, in the ability of these women
4
to have agency in their fates, and I think my client is very
5
likely to go forward with litigation.
6
THE COURT: All right.
7
MS. KAPLAN: Highly likely.
8
THE COURT: I didn't want to set a motion schedule.
9
If we are going forward with the litigation, the folks at the
10
back table have to respond.
11
MS. KAPLAN: Understood. But nothing about their
12
response is relevant to the motion about punitive damages.
13
Again, it does not dismiss a single claim in the case. It
14
doesn't relate to a single one of the one through 86 paragraphs
15
of factual allegations in the complaint. All it relates to are
16
three words in the prayer for relief at the end of the
17
complaint, and we all acknowledge sitting here today that our
18
client is entitled to compensatory damage. So I'm completely
19
willing to brief the issue, your Honor. And I can talk about
20
how the choice of law analysis would work here. But it
21
shouldn't delay anything, frankly, your Honor. Because it
22
won't change anything in terms of moving forward with
23
discovery, and trial in the case.
24
THE COURT: All right. I don't know I need to hear
25
anything else. Mr. Moskowitz, last words?
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00027908

=== Page 26 ===
26
JCB3DOEC
1
MR. MOSKOWITZ: Yes. If I can just give three cites
2
where judges in this district, again, I think I referred to
3
them earlier, Batts, Buchwald, and Sweet did dismiss on
4
12 (b) (6) motions claims for punitive damages. Happy to do SO.
5
If you want us to save it for the brief.
6
THE COURT: That's fine. Well, I haven't yet
7
scheduled the brief, and I want to think about the degree to
8
which discovery runs concurrent with the brief. It is only for
9
the punitive damages; is that not correct?
10
MR. MOSKOWITZ: And the time bar issue which since --
11
THE COURT: We are back to that again.
12
MR. MOSKOWITZ: It was a surprise to US.
13
THE COURT: Of course. I make no final decisions but
14
you're observing the skepticism with which I heard the time bar
15
issue. Because I'm incapable of not expressing my emotions.
16
So I understand that. But I don't think that's going to be
17
carrying the day any time soon.
18
I think I have what I need to go back and think about
19
the issue and set a schedule. But I don't want to deprive
20
either side the opportunity to say final words to me.
21
Ms. Kaplan, anything else you wish me to know?
22
MS. KAPLAN: Just briefly. I've become a student of
23
the law of punitive damages and Mr. Moskowitz is right that the
24
majority rule is to bar it, as we do in New York. But the
25
jurisdictions that do that, at least in the United States, are
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00027909

=== Page 27 ===
27
JCB3DOEC
1
all based on statute. New York has a statute that prohibits
2
punitive damages against an estate. Virgin Islands has no such
3
statute. We are not aware of any case, we researched the issue
4
too in Virgin Islands, saying one way or the other whether that
5
is the law. Although of course in other contexts, the courts
6
in Virgin Islands refer to the restatement.
7
The factors that courts would look to in deciding this
8
issue is kind of the traditional factors. So the purpose of
9
punitive damages in a case is deterrence of future wrongdoing.
10
It's really honestly hard to imagine a case in which deterrence
11
of future wrongdoing is not a stronger interest, particularly
12
given the fact that Mr. Epstein can no longer be prosecuted
13
criminally. There is nothing more important than deterring
14
criminal sexual acts against young children.
15
The countervailing perspective is whether it's unfair
16
to punish the estate for the acts of the decedent. Typically,
17
your Honor, as you can imagine, that comes up in the context of
18
children. There is that famous line from Exodus in the Bible
19
about punishing the children for the sins of the fathers. And
20
since the Enlightenment in our country and in our world, we
21
believe that you shouldn't punish children for the sins of the
22
father.
23
There is no children at issue in this estate. They
24
have identified the sole beneficiary as Mr. Epstein's brother.
25
At least since Mr. Epstein was prosecuted in Florida, his
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00027910

=== Page 28 ===
28
JCB3DOEC
1
brother was fully aware of what Mr. Epstein did, and in fact,
2
we have reason to believe his brother lives in a building owned
3
partly owned by him, partly owned by Mr. Epstein, in which the
4
the two women who did the booking of massages for these girls
5
also lived. So, the idea that Mr. Epstein's brother is somehow
6
innocent here, or should have the full benefits of the estate,
7
based on those policy reasons, makes very, very little sense.
8
And obviously, deterrence is really a huge factor
9
here. This should never happen to any young girl ever again,
10
certainly anywhere in New York or anywhere in this country.
11
THE COURT: Thank you. Mr. Moskowitz, final thoughts?
12
MR. MOSKOWITZ: Yes. I have various law in front of
13
me that I'm happy to brief that, number one, show there are
14
plenty of jurisdictions that not based on statute bar punitive
15
damages against an estate. I have cases such as Lohr V. Byrd,
16
522 So 2d 845, 846 (Fla. 1988), which is a Florida case that
17
refutes any notion that deterrence is served by punishing a
18
tortfeasor. And I am happy to brief all of those.
19
THE COURT: All right. I will get back to the parties
20
as soon as I can. I'm imagining one side or the other will be
21
getting a transcript of this. If you do so, I'll receive it
22
automatically. So I'll just imagine one of you will do that.
23
Thank you very much.
24
(Adjourned)
25
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00027911


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=== Page 1 ===
From:
To: "NathanNYSDChambers@nysd.uscourts.gov"
Cc:
BOBBI C STERNHEIM
"Christian Everdell"
,
Laura Menninger
, Jeff
Pagliuca
Subject: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Date: Sat, 22 May 2021 02:32:41 +0000
Attachments: 2021.05.21_Government_Opposition_to_Defense_Supplemental_Pretrial_Motions.pdf
Dear Judge Nathan,
Attached is the Government's memorandum of law in opposition to the defendant's supplemental pretrial motions. The
Government is not seeking redactions to the memorandum. However, the electronic case filing system does not accept
the filing of opposition briefs where the original motion does not appear on the docket, and the defense motion has not
yet been publicly filed. The Government will promptly file its opposition on the public docket after the defense motion is
filed.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00028584


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=== Page 1 ===
From:
)"
To:
Cc:
Subject: RE: Epstein investigation
Date: Wed, 30 Jan 2019 22:18:50 +0000
Importance: Normal
Following up on our conversation from yesterday, wanted to send a quick email as promised so you have my full contact
info - I'm reachable at this email address or by phone at
(office) or
(cell). Please don't
hesitate to reach out anytime day or night if we can provide any useful info, or if you have any questions at all, and we
appreciate you talking with us about the records information. Let us know if it makes sense to set up another call for
Friday or early next week to check in on the questions we had, and thanks very much for your help.
thanks again,
Alex.
Assistant U.S. Attorney
Southern District of New York
EFTA00029463


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=== Page 1 ===
From: "
)"
To:
)"
Subject: epstein
Date: Mon, 08 Jul 2019 16:12:51 +0000
Importance: Normal
Pls send me the indictment and the Detention Memo. Tx.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
EFTA00028307


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=== Page 1 ===
From:
(NY) (FBI)"
To:
Cc:
"
Subject: RE: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Date: Wed, 07 Apr 2021 19:27:38 +0000
Just dropped it off.
Special Agent
FBI New York Field Office
On Apr 7, 2021 2:24 PM,
(USANYS) [Contractor]"
wrote:
That's perfect, thank you. Please let me know once you've dropped them off.
From:
(NY) (FBI)
Sent: Wednesday, April 7, 2021 2:22 PM
To:
(USANYS) [Contractor]
is
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Do you want me to just leave it downstairs in a folder? I'll bring it over now. There are four disks to include 1B-14, 1B 8-2,
1B 8-7, and 1D-1.
From:
(USANYS) [Contractor]
Sent: Wednesday, April 7, 2021 11:26 AM
To:
(NY) (FBI)
is
)
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Sounds good, thank you!
From:
(NY) (FBI)
^
Sent: Wednesday, April 7, 2021 11:09 AM
To:
)
is
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Hey
EFTA00029231

=== Page 2 ===
I'm having some issues with my usa fx account. I have to drop some other media off, so I'll put this on another disc and
drop it off. I can drop it all off early afternoon if that's alright.
Special Agent
FBI New York Field Office
On Apr 7, 2021 9:48 AM,
(USANYS) [Contractor]"
wrote:
Hey
Just wanted to follow up on getting the folder "1B 1-14" on USAfx. Please let us know when you've been able to upload it,
thanks!
From:
Sent: Tuesday, April 6, 2021 1:14 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: FW: CD with Maxwell files
Thanks so much,
(cc'd) will make another copy this afternoon and will send it to you via USAfx.
From:
(USANYS) [Contractor]
Sent: Tuesday, April 6, 2021 1:12 PM
To:
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: CD with Maxwell files
Just confirmed with
that we'll need a replacement of the folder called "1B 1-14" since it won't copy for him either,
probably due to the files getting corrupted somehow when the disc was burned. The folder/its contents may be small
enough that the FBI could send it via USAfx rather than having to burn a new disc, but we'll need a replacement of this
folder either way.
From:
Sent: Monday, April 5, 2021 4:27 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: CD with Maxwell files
Great, thank you!
From:
(USANYS) [Contractor]
Sent: Monday, April 5, 2021 4:20 PM
To:
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: CD with Maxwell files
Hi
EFTA00029232

=== Page 3 ===
Four of the five folders from the disc have successfully uploaded to the folder path linked below, but the fifth folder (1B 1-
14) contains at least one file that will not copy off of the disc (not sure if the file is corrupted or what the issue is exactly).
l'll check with the IT folks and
to see if they're able to copy the remaining folder off the disc or if we'll need the FBI
to recopy and resend it. I will keep you posted on the status of this last folder.
Thanks,
From:
(USANYS) [Contractor]
Sent: Monday, April 5, 2021 2:04 PM
To:
(USANYS) [Contractor]
Subject: FW: CD with Maxwell files
Thank you so much!
From:
Sent: Monday, April 5, 2021 1:55 PM
To:
(USANYS) [Contractor]
i
(USANYS) [Contractor]
Subject: CD with Maxwell files
Hi
and
On Friday, the FBI brought me a CD containing additional files that I need to review for Maxwell. It should be sitting in my
office on the 4th floor on my keyboard at my desk. Would one of you (or another paralegal who is in the office) be able to
please grab the CD and load its contents onto the Epstein share? You can save everything from the CD here:
Thanks so much,
EFTA00029233


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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From: AUSA
Date: August 31, 2021
Re:
United States V. Ghislaine Maxwell
Court Docket No:
20 Cr. 330 (AJN)
USAO No:
2018R01618
Witness Name:
Witness DOB:
(Name/DOB as printed here will be forwarded to travel agency and then to TSA and must
exactly match the witness's driver's license or other travel ID or TSA will not permit the
witness to fly.)
Witness Address:
Witness TelNos (mobile):
Witness e-mail:
Witness Needed to Appear in SDNY on
Date: September 17, 2021
Time: 10 a.m.
Witness Needed to Appear for:
Trial ( )
Date:
Grand Jury ( )
Date:
Trial/GJ Prep (X)
Date: September 17, 2021 at 10 a.m.
Estimated Dates Witness will Arrive: September 16, 2021
Depart: September 17 or 18, 2021
Is the person a Fact Witness and not an Expert Witness?
(Yes/No):
Current Federal Civilian or Military Employee?
(Yes/No):
Is the Witness Facing Criminal Charges?
(Yes/No):
Does the Witness Reside Outside the Continental United States?
(Yes/No):
Is this Witness a Victim-Witness?
(Yes/No):
Hotel Required?
(Yes/No):
Has the Witness advised you of any unusual travel expenses?
(Yes/No):
Unusual expenses of fact witnesses can include
special travel arrangements
care for dependent child or incapacitated family member left at home
rev. 2019.11.19
EFTA00029596

=== Page 2 ===
kennel fees for pets
necessary travel companion
extra baggage (more than one bag)
Please describe the unusual expense:
For Victim-Witness Coordinator:
1. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW
is apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should
be used.
For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to
court/GJ testimony.
Witnesses may only be brought in under the FEWS appropriation for grand jury testimony that
has been scheduled and where the witness is expected to testify before the grand jury; court
testimony; or preparation for same. Any other witness travel, e.g., for investigative interviews,
must be covered by the investigating component from litigative funds. See Ed Tyrrell.
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
EFTA00029597


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=== Page 1 ===
From:
To:
Subject: FW: Submission on behalf o
Date: Fri, 13 Mar 2020 00:47:43 +0000
Attachments:
Attached in PDF format.
From
(via Google Docs)
@gmail.com>
Sent: Thursday, March 12, 2020 20:40
To:
Cc:
is
Subject: Submission on behalf of
@gmail.com has shared a link to the following document:
Submission on behalf of
Unk
nown
profile
Attached is a draft of the factual statement, just so that you can better understand the facts that we are
presenting.
We feel that given
abuse, and given the fact that we see her basically as a cog in Epstein's wheel,
acting entirely at his direction and doing what she did at a time that she herself was a very vulnerable victim, a
non-pros would be the appropriate disposition. But we want to discuss this with you before we finalize this and
make a submission.
Thanks
Open in Docs
Logo for
Google Docs: Create and edit documents online.
Google Docs
Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
You have received this email because someone shared a document with you from Google Docs.
EFTA00028803


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=== Page 1 ===
From: Roberta Kaplan
To:
Subject: Fwd: Doe V. Indyke, et al., 1:19-cv-08673-KPF, Plaintiff's Response to Defendants' Letters
Filed Nov. 5, 2019
Date: Wed, 06 Nov 2019 16:48:47 +0000
Attachments: 021 -
2019.11.06_Letter_from_R_Kaplan_to_J_Failla_re_Response_to_Defendants'_Nov_5,2
019_Letters.pdf
FYI
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
From: Kyla Magun
Sent: Wednesday, November 6, 2019 11:44:49 AM
To:
Cc:
>; Roberta Kaplan
>; ; Julie Fink
>; Jenna Dabbs
>; ; Justin
Horton
Subject: Doe V. Indyke, et al., 1:19-cv-08673-KPF, Plaintiff's Response to Defendants' Letters Filed Nov. 5, 2019
Dear Judge Failla:
I write on behalf of Plaintiff Jane Doe to attach a courtesy copy of a letter just filed by Roberta Kaplan as ECF 21 in the
above-captioned case. The letter responds to Defendants' two letters filed last night, November 5, 2019 (ECF 19 & 20).
Respectfully submitted,
Kyla Magun
Kyla Magun I Kaplan Hecker & Fink LLP
Associate
(W)
I (M)
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00028471


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=== Page 1 ===
From: Jeff Pagliuca
To:
)"
Cc: Sabina Mariella
"Sigrid McCawley
)"
>, Laura Menninger
>, Nicole Simmons
Subject: FW: Documents Per Judge Nathan's Order
Date: Wed, 21 Apr 2021 22:55:28 +0000
Attachments: 2021.04.02 Defts to BSF Ltr. to 17_Sub.pdf;
ExA_2021.04.02_Defts_Resp_to_BSF_Ltr_Motn_to_Quash_Rule_17_Sub_-Prpsd.p
Ex._A_.pdf;Ex._B_2021.04.05_BSF_Reply_re_Maxwell_Rule_17(c)_Subpoena_
_Redact...pdf;2021.04.05_BSF_Reply_re_Maxwell_Rule_17(c)_Subpoena.pdf;
2021.04.19_LAM_Joint_Letter_with_BSF_re_redactions_in_Rule_17_pleadings.pdf;_2021-
04-21_[00226-000]_ORDER_as_to_Ghislaine_Maxwell_The_Court_is_in_re..pdf
Here they are. I thought they were attached to the last email.
From: Sigrid McCawley
Sent: Wednesday, April 21, 2021 4:32 PM
To: Laura Menninger
>; Jeff Pagliuca
Cc: Sabina Mariella
>; Sigrid McCawley
Subject: Documents Per Judge Nathan's Order
Hello Laura and Jeff,
As we understand Judge Nathan's Order, we are directed to confer with the Government about
any redactions they are requesting to the above. Please confirm that you agree the above set of
materials can be sent to the Government pursuant to Judge Nathan's Order this afternoon.
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among
other protections, is the subject of attorney-client privilege, attomey 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
EFTA00027162


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=== Page 1 ===
From:
To:
Subject: RE: thanks I need your questionnaire too
Date: Fri, 24 Jan 2020 16:02:09 +0000
Attachments: Questionnaire_for_Official_Foreign_Travel,_Stockholm,_2020,
.pdf
Thanks! It's attached. I just checked with
and there's an issue with my itinerary, so just so you know we're
cancelling it and rebooking a different flight.
From:
Sent: Friday, January 24, 2020 11:01 AM
To:
Subject: thanks I need your questionnaire too
EFTA00027829


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=== Page 1 ===
From:
(USANYS)"
To:
Cc:
Subject: RE: motions under seal?
Date: Fri, 02 Aug 2019 16:09:36 +0000
We had the court seal the documents, and per the Court's request, are following up with a formal letter request to do so.
We do not believe there is a legitimate legal basis to seal
statements, but if you can point us to any
authority, we are happy to look at it.
Assistant United States Attorney
From:
Sent: Friday, August 2, 2019 12:07 PM
To:
(USANYS)
is
Cc:
Subject: RE: motions under seal?
We will take care of that error and apologize for it.
I know that the statements are not marked as sensitive by the Government but for obvious reasons we don't want to file
those publically. Thus our request. If the government won't consent then, we will serve you via email and hold off filing it
until we can get the court to rule.
Garden City, NY 11530
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
From:
(USANYS) [mailto:
Sent: Friday, August 02, 2019 11:50 AM
To:
)
Cc:
Subject: RE: motions under seal?
EFTA00028529

=== Page 2 ===
As you know, the protective order distinguishes between all discovery and that marked "sensitive," and it is the sensitive
discovery that cannot be publicly filed.
statements to law enforcement do not fall into the sensitive
category, so they should be publicly filed. We'd ask that, consistent with the protective order, any sensitive discovery and
references to cooperators be redacted in your public filings. Along the same lines, we noticed that you publicly filed four
documents that were marked sensitive (Exhibits A through D to your cell site motion) in violation of the protective order.
We will be asking the Court to remove them from the docket and you will need to refile.
Assistant United States Attorney
From:
Sent: Friday, August 2, 2019 11:33 AM
To:
(USANYS)
is
)
Cc:
Subject: RE: motions under seal?
I don't think that will satisfy our concern about revealing the statements and certainly not something we can do today or
easily. Nor do I want the extra work.
Garden City, NY 11530
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
From:
,
(USANYS) [mailto:
Sent: Friday, August 02, 2019 11:26 AM
To:
)
Cc:
Subject: RE: motions under seal?
It is a little difficult to know what needs to be sealed/redacted in the abstract. Out of an abundance of caution, can you
file the documents with any reference to evidence/discovery and cooperators redacted? We can then review the
unredacted version and discuss what, if anything, can be unredacted for the public version.
Assistant United States Attorney
From:
Sent: Friday, August 2, 2019 11:03 AM
To:
)
is
(USANYS)
Cc:
EFTA00028530

=== Page 3 ===
Subject: motions under seal?
Our motions will be ready to go out in a few hours., One is straight forward legal argument about the cell tower data,
which we don't have a problem filing. The other motion deals with the statements to the police and by necessity we
discuss the statements in detail. We also discuss some of the discovery and the cooperating witnesses. What is the
Government position about filing that motion under seal?
Also,
affidavit hasn't been signed because the only regular access to a notary are members of his legal team and we
don't want to witness his signature. We will have him sign it through whatever the process is at MCC or in open court at
our next appearance.
Garden City, NY 11530
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
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From
To:
)"
Subject: RE: FBI Case File - Epstein
Date: Tue, 22 Jan 2019 15:35:53 +0000
Importance: Normal
Perfect, thanks. I deleted my duplicative copy. I'll create a case file for additional records.
From:
)
Sent: Tuesday, January 22, 2019 10:35 AM
To
Subject: RE: FBT Case File - Epstein
Hey I'm sorry, I should have been more clear - I already saved the contents here -
I just wanted to give you the disc for a case file for physical records. Sorry again! And yeah, if you could please retain the
hard copy that would be great. Many thanks.
From
Sent: Tuesday, January 22, 2019 10:33
To:
)
Subject: FBI Case File - Epstein
I placed the materials on the disc you left on my desk here:
I believe this is where it belongs, but let me know if you'd like the folder renamed/moved elsewhere. Should I create a
case file for this case and keep physical records or would you like the disc back?
Best,
Paralegal
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Bcc: "USAHUB-USAJournal111"
Subject: RE: SOL
Date: Wed, 17 Feb 2021 03:15:32 +0000
Embedded: RE:_SOL.msg
Sender:
Subject: RE: SOL
Message-Id:
<BN3P110MB025737AE4ABE6364C9A03B188A869@BN3P110MB0257.NAMP110.PROD.OUTLOOK.CO
M>
To:
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=== Page 1 ===
From:
)"
To:
)"
Subject: FW: RE: Outlook question
Date: Sun, 11 Oct 2020 15:54:48 +0000
EMAIL TO FILE:
During the course of reviewing my emails, as described in the Epstein Transition Memo dated October 9, 2020, I moved
approximately 160 non-substantive (but arguably or clearly related to the case in some fashion) emails to a separate
folder in Outlook. In the process of doing so, approximately 140 of those emails were duplicated. Today, I deleted the
duplicate version of those emails, taking care to ensure that one copy of each email remains in that folder, consistent with
the litigation hold in this case.
-
From: USANYS-IT Services
Sent: Friday, October 09, 2020 19:49
To:
Subject: RE: RE: Outlook question
Do not believe there is a de-dupe option.
From:
Sent: Friday, October 9, 2020 7:43 PM
To: USANYS-IT Services
Subject: RE: Outlook question
Sorry for the bother, but I copied a number of emails into a new Outlook folder and it somehow appears to have doubled
every single email. Is there a way to update / de-dupe that? Or do I need to individually delete every other email to get it
back to normal?? Thank you!
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Cc:
Subject: edits to brief
Date: Fri, 21 May 2021 15:54:37 +0000
Attachments: Government_Opposition_to_Defense_Supplemental_Pretrial_Motions_v5_(MC).docx
Hi
Attached please find my proofread and cite check edits to the brief in track.
Thanks!
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=== Page 1 ===
From:
To:
Cc:
Subject: Re: SDNY investigation
Date: Thu, 11 Jul 2019 18:52:58 +0000
Good Afternoon Mr.
& Ms.
We have never spoke directly. I have been told by my attorney I can speak to you since you are consider law
enforcement. You emailed my attorney Mr. Robert Lewis. I am writing you to please do not under estimate Mr.
Epstein's ability to leave the country as he is asking for bail. Mr. Epstein has an apartment in Paris and he has
friends that have the private means of getting him out of the country. I am not saying this is going to happen,
but I know first hand that Mr. Epstein is like a family member to my former employer. He is the godfather to
their children and they will help him and vice versa. They call him uncle "F." Since this situation is now extreme
there is no telling how much pressure Mr. Epstein might put on them to help him. As they say, "they do favors
for each other," and this goes as far as giving each other money when needed as well as the use of their private
planes and cars.
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=== Page 1 ===
SECURITY
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
November 6, 2021
VIA FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Enclosed are witness materials pertinent to the following inmate:
Ghislaine Maxwell: 02879-509
Please allow her access to the materials enclosed.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
/s
Assistant United States Attorneys
Enclosure
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=== Page 1 ===
From:
To:
Cc:
Subject: Call with PAE re Epstein
Date: Thu, 25 Mar 2021 19:29:34 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From:
)"
To:
Cc:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
(USANYS)"
Subject: Ghislaine Maxwell - new discovery production
Date: Fri, 02 Oct 2020 13:10:56 +0000
Attachments: 2020.10.02_MDC - Maxwell_PASSWORD.pdf;
2020.10.02_Maxwell_Discovery_Letter.pdf
Hi
Today our office is sending via FedEx a new drive containing additional discovery for Ghislaine Maxwell. For your
reference, attached are the cover letters. Would you (or someone at the MDC) please keep an eye out for this and make
sure it gets to Maxwell as soon as it arrives? Her attorneys have been complaining about delays between when we send
the drives and when they get to Maxwell.
Thanks so much, as always, for all of your help.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
Subject: Accepted: Update Conference Call - Epstein
Date: Tue, 13 Aug 2019 00:15:04 +0000
Importance: Normal
Attachments: unnamed
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From:
To:
Cc:
Subject: US V. Maxwell - Request for Review Batches on Relativity
Date: Mon, 16 Nov 2020 17:21:18 +0000
Hi
I hope you had a good weekend. The Maxwell team is now turning to review the SDFL documents that you helped get
loaded onto Relativity. Would you please help us get those documents batched out for review? Specifically, please break
down all of the documents in the folder entitled "USAO-SDFL Files" within the "US V Epstein" database into batches of
approximately 500 documents.
Would you please also add an Issue Designation tag entitled "Relevant to NPA" to the preexisting Issue Designation tags?
Thanks very much,
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From:
To:
Subject: Automatic reply: Timing of victim-related disclosures
Date: Tue, 27 Aug 2019 00:35:18 +0000
I am currently on trial before the Honorable Ronnie Abrams. I will be checking email at the end of each trial day. If you need immediate
assistance in connection with United States V. Epstein, 19 Cr. 490 (RMB), please contact AUSA
at
For all other matters,
please contact AUSA
at
Thank you.
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=== Page 1 ===
From:
To:
"
)"
Subject: Epstein subpoenas
Date: Wed, 10 Jul 2019 16:00:08 +0000
Importance: Normal
Subpoenas Before Today
Employees involved in offenses
(
)
Associates with knowledge of the offenses
(
Ghislaine Maxwell,
(only known client)
(one of his pilots)
Also, we have contacted, but not used subpoenas with, many victims
Subpoenas Today
Today they are subpoenaing two Miami household staff
(
and
), one recruiter
(
), and
another pilot
(
).
Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
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=== Page 1 ===
AO 106 (SDNY Rev. 01/17) Application for a Search Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Briefly describe the property to be searched
9MAG
6572
or identify the person by name and address)
Case No.
See Attached Affidavit and its Attachment A
APPLICATION FOR A SEARCH AND SEIZURE WARRANT
I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):
located in the
Southern
District of
New York
, there is now concealed (identify the
person or describe the property to be seized):
See Attached Affidavit and its Attachment A
The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
evidence of a crime;
contraband, fruits of crime, or other items illegally possessed;
property designed for use, intended for use, or used in committing a crime;
a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section(s)
Offense Description(s)
18 U.S.C. §§ 1591 and
Sex trafficking of minors; sex trafficking conspiracy
371
The application is based on these facts:
See Attached Affidavit and its Attachment A
Continued on the attached sheet.
Delayed notice of
days (give exact ending date if more than 30 days:
) is requested
under 18 U.S.C. $ 3103a, the basis of which is set forth on the attached sheet.
Applicant's signature
Special Agent
FBI
Printed name and title
Sworn to before me and signed in my presence.
Date:
7/7/19
s/
Judge's signature
City and state: New York, NY
Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and title
EFTA00028485

=== Page 2 ===
affidavit is being submitted for the limited purpose of establishing probable cause, it does not
include all the facts that I have learned during the course of my investigation. Where the contents
of documents and the actions, statements, and conversations of others are reported herein, they are
reported in substance and in part, except where otherwise indicated.
B. The Subject Premises
3.
The Subject Premises are particularly described as a multi-story, single-family
residence located at
New York, New York, and include all locked and closed
containers found therein. As detailed further herein, the Subject Premises is believed to be owned,
possessed and controlled by JEFFREY EPSTEIN, a target subject of this investigation. A
photograph of the front entrance to the Subject Premises is included below:
Google
C. The Target Subject and the Subject Offenses
4.
The Target Subject of this investigation is JEFFREY EPSTEIN.
5.
For the reasons detailed below, I believe that there is probable cause to believe that
the Subject Premises contain evidence, fruits, and instrumentalities of violations of Title 18, United
2
2017.08.02
EFTA00028486

=== Page 3 ===
masturbate during these sexualized encounters, ask victims to touch him while he masturbated,
and touch victims' genitals with his hands or with sex toys. Following each encounter, EPSTEIN
or one of his employees or associates paid the victim in cash.
9.
As set forth in paragraphs 12 through 13 of Exhibit A, to further facilitate his ability
to abuse minor girls in New York, JEFFREY EPSTEIN asked and enticed certain of his victims to
recruit additional minor girls to perform "massages" and similarly engage in sex acts with
EPSTEIN. When a victim would recruit another minor girl for EPSTEIN, he paid both the victim-
recruiter and the new victim hundreds of dollars in cash. EPSTEIN knew that his victims were
underage, including because certain victims told him their age.
10.
One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of
the FBI's investigation of EPSTEIN, other law enforcement officers have interviewed Victim-1.¹
I know from my conversations with other law enforcement officers who have interviewed Victim-
1, that Victim-1 has provided the following information, in substance and in part:
a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-1 on
multiple occasions in the Subject Premises. This sexual abuse all occurred when Victim-1 was
under the age of 18.
b. During that same period, Victim-1 observed multiple floors of the Subject Premises
and numerous individual rooms within the Subject Premises. Victim-1 has provided detailed
1 In meetings with the Government, Victim-1 has disclosed that, approximately a decade ago, she
committed marriage fraud in order to obtain a green card and, subsequently, U.S. citizenship. She
has also disclosed personal substance abuse, primarily involving the abuse of prescription drugs,
during various periods between the early 2000s and 2019. Victim-1 has also disclosed having
worked for approximately a year at a "happy-ending" massage parlor, performing paid sex acts.
Victim-1 is currently pursuing a civil damages claim against EPSTEIN for his sexual abuse of her.
Information provided by Victim-1 has proven reliable and has been corroborated by independent
evidence, including documents and records obtained during the investigation and the accounts of
other victims whom Victim-1 has never met.
4
2017.08.02
EFTA00028487

=== Page 4 ===
from the ribcage to the clavicle (collectively, (the "Busts"). The Busts do not appear to be designed
for use as sex toys, and appear instead to be artwork. Nevertheless, based on my conversations
with law enforcement officers who have interviewed Victim-1, I have learned that the Busts appear
to be generally consistent with Victim-1's description of observing the Torso in EPSTEIN's
bathroom in the Subject Premises. Accordingly, there is probable cause to believe that the Busts
are corroborating evidence of Victim-1's description of the Subject Premises.
b.
Inside the Subject Premises, I observed a room that, based on my conversations
with law enforcement officers who have interviewed Victim-1, appears to be consistent with
Victim-1's descriptions of the Massage Room. The room contained a table covered with a sheet,
and appears to be a massage table. The walls appear to be covered in a type of felt-like tapestry
fabric. I further observed two paintings and three photographs hanging on the walls of the Massage
Room: The paintings and photographs depict nude females. One of the photographs appears to
depict a nude girl. Based on my training and experience investigating crimes involving the sexual
exploitation of children, the girl appears to be approximately 15 to 20 years old.
c.
Inside the Subject Premises, inside a closet adjacent to a bathroom, I observed a
shelf that appears to contain several black binders, with labels on the spine of each binder. In
particular, one of the binders is marked with a series of labels, one of which reads: "PB Girls."
Given that the Indictment charges EPSTEIN with participating in a conspiracy to engage in sex
trafficking of minor girls in both Palm Beach, Florida and New York, I believe that "PB Girls"
may refer to minor victims in Palm Beach, Florida.
d.
Inside the Subject Premises, in what appears to be EPSTEIN's office, on or about
the second floor of the Subject Premises, I observed what appears to be a taxidermied dog (the
"Dog"). Based on my conversations with law enforcement officers who have interviewed
6
2017.08.02
EFTA00028488

=== Page 5 ===
10 p.m. In view of the foregoing circumstances, I respectfully submit that the present
circumstances demonstrate good cause to execute the warrant after 10 p.m.
Special Agent
Federal Bureau of Investigation
Sworn to before me on
July 4. 2019
THE HONORABLE S/ BARBARA MOSES
UNITED STATES MAGISTRATE JUDGE
8
2017,08.02
EFTA00028489

=== Page 6 ===
1 9MAG 6572
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
:
SEALED
UNITED STATES OF AMERICA
:
INDICTMENT
:
V. -
:
19 Cr.
:
JEFFREY EPSTEIN,
:
:
19 CRIM
490
Defendant.
:
:
x
COUNT ONE
(Sex Trafficking Conspiracy)
The Grand Jury charges:
OVERVIEW
1. As set forth herein, over the course of many
years, JEFFREY EPSTEIN, the defendant, sexually exploited and
abused dozens of minor girls at his homes in Manhattan, New
York, and Palm Beach, Florida, among other locations.
2. In particular, from at least in or about 2002, up
to and including at least in or about 2005, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
recruited, minor girls to visit his mansion in Manhattan, New
York (the "New York Residence") and his estate in Palm Beach,
Florida (the "Palm Beach Residence") to engage in sex acts with
him, after which he would give the victims hundreds of dollars
in cash. Moreover, and in order to maintain and increase his
supply of victims, EPSTEIN also paid certain of his victims to
recruit additional girls to be similarly abused by EPSTEIN. In
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=== Page 7 ===
recruited, dozens of minor girls to engage in sex acts with him,
after which EPSTEIN paid the victims hundreds of dollars in
cash, at the New York Residence and the Palm Beach Residence.
7. In both New York and Florida, JEFFREY EPSTEIN,
the defendant, perpetuated this abuse in similar ways. Victims
were initially recruited to provide "massages" to EPSTEIN, which
would be performed nude or partially nude, would become
increasingly sexual in nature, and would typically include one
or more sex acts. EPSTEIN paid his victims hundreds of dollars
in cash for each encounter. Moreover, EPSTEIN actively
encouraged certain of his victims to recruit additional girls to
be similarly sexually abused. EPSTEIN incentivized his victims
to become recruiters by paying these victim-recruiters hundreds
of dollars for each girl that they brought to EPSTEIN. In so
doing, EPSTEIN maintained a steady supply of new victims to
exploit.
The New York Residence
8. At all times relevant to this Indictment, JEFFREY
EPSTEIN, the defendant, possessed and controlled a multi-story
private residence on the Upper East Side of Manhattan, New York,
i.e., the New York Residence. Between at least in or about 2002
and in or about 2005, EPSTEIN abused numerous minor victims at
the New York Residence by causing these victims to be recruited
to engage in paid sex acts with him.
3
EFTA00028491

=== Page 8 ===
employees and associates, including a New York-based employee
("Employee-1"), to communicate with victims via phone to arrange
for these victims to return to the New York Residence for
additional sexual encounters with EPSTEIN.
12. Additionally, and to further facilitate his
ability to abuse minor girls in New York, JEFFREY EPSTEIN, the
defendant, asked and enticed certain of his victims to recruit
additional girls to perform "massages" and similarly engage in
sex acts with EPSTEIN. When a victim would recruit another girl
for EPSTEIN, he paid both the victim-recruiter and the new
victim hundreds of dollars in cash. Through these victim-
recruiters, EPSTEIN gained access to and was able to abuse
dozens of additional minor girls.
13. In particular, certain recruiters brought dozens
of additional minor girls to the New York Residence to give
massages to and engage in sex acts with JEFFREY EPSTEIN, the
defendant. EPSTEIN encouraged victims to recruit additional
girls by offering to pay these victim-recruiters for every
additional girl they brought to EPSTEIN. When a victim-
recruiter accompanied a new minor victim to the New York
Residence, both the victim-recruiter and the new minor victim
were paid hundreds of dollars by EPSTEIN for each encounter. In
addition, certain victim-recruiters routinely scheduled these
5
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=== Page 9 ===
to touch him while he masturbated, and touch victims' genitals
with his hands or with sex toys.
16. In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash. Victims typically were paid hundreds
of dollars for each encounter.
17. JEFFREY EPSTEIN, the defendant, knew that certain
of his victims were underage, including because certain victims
told him their age. In addition, as with New York-based
victims, many Florida victims, once recruited, were abused by
JEFFREY EPSTEIN, the defendant, on multiple additional
occasions.
18. JEFFREY EPSTEIN, the defendant, who during the
relevant time period was frequently in New York, would arrange
for Employee-2 or other employees to contact victims by phone in
advance of EPSTEIN's travel to Florida to ensure appointments
were scheduled for when he arrived. In particular, in certain
instances, Employee-2 placed phone calls to minor victims in
Florida to schedule encounters at the Palm Beach Residence. At
the time of certain of those phone calls, EPSTEIN and Employee-2
were in New York, New York. Additionally, certain of the
individuals victimized at the Palm Beach Residence were
contacted by phone by Employee-3 to schedule these encounters.
7
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=== Page 10 ===
commercial sex act, in violation of Title 18, United States
Code, Sections 1591 (a) and (b) (2).
Overt Acts
22. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a. In or about 2004, JEFFREY EPSTEIN, the
defendant, enticed and recruited multiple minor victims,
including minor victims identified herein as Minor Victim-1,
Minor Victim-2, and Minor Victim-3, to engage in sex acts with
EPSTEIN at his residences in Manhattan, New York, and Palm
Beach, Florida, after which he provided them with hundreds of
dollars in cash for each encounter.
b. In or about 2002, Minor Victim-1 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the New York Residence over a
period of years and was paid hundreds of dollars for each
encounter. EPSTEIN also encouraged and enticed Minor Victim-1
to recruit other girls to engage in paid sex acts, which she
did. EPSTEIN asked Minor Victim-1 how old she was, and Minor
Victim-1 answered truthfully.
C. In or about 2004, Employee-1, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
9
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=== Page 11 ===
g.
In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-3 in Florida in order to
schedule an appointment for Minor Victim-3 to engage in paid sex
acts with EPSTEIN.
h. In or about 2004, Employee-3 placed a
telephone call to Minor Victim-3 in order to schedule an
appointment for Minor Victim-3 to engage in paid sex acts with
EPSTEIN.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Sex Trafficking)
The Grand Jury further charges:
23. The allegations contained in paragraphs 1
through 19 and 22 of this Indictment are repeated and realleged
as if fully set forth within.
24. From at least in or about 2002, up to and
including in or about 2005, in the Southern District of New
York, JEFFREY EPSTEIN, the defendant, willfully and knowingly,
in and affecting interstate and foreign commerce, did recruit,
entice, harbor, transport, provide, and obtain by any means a
person, knowing that the person had not attained the age of 18
years and would be caused to engage in a commercial sex act, and
did aid and abet the same, to wit, EPSTEIN recruited, enticed,
harbored, transported, provided, and obtained numerous
11
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=== Page 12 ===
Substitute Asset Provision
26. If any of the above-described forfeitable
property, as a result of any act or omission of the defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a
third person;
(c) has been placed beyond the jurisdiction of the Court;
(d), has been substantially diminished in value; or
(e) has been commingled with other property which cannot
be subdivided without difficulty;
it is the intent of the United States, pursuant to 21 U.S.C.
$ 853 (p) and 28 U.S.C. $ 2461 (c), to seek forfeiture of any
other property of the defendant up to the value of the above
forfeitable property.
(Title 18, United States Code, Section 1594; Title 21,
United States Code, Section 853 (p) and
Title 28, United States Code, Section 2461.)
Jumpas
Heopy S. Bann
FOREPERSON
GEOFFREY S. BERMAN
United States Attorney
13
EFTA00028496

=== Page 13 ===
EXHIBIT B

=== Page 14 ===
ATTACHMENT A
I. Premises to be Searched-Subject Premises
1.
The premises to be searched (the "Subject Premises") are described as a multi-story
single-family residence located at
New York, New York, and include all locked
and closed containers found therein. A photograph of the front entrance to the Subject Premises
is included below:
Google
II. Items to Be Seized
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses
This warrant authorizes, the seizure of certain evidence, fruits, and instrumentalities of
violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors) and 371
(sex trafficking conspiracy) (the "Subject Offenses") described as follows:
i. Any and all taxidermied dogs.
ii. Any and all massage tables and massage paraphernalia.
iii. Any and all busts or three-dimensional representations of female human
torsos.
iv. Any and all photos or representations depicting nude or partially nude
women located in the Massage Room, as defined herein.
V. Any and all sex toys and sex paraphernalia located in the Massage
Room, as defined herein.
2017.08.02
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=== Page 1 ===
From:
)"
To:
)"
Cc:
(USANYS)"
)"
Subject: reply brief
Date: Wed, 27 Oct 2021 01:29:58 +0000
Attachments: !Maxwell's_Response_to_Govs_Omnibus_Motns_in_Limine.pdf; Govt_Reply_vl.docx
Hi
Judge Nathan has given us 48 hours (i.e. until midnight tomorrow) to write a reply brief. Attached is a partial draft and
their motion. Part I of their brief has a bunch on MV-4, especially at pp. 12-15 and 18. We respond primarily at pp. 10-
11. Would you take a look and see if what we're saying is accurate?
Thanks!
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
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=== Page 1 ===
From: UberConference <noreply@uberconference.com>
To:
Subject: Conference Invite from The Bloom Firm: Call re Epstein on Thursday January 23, 2020
@ 12:00 pm (PST)
Date: Wed, 22 Jan 2020 21:44:54 +0000
Attachments: invite.ics
The Bloom Firm has invited you to a conference call.
Your UberConference Will Begin At:
January 23, 2020 at 12:00PM (PST
-
US/Pacific)
Call re Epstein
6 Participants
JOIN THE CALL
Other ways to join
URL - https://www.uberconference.com/thebloomfirm
EFTA00028454

=== Page 2 ===
Conference Number - 818-405-0476
No PIN needed
Joining from outside the US? - International access numbers
Add to my calendar: Google I Outlook I iCal I Yahoo
6 Participants
F
T
L
witt
ink
EFTA00028455

=== Page 3 ===
UberConference by Dialpad
100 California Street
San Francisco, CA 94111
You are receiving this email because you signed up for UberConference
If you'd like to stop getting emails from UberConference, click here
EFTA00028456


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=== Page 1 ===
From: Bruce Barket <bbarket@barketepstein.com>
To:
)"
Cc:
Subject: Re:
disclosure letter
Date: Tue, 15 May 2018 16:06:46 +0000
Thanks,
Bruce A. Barket
Barket, Epstein & Kearon, LLP
666 Old Country Road
Garden City, NY 11530
(516) 745-1500
www.BarketEpstein.com
On May 15, 2018, at 11:48 AM,
)
wrote:
Counsel,
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10003
212-637-2324
<2018.05.15 disclosure letter to
pdf>
EFTA00027954


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=== Page 1 ===
From: "Berman, Geoffrey (USANYS)"
To:
(USANYS) 4"
(USANYS)"
Subject: RE: Epstein
Date: Tue, 27 Aug 2019 23:19:53 +0000
I'm glad to hear that,
It was an extraordinary and memorable day made possible by our fabulous team. Geoff
From:
(USANYS) 4
Sent: Tuesday, August 27, 2019 7:07 PM
To: Berman, Geoffrey (USANYS)
is
(USANYS)
Subject: Epstein
Geoff and
:
Just wanted you both to know that we've been receiving a positive response from NGOs on the Epstein case - not just in
terms of the charges brought, but also in terms of the opportunity created for victims to be heard. I was in court for part
of today, and I'm not sure that I've experienced anything like it. I am very proud of the way that our Office has handled
this case and investigation, and I hope that it encourages more victims to come forward.
Thank you.
Assistant United States Attorney
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00027257


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=== Page 1 ===
From:
)"
To: Stan Pottinger
Subject: RE: Jeffrey Epstein's disregard for environmental protections showed his disrespect for the law,
Virgin Islands says - CNN
Date: Fri, 17 Jan 2020 00:23:58 +0000
Ah yes, Jeffrey Epstein, the world-historically appalling
polluter.
From: Stan Pottinger
Sent: Thursday, January 16, 2020 18:58
To:
Subject: Jeffrey Epstein's disregard for environmental protections showed his disrespect for the law, Virgin Islands says -
CNN
https://www.cnn.com/2020/01/16/us/jeffrey-epstein-virgin-islands-environment/index.html
Sent from my Verizon, Samsung Galaxy smartphone
EFTA00028482


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=== Page 1 ===
From:
To:
Subject:
Date: Tue, 26 Oct 2021 21:30:37 +0000
She called our 800 line. She said that it took her many years and months to get the courage to call. She called the FBI
hotline but nobody got back to her and she called
She has applied for the Victim Compensation fund.
She wanted to know if she could come to the trial. I told her that I will do whatever I can within the Judges rules to let her
view the trial.
She met Epstein and Maxwell 25 years ago has had a hard time reliving the events.
She has the gown that she was wearing and the presents that they gave her. No pictures.
This might be nothing. She was very nice and asked me for help. She lives in
Victim Witness Coordinator
United States Attorney's Office
Southern District of New York
Tel.
EFTA00028032


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Monday
Date: Mon, 16 Sep 2019 13:51:16 +0000
Totally agree. If you guys are up for handling (or if
is able to handle solo), I'd definitely like to use the time in the
office today before being out for the next few days. But I'm around until noon, so if folks would like me to join, I certainly
can.
From:
Sent: Monday, September 16, 2019 9:50 AM
To:
Subject: RE: Monday
I think this is probably eminently handle-able by one person, unless anybody disagrees?
I'm happy to join if
you'd like, or to just handle, or if you feel like doing it then I'm totally happy to defer (and l'll just continue to prep for
California interviews). Agree with
that certainly in the first instance it's likely to involve getting a list of names and
not particularly credibility-heavy, such that we'd want a couple people to be able to weigh in on the info up the chain.
Thoughts?
From:
Sent: Monday, September 16, 2019 09:26
To:
Subject: RE: Monday
Sorry, this got lost in my inbox. No problem at all if you still need to skip this.
From:
Sent: Friday, September 13, 2019 4:13 PM
To:
Subject: Monday
Sorry to ask, but is it okay if I don't join you guys for Monday's interview with
? I'm trying to find time to
meet with another case team, and it looks like Monday morning would work best for that.
was Epstein's long-time house manager in NY, but we don't know anything beyond that, so the purpose of the
interview is really just to identify other employees and see what if anything he saw at the house.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
Event: Accepted: Epstein estate call
Start Date: 2019-12-02 15:30:00 +0000
End Date: 2019-12-02 16:00:00 +0000
Location: Skype Meeting; Conference ID: 169 269 771;
Class: X-PERSONAL
Comment:
Date Created: 2019-11-25 15:08:57 +0000
Date Modified: 2019-11-25 15:08:57 +0000
Priority: 5
DTSTAMP: 2019-11-25 14:51:06 +0000
Attendee: Weinstein, Marc A.
EFTA00028116


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Fwd: Question re emails
Date: Sat, 10 Oct 2020 12:15:01 +0000
This seems right to me. First, this goes beyond what we said we would do or told the court we would do. Second,
in any event they are separately gathering any potentially relevant emails from the agent with victims. Third, we
have no reason to believe there were significant gaps in retention or collection for
, such that any of his
emails would be in what we already have.
Begin forwarded message:
From:
)"
Date: October 9, 2020 at 9:05:09 PM EDT
To:
(USANYS)"
,
(USANYS)"
Cc:
(USANYS)"
)"
Subject: Question re emails
Chiefs,
Today, we spoke with SA
one of the original FBI agents from the Florida investigation of Epstein.
told us he has a number of emails with AUSA
regarding the case. Our view is that we do not need to collect
those emails from
because we have already received thousands of
emails, which were collected by OPR
and should encompass any emails with the FBI about the Epstein case.
is going to send us any emails he received
from victims or witnesses. We also discussed other documents
has in his possession from the Epstein
investigation and asked him to send us any that sounded potentially discoverable.
Please let us know if this approach sounds right to you or if you would like to discuss.
Thanks,
EFTA00029490


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=== Page 1 ===
From:
"
To:
Cc:
Subject:
Date: Mon, 05 Apr 2021 16:09:06 +0000
Attachments:
Transcript_(06-10-16).pdf
Embedded: Re:_SDNY_investigation.msg; Epstein_-
Hi
Could you please create a potential testifying witness folder for
and include the attached items?
Thanks
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00027373


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=== Page 1 ===
From:
To:
Subject: ODAG Update Memos
Date: Wed, 19 Jun 2019 18:23:03 +0000
Importance: Normal
Do you want to review those? Or should they go straight to Audrey? I confess, most of the ones we have done historically
have been MC related, so they went straight to Audrey, but this one is on Epstein, so if you'd like to see first, let me know.
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: Re: Question re Epstein Relativity Database
Date: Wed, 17 Feb 2021 14:29:46 +0000
Thank you!
On Feb 17, 2021, at 9:28 AM,
(USANYS) [Contractor]
wrote:
I added the field to the view and you should see it when you log into the database.
From:
Sent: Wednesday, February 17, 2021 9:23 AM
To:
(USANYS) [Contractor]
Subject: Re: Question re Epstein Relativity Database
Thanks
How can I get the filepath field to show up when I look in the database?
On Feb 17, 2021, at 9:19 AM,
(USANYS) [Contractor]
wrote:
Hello
Please make sure to use the file path field which will contain the NYC number. Please see screenshot below:
<image001.png>
Thank you.
From:
Sent: Tuesday, February 16, 2021 6:06 PM
To:
(USANYS) [Contractor]
Subject: Question re Epstein Relativity Database
Hi
In the "US V. Epstein (SW Returns)" I'm trying to see the NYC serial number reflecting which device a particular
document came from. In the past, you helped me add a column in Relativity to show the NYC serial number for each
document. Would you be able to help me with that again, please?
Thanks,
EFTA00028201

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00028202


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=== Page 1 ===
From:
To:
Subject: Read: EOUSA-2019-004234 :: US V. Jeffrey Epstein :: 2018R01618 :: Exemption Memo
Date: Thu, 27 May 2021 17:02:56 +0000
EFTA00027712


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=== Page 1 ===
From:
To:
Cc:
Subject: SDNY Press Clips, July 28, 2020
Date: Tue, 28 Jul 2020 21:16:59+0000
AG TESTIMONY
ABC (live updating): https://abcnews.go.com/Politics/barr-testimony-live-updates-ag-faces-questions-
2020/story?id=72029139
MSN:https://www.msn.com/en-gb/news/politics/why-everyone-is-terrible-at-questioning-william-bar/ar-
BB17i3CG
MICHAEL COHEN
MSN: https://www.msn.com/en-us/news/politics/swalwel-barr-has-taken-michael-cohens-job-as-trumps-
fixer/ar-BB17hU5Y
GHISLAINE MAXWELL
Newsweek: https://www.newsweek.com/ghislaine-maxwell-seeks-privacy-over-nude-images-jefrey-epstein-
case-1521010
Daily Beast: https://www.thedailybeast.com/pretty-close-to-a-hundred-new-epstein-accusers?ref=home?
ref=home
MATTERS OF INTEREST
https://www.politico.com/states/new-jersey/story/2020/07/24/christie-giuliani-inspire-codey-bill-to-bar-
prosecutors-from-running-for-office-for-3-years-1303399
NYT: https://www.nytimes.com/2020/07/28/opinion/homeland-security-portland-trump.html
WSJ: https://www.wsj.com/articles/a-young-ceo-an-ex-assistant-and-a-grisly-murder-11595685601
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Maxwell
Date: Mon, 07 Jun 2021 16:51:03 +0000
Inline-Images: image003.jpg; image002.jpg
Excellent. Thanks for your careful handling.
On Jun 7, 2021, at 12:43 PM,
(USANYS)
wrote:
From:
(USAEO)
Sent: Monday, June 7, 2021 12:11 PM
To:
(USANYS)
is
(USAEO)
Subject: RE: Maxwell
Thanks
CISSP, C|EH
Assistant Director & Chief Information Security Officer
Department of Justice
Executive Office for the United States Attorneys'
Office of the Chief Information Officer, Cybersecurity Services Group
<image002.jpg>
From:
(USANYS)
Sent: Monday, June 7, 2021 11:49 AM
To:
(USAEO)
Cc:
(USAEO)
Subject: RE: Maxwell
The issue as it relates to conduct of
is closed.
As to
, he is leaving CACI's employ this Friday, but it has nothing to do with the transfer of documents. I think
we can let it die on Friday.
Thanks,
EFTA00029020

=== Page 2 ===
From:
(USAEO)
Sent: Monday, June 7, 2021 10:56 AM
To:
(USANYS)
Cc:
(USAEO)
Subject: RE: Maxwell
Good morning
GCO's records show that this matter, as it applies to
was already addressed by GCO back on April 19.
Those records show that the USAO took necessary steps to mitigate the action and did not wish to proceed with any
disciplinary actions given the circumstances. Would you like to discuss the circumstances regarding the new incident
with employee
who I understand is also a contractor?
,
Thank you,
Assistant United States Attorney
General Counsel's Office (On Detail)
Executive Office for U.S. Attorneys
From:
(USAEO)
Sent: Friday, June 4, 2021 12:45 PM
To: SOC-EOUSA
is
(USANYS)
Cc:
(USAEO)
i
(USAEO)
>;
(USAEO)
is
(USAEO)
V.
(USAEO)
Subject: RE: Maxwell
Importance: High
SOC,
Please complete the following actions with the district:
I've spoken with
this is not a classified spill. The data label is based on a protective order issued by the court.
The Information Disclosure will need to be completed as there was a substantial amount of PII included in the
upload.
Validate the information was received by the intended recipient.
Insure the data has been removed from
and
I believe the district did speak to the individual on this, not sure if you have any further questions. A summary of the
incident is below for your reference.
On April 13th,
uploaded 5.5 GB of data to
Analysts determined the content of these files were discovery for the Jeffrey Epstein case against Ghislaine
Maxwell. It contained the under-age victim names among other PII.
The CISO notification was sent May 26th and the SOC notification with the Information Disclosure form sent on
May 28th.
EFTA00029021

=== Page 3 ===
Contractor stated they chose to use the Sharefile.com instead of USAfx.
In the last 24 hours, another user from the same district, uploaded less than a GB of data to another law firm that
uses sharefile.com. This user is:
in NYS.
R/G
CISSP, C|EH
Assistant Director & Chief Information Security Officer
Department of Justice
Executive Office for the United States Attorneys'
Office of the Chief Information Officer, Cybersecurity Services Group
<image003.jpg>
From:
(USANYS)
Sent: Thursday, June 3, 2021 1:59 PM
To:
(USAEO)
Subject: FW: Maxwell
From:
(USANYS)
Sent: Thursday, June 3, 2021 1:49 PM
To:
(USANYS)
Cc:
(USANYS)
is
)
Subject: Maxwell
Attached is the Court ordered protective order, which requires us to mark things as confidential (paragraph 7).
The production
uploaded was non-testifying witness 3500. An example page is attached, and includes our
"confidential" marking that we applied pursuant to the protective order. Given that this information clearly contains PII
for victims, the designation is necessary. We'd also ask that this page not be widely disseminated outside of those at
EOUSA who already have access.
Thank you,
Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
EFTA00029022

=== Page 4 ===
THE EXECUTIVE OFFICE
for
STATE
UNITED STATES ATTORNEYS
Cybersecurity Staff
N
THE EXECUTIVE OFFICE
ATTOR
for
UNITED STATES ATTORNEYS
Cybersecurity Staff
EFTA00029023


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=== Page 1 ===
AO 106 (SDNY Rev. 01/17) Application for a Search Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case No.
See Attached Affidavit and its Attachment A
)
)
)
APPLICATION FOR A SEARCH AND SEIZURE WARRANT
I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):
located in the
Southern
District of
New York
, there is now concealed (identify the
person or describe the property to be seized):
See Attached Affidavit and its Attachment A
The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
evidence of a crime;
contraband, fruits of crime, or other items illegally possessed;
property designed for use, intended for use, or used in committing a crime;
a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section(s)
Offense Description(s)
18 U.S.C. §§ 1591 and
Sex trafficking of minors; sex trafficking conspiracy
371
The application is based on these facts:
See Attached Affidavit and its Attachment A
Continued on the attached sheet.
Delayed notice of
days (give exact ending date if more than 30 days:
) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.
Applicant's signature
Special Agent
FBI
Printed name and title
Sworn to before me and signed in my presence.
Date:
Judge's signature
City and state: New York, NY
Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and title
EFTA00028388

=== Page 2 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In the Matter of the Application of the United
TO BE FILED UNDER SEAL
States Of America for a Search and Seizure
Warrant for the Premises Known and Described
Agent Affidavit in Support of
as 9 East 71st Street, New York, New York and
Application for Search and Seizure
Any Closed Containers/Items Contained Therein
Warrant
SOUTHERN DISTRICT OF NEW YORK) SS.:
,
being duly sworn, deposes and says:
I. Introduction
A. Affiant
1.
I have been a Special Agent with the Federal Bureau of Investigation ("FBI") since
2017. During that time, I have participated in numerous investigations and prosecutions of crimes
against children, including the sex trafficking of minors. I have also participated in the execution
of multiple search warrants.
2.
I make this Affidavit in support of an application pursuant to Rule 41 of the Federal
Rules of Criminal Procedure for a warrant to search the premises specified below (the "Subject
Premises") for the purpose of photographing, video-recording or otherwise documenting the
appearance of its interior, and to seize the items and information described in Attachment A. This
affidavit is based upon my personal knowledge; my review of documents and other evidence; and
my conversations with other law enforcement personnel. Because this affidavit is being submitted
for the limited purpose of establishing probable cause, it does not include all the facts that I have
learned during the course of my investigation. Where the contents of documents and the actions,
statements, and conversations of others are reported herein, they are reported in substance and in
part, except where otherwise indicated.
2
2017.08.02
EFTA00028389

=== Page 3 ===
B. The Subject Premises
3.
The Subject Premises are particularly described as a nearly 19,000 square foot
multi-story, single-family residence located at 9 East 71st Street, New York, New York, and
include all locked and closed containers found therein. As detailed further herein, the Subject
Premises is believed to be owned, possessed and controlled by JEFFREY EPSTEIN, a target
subject of this investigation. A photograph of the front entrance to the Subject Premises is included
below:
Google
C. The Target Subject and the Subject Offenses
4.
The Target Subject of this investigation is JEFFREY EPSTEIN.
5.
For the reasons detailed below, I believe that there is probable cause to believe that
the Subject Premises contain evidence, fruits, and instrumentalities of violations of Title 18, United
States Code, Section 1591 (sex trafficking of minors) and Title 18, United States Code, Section
371 (sex trafficking conspiracy) (the "Subject Offenses") by the Target Subject.
3
2017.08.02
EFTA00028390

=== Page 4 ===
II. Probable Cause
A. Probable Cause Regarding the Target Subject's Commission of the
Subject Offenses
6.
On or about July 2, 2019, a grand jury in this District returned an Indictment
charging JEFFREY EPSTEIN with the Subject Offenses. A copy of the Indictment is attached
hereto as Exhibit A and is incorporated by reference.
B. Probable Cause Justifying Search of the Subject Premises
7.
As set forth in Exhibit A, from at least in or about 2002, up to and including at least
in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in the Southern
District of New York and elsewhere. During that time and continuing to the present, EPSTEIN
possessed and controlled the Subject Premises, which is described in Exhibit A as "the New York
Residence."
8.
As further set forth in paragraphs 8 through 10 of Exhibit A, from at least in or
about 2002, up to and including at least in or about 2005, EPSTEIN sexually abused numerous
minor victims at the Subject Premises. In particular, and as alleged in the Indictment, when a
victim arrived at the Subject Premises, she would be escorted to a room inside the Subject Premises
with a massage table, where she would perform a massage on EPSTEIN. The victims, who were
as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress
before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and
scope of physical contact with his victim to include, among other things, sex acts such as groping
and direct and indirect contact with the victims' genitals. EPSTEIN typically would also
masturbate during these sexualized encounters, ask victims to touch him while he masturbated,
and touch victims' genitals with his hands or with sex toys. Following each encounter, EPSTEIN
or one of his employees or associates paid the victim in cash.
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=== Page 5 ===
9.
As set forth in paragraphs 12 through 13 of Exhibit A, to further facilitate his ability
to abuse minor girls in New York, JEFFREY EPSTEIN, the defendant, asked and enticed certain
of his victims to recruit additional minor girls to perform "massages" and similarly engage in sex
acts with EPSTEIN. When a victim would recruit another minor girl for EPSTEIN, he paid both
the victim-recruiter and the new victim hundreds of dollars in cash. EPSTEIN knew that his
victims were underage, including because certain victims told him their age.
10.
One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of
the FBI's investigation of EPSTEIN, other law enforcement officers and I have interviewed
Victim-1. I know from my personal participation of interviews with Victim-1, my conversations
with other law enforcement officers who have interviewed Victim-1, and my review of notes and
reports of other interviews with Victim-1 that Victim-1 has provided the following information, in
substance and in part:
a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-1 on
multiple occasions in the Subject Premises. This sexual abuse all occurred when Victim-1 was
under the age of 18.
b. During that same period, Victim-1 observed multiple floors of the Subject Premises
and numerous individual rooms within the Subject Premises. Victim-1 has provided detailed
descriptions of certain aspects of the interior of the Subject Premises, including Victim-1's
1 In meetings with the Government, Victim-1 has disclosed that, approximately a decade ago, she
committed marriage fraud in order to obtain a green card and, subsequently, U.S. citizenship. She
has also disclosed personal substance abuse, primarily involving the abuse of prescription drugs,
during various periods between the early 2000s and 2019. Victim-1 has also disclosed having
worked for approximately a year at a "happy-ending" massage parlor, performing paid sex acts.
Victim-1 is currently pursuing a civil damages claim against EPSTEIN for his sexual abuse of her.
Information provided by Victim-1 has proven reliable and has been corroborated by independent
evidence, including documents and records obtained during the investigation and the accounts of
other victims whom Victim-1 has never met.
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=== Page 6 ===
memory of specific details regarding the layout, furnishings, decorations, and floor pattern of
various areas within the Subject Premises.
11.
I know from my review of publicly available corporate and property records that at
all times relevant to the Subject Offenses as alleged in the Indictment, the Subject Premises was
owned by Nine East 71st Street Corporation (the "Corporation"). The President of the Corporation
is listed as JEFFREY EPSTEIN, and no other officers or occupants are identified on the
Corporation paperwork. In or around December 2011, the Subject Premises was transferred from
the Corporation to another corporate entity, Maple, Inc., which is registered in the U.S. Virgin
Islands, where EPSTEIN was then known to and continues to reside. Though no officer of Maple,
Inc., is identified in the transfer paperwork, the signature of both the buyer and seller in the
transaction appear to be the same. Moreover, the deed lists the consideration for the transfer of
the Subject Premises as $10, an amount facially inconsistent with a fair market transfer to a third
party.
12.
I know from my participation in this investigation that EPSTEIN has continued to
possess and control the Subject Premises from at least in or about 2002 to the present. In particular,
I know from my review of Sex Offender Registration records that EPSTEIN presently lists the
Subject Premises as one of his residences. Moreover, as described in paragraph 11, above,
although ownership of Subject Premises was transferred from one corporate entity to another in
December 2011, both corporations appear to be under EPSTEIN's control, and EPSTEIN appears
to remain the sole owner and occupant of the Subject Premises.
13.
Additionally, although Victim-1 has not been in the Subject Premises since in or
around 2005, based on my review of publicly available records maintained by the New York City
Department of Buildings ("DOB"), it does not appear that there have been any significant or
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=== Page 7 ===
structural renovations to the interior of the Subject Premises since that time. In particular, the
DOB reflects only three approved alteration permits for the Subject Premises, one in or around
2011 which authorized façade restoration but expressly noted that there would be "no change to
occupancy, use egress or bulk," and two permitting the "installation of heavy duty sidewalk shed"
outside of the Subject Premises at various points, but similarly noting that there would be "no
changes in use, egress or occupancy." As such, while it is possible that certain interior decorations
have changed since 2005, it is probable that structural components of the interior, such as
Victim-1's description of the layout of rooms and floors, among other details, would remain the
same.
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=== Page 8 ===
III. Conclusion and Ancillary Provisions
14.
Based on the foregoing, I respectfully submit that there is probable cause to believe
that photographing, video-recording, and otherwise documenting the appearance of the interior of
the Subject Premises, and seizing the items described in Attachment A, will yield evidence of the
Subject Offenses. In particular, evidence depicting the interior of the Subject Premises and
reflecting the occupancy, ownership, layout, furnishings, decorations, and floor pattern of the
Subject Premises will corroborate Victim-1's account of EPSTEIN's commission of the Subject
Offenses. I further submit that there is probable cause to believe that such evidence will be located
within the Subject Premises and therefore request the court to issue a warrant to seize the items
and information specified in Attachment A to this affidavit and to the Search and Seizure Warrant.
Special Agent
Federal Bureau of Investigation
Sworn to before me on
July 5, 2019
THEHONORABLE BARBARA MOSES
UNITED STATES MAGISTRATE JUDGE
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=== Page 9 ===
ATTACHMENT A
I. Premises to be Searched-Subject Premises
1.
The premises to be searched (the "Subject Premises") are described as a nearly
19,000 square foot multi-story single-family residence located at 9 East 71st Street, New York,
New York, and include all locked and closed containers found therein. A photograph of the front
entrance to the Subject Premises is included below:
Google
II. Items to Be Seized
1. This warrant authorizes executing agents to photograph, video record and otherwise
document the full interior of the Subject Premises, including any items, furnishings, or possessions
therein.
2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows:
a. Evidence concerning occupancy or ownership of the Subject Premises,
including utility and telephone bills, mail envelopes, addressed correspondence,
diaries, statements, identification documents, address books, telephone
directories, and photographs of its occupant(s).
b. Evidence concerning the layout, furnishings, decorations, and floor pattern of
the Subject Premises, including photographs and blueprints of the Subject
Premises.
2017.08.02
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=== Page 10 ===
EXHIBIT A
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=== Page 11 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
SEALED
UNITED STATES OF AMERICA
:
INDICTMENT
:
- V. -
:
19 Cr.
:
JEFFREY EPSTEIN,
:
:
19 CRIM
490
Defendant.
:
:
X
COUNT ONE
(Sex Trafficking Conspiracy)
The Grand Jury charges:
OVERVIEW
1.
As set forth herein, over the course of many
years, JEFFREY EPSTEIN, the defendant, sexually exploited and
abused dozens of minor girls at his homes in Manhattan, New
York, and Palm Beach, Florida, among other locations.
2.
In particular, from at least in or about 2002, up
to and including at least in or about 2005, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
recruited, minor girls to visit his mansion in Manhattan, New
York (the "New York Residence") and his estate in Palm Beach,
Florida (the "Palm Beach Residence") to engage in sex acts with
him, after which he would give the victims hundreds of dollars
in cash. Moreover, and in order to maintain and increase his
supply of victims, EPSTEIN also paid certain of his victims to
recruit additional girls to be similarly abused by EPSTEIN. In
EFTA00028398

=== Page 12 ===
this way, EPSTEIN created a vast network of underage victims for
him to sexually exploit in locations including New York and
Palm Beach.
3.
The victims described herein were as young as 14
years old at the time they were abused by JEFFREY EPSTEIN, the
defendant, and were, for various reasons, often particularly
vulnerable to exploitation. EPSTEIN intentionally sought out
minors and knew that many of his victims were in fact under the
age of 18, including because, in some instances, minor victims
expressly told him their age.
4.
In creating and maintaining this network of minor
victims in multiple states to sexually abuse and exploit,
JEFFREY EPSTEIN, the defendant, worked and conspired with
others, including employees and associates who facilitated his
conduct by, among other things, contacting victims and
scheduling their sexual encounters with EPSTEIN at the New York
Residence and at the Palm Beach Residence.
FACTUAL BACKGROUND
5.
During all time periods charged in this
Indictment, JEFFREY EPSTEIN, the defendant, was a financier with
multiple residences in the continental United States, including
the New York Residence and the Palm Beach Residence.
6.
Beginning in at least 2002, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
2
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=== Page 13 ===
recruited, dozens of minor girls to engage in sex acts with him,
after which EPSTEIN paid the victims hundreds of dollars in
cash, at the New York Residence and the Palm Beach Residence.
7.
In both New York and Florida, JEFFREY EPSTEIN,
the defendant, perpetuated this abuse in similar ways. Victims
were initially recruited to provide "massages" to EPSTEIN, which
would be performed nude or partially nude, would become
increasingly sexual in nature, and would typically include one
or more sex acts. EPSTEIN paid his victims hundreds of dollars
in cash for each encounter. Moreover, EPSTEIN actively
encouraged certain of his victims to recruit additional girls to
be similarly sexually abused. EPSTEIN incentivized his victims
to become recruiters by paying these victim-recruiters hundreds
of dollars for each girl that they brought to EPSTEIN. In so
doing, EPSTEIN maintained a steady supply of new victims to
exploit.
The New York Residence
8. At all times relevant to this Indictment, JEFFREY
EPSTEIN, the defendant, possessed and controlled a multi-story
private residence on the Upper East Side of Manhattan, New York,
i.e., the New York Residence. Between at least in or about 2002
and in or about 2005, EPSTEIN abused numerous minor victims at
the New York Residence by causing these victims to be recruited
to engage in paid sex acts with him.
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EFTA00028400

=== Page 14 ===
9. When a victim arrived at the New York Residence,
she typically would be escorted to a room with a massage table,
where she would perform a massage on JEFFREY EPSTEIN, the
defendant. The victims, who were as young as 14 years of age,
were told by EPSTEIN or other individuals to partially or fully
undress before beginning the "massage." During the encounter,
EPSTEIN would escalate the nature and scope of physical contact
with his victim to include, among other things, sex acts such as
groping and direct and indirect contact with the victim's
genitals. EPSTEIN typically would also masturbate during these
sexualized encounters, ask victims to touch him while he
masturbated, and touch victims' genitals with his hands or with
sex toys.
10. In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash. Victims typically were paid hundreds
of dollars in cash for each encounter.
11. JEFFREY EPSTEIN, the defendant, knew that many of
his New York victims were underage, including because certain
victims told him their age. Further, once these minor victims
were recruited, many were abused by EPSTEIN on multiple
subsequent occasions at the New York Residence. EPSTEIN
sometimes personally contacted victims to schedule appointments
at the New York Residence. In other instances, EPSTEIN directed
4
EFTA00028401

=== Page 15 ===
employees and associates, including a New York-based employee
("Employee-1"), to communicate with victims via phone to arrange
for these victims to return to the New York Residence for
additional sexual encounters with EPSTEIN.
12. Additionally, and to further facilitate his
ability to abuse minor girls in New York, JEFFREY EPSTEIN, the
defendant, asked and enticed certain of his victims to recruit
additional girls to perform "massages" and similarly engage in
sex acts with EPSTEIN. When a victim would recruit another girl
for EPSTEIN, he paid both the victim-recruiter and the new
victim hundreds of dollars in cash. Through these victim-
recruiters, EPSTEIN gained access to and was able to abuse
dozens of additional minor girls.
13. In particular, certain recruiters brought dozens
of additional minor girls to the New York Residence to give
massages to and engage in sex acts with JEFFREY EPSTEIN, the
defendant. EPSTEIN encouraged victims to recruit additional
girls by offering to pay these victim-recruiters for every
additional girl they brought to EPSTEIN. When a victim-
recruiter accompanied a new minor victim to the New York
Residence, both the victim-recruiter and the new minor victim
were paid hundreds of dollars by EPSTEIN for each encounter. In
addition, certain victim-recruiters routinely scheduled these
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EFTA00028402

=== Page 16 ===
encounters through Employee-1, who sometimes asked the
recruiters to bring a specific minor girl for EPSTEIN.
The Palm Beach Residence
14. In addition to recruiting and abusing minor girls
in New York, JEFFREY EPSTEIN, the defendant, created a similar
network of minor girls to victimize in Palm Beach, Florida,
where EPSTEIN owned, possessed and controlled another large
residence, i.e., the Palm Beach Residence. EPSTEIN frequently
traveled from New York to Palm Beach by private jet, before
which an employee or associate would ensure that minor victims
were available for encounters upon his arrival in Florida.
15. At the Palm Beach Residence, JEFFREY EPSTEIN, the
defendant, engaged in a similar course of abusive conduct.
When a victim initially arrived at the Palm Beach Residence, she
would be escorted to a room, sometimes by an employee of
EPSTEIN's, including, at times, two assistants ("Employee-2" and
"Employee-3") who, as described herein, were also responsible
for scheduling sexual encounters with minor victims. Once
inside, the victim would provide a nude or semi-nude massage for
EPSTEIN, who would himself typically be naked. During these
encounters, EPSTEIN would escalate the nature and scope of the
physical contact to include sex acts such as groping and direct
and indirect contact with the victim's genitals. EPSTEIN would
also typically masturbate during these encounters, ask victims
6
EFTA00028403

=== Page 17 ===
to touch him while he masturbated, and touch victims' genitals
with his hands or with sex toys.
16. In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash. Victims typically were paid hundreds
of dollars for each encounter.
17. JEFFREY EPSTEIN, the defendant, knew that certain
of his victims were underage, including because certain victims
told him their age. In addition, as with New York-based
victims, many Florida victims, once recruited, were abused by
JEFFREY EPSTEIN, the defendant, on multiple additional
occasions.
18. JEFFREY EPSTEIN, the defendant, who during the
relevant time period was frequently in New York, would arrange
for Employee-2 or other employees to contact victims by phone in
advance of EPSTEIN's travel to Florida to ensure appointments
were scheduled for when he arrived. In particular, in certain
instances, Employee-2 placed phone calls to minor victims in
Florida to schedule encounters at the Palm Beach Residence. At
the time of certain of those phone calls, EPSTEIN and Employee-2
were in New York, New York. Additionally, certain of the
individuals victimized at the Palm Beach Residence were
contacted by phone by Employee-3 to schedule these encounters.
7
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=== Page 18 ===
19. Moreover, as in New York, to ensure a steady
stream of minor victims, JEFFREY EPSTEIN, the defendant, asked
and enticed certain victims in Florida to recruit other girls to
engage in sex acts. EPSTEIN paid hundreds of dollars to victim-
recruiters for each additional girl they brought to the Palm
Beach Residence.
STATUTORY ALLEGATIONS
20. From at least in or about 2002, up to and
including in or about 2005, in the Southern District of New York
and elsewhere, JEFFREY EPSTEIN, the defendant, and others known
and unknown, willfully and knowingly did combine, conspire,
confederate, and agree together and with each other to commit an
offense against the United States, to wit, sex trafficking of
minors, in violation of Title 18, United States Code, Section
1591 (a) and (b).
21. It was a part and object of the conspiracy that
JEFFREY EPSTEIN, the defendant, and others known and unknown,
would and did, in and affecting interstate and foreign commerce,
recruit, entice, harbor, transport, provide, and obtain, by any
means a person, and to benefit, financially and by receiving
anything of value, from participation in a venture which has
engaged in any such act, knowing that the person had not
attained the age of 18 years and would be caused to engage in a
8
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=== Page 19 ===
commercial sex act, in violation of Title 18, United States
Code, Sections 1591 (a) and (b) (2).
Overt Acts
22. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a. In or about 2004, JEFFREY EPSTEIN, the
defendant, enticed and recruited multiple minor victims,
including minor victims identified herein as Minor Victim-1,
Minor Victim-2, and Minor Victim-3, to engage in sex acts with
EPSTEIN at his residences in Manhattan, New York, and Palm
Beach, Florida, after which he provided them with hundreds of
dollars in cash for each encounter.
b. In or about 2002, Minor Victim-1 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the New York Residence over a
period of years and was paid hundreds of dollars for each
encounter. EPSTEIN also encouraged and enticed Minor Victim-1
to recruit other girls to engage in paid sex acts, which she
did. EPSTEIN asked Minor Victim-1 how old she was, and Minor
Victim-1 answered truthfully.
C.
In or about 2004, Employee-1, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
9
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=== Page 20 ===
a telephone call to Minor Victim-1 in order to schedule an
appointment for Minor Victim-1 to engage in paid sex acts with
EPSTEIN.
d. In or about 2004, Minor Victim-2 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the Palm Beach Residence over a
period of years and was paid hundreds of dollars after each
encounter. EPSTEIN also encouraged and enticed Minor Victim-2
to recruit other girls to engage in paid sex acts, which she
did.
e. In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-2 in order to schedule an
appointment for Minor Victim-2 to engage in paid sex acts with
EPSTEIN.
f. In or about 2005, Minor Victim-3 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the Palm Beach Residence over a
period of years and was paid hundreds of dollars for each
encounter. EPSTEIN also encouraged and enticed Minor Victim-3
to recruit other girls to engage in paid sex acts, which she
did. EPSTEIN asked Minor Victim-3 how old she was, and Minor
Victim-3 answered truthfully.
10
EFTA00028407

=== Page 21 ===
g.
In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-3 in Florida in order to
schedule an appointment for Minor Victim-3 to engage in paid sex
acts with EPSTEIN.
h.
In or about 2004, Employee-3 placed a
telephone call to Minor Victim-3 in order to schedule an
appointment for Minor Victim-3 to engage in paid sex acts with
EPSTEIN.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Sex Trafficking)
The Grand Jury further charges:
23. The allegations contained in paragraphs 1
through 19 and 22 of this Indictment are repeated and realleged
as if fully set forth within.
24. From at least in or about 2002, up to and
including in or about 2005, in the Southern District of New
York, JEFFREY EPSTEIN, the defendant, willfully and knowingly,
in and affecting interstate and foreign commerce, did recruit,
entice, harbor, transport, provide, and obtain by any means a
person, knowing that the person had not attained the age of 18
years and would be caused to engage in a commercial sex act, and
did aid and abet the same, to wit, EPSTEIN recruited, enticed,
harbored, transported, provided, and obtained numerous
11
EFTA00028408

=== Page 22 ===
individuals who were less than 18 years old, including but not
limited to Minor Victim-1, as described above, and who were then
caused to engage in at least one commercial sex act in
Manhattan, New York.
(Title 18, United States Code, Sections 1591 (a),
(b) (2), and 2.)
FORFEITURE ALLEGATIONS
25. As a result of committing the offense alleged in
Count Two of this Indictment, JEFFREY EPSTEIN, the defendant,
shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 1594 (c) (1), any property, real and
personal, that was used or intended to be used to commit or to
facilitate the commission of the offense alleged in Count Two,
and any property, real or personal, constituting or derived from
any proceeds obtained, directly or indirectly, as a result of
the offense alleged in Count Two, or any property traceable to
such property, and the following specific property:
a.
The lot or parcel of land, together with its
buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 9 East 71st Street, New York, New
York, with block number 1386 and lot number 10, owned by
Maple, Inc.
12
EFTA00028409

=== Page 23 ===
Substitute Asset Provision
26. If any of the above-described forfeitable
property, as a result of any act or omission of the defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a
third person;
(c) has been placed beyond the jurisdiction of the Court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot
be subdivided without difficulty;
it is the intent of the United States, pursuant to 21 U.S.C.
§ 853 (p) and 28 U.S.C. $ 2461 (c), to seek forfeiture of any
other property of the defendant up to the value of the above
forfeitable property.
(Title 18, United States Code, Section 1594; Title 21,
United States Code, Section 853 (p); and
Title 28, United States Code, Section 2461.)
Hoppy S. Bunn
FOREPERSON
GEOFFREY S. BERMAN
United States Attorney
13
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=== Page 24 ===
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
JEFFREY EPSTEIN,
Defendant.
INDICTMENT
(18 U.S.C. $$ 371, 1591 (a), (b) (2),
and 2)
GEOFFREY S. BERMAN
United States Attorney
Foreperson
14
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=== Page 25 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
)
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case No.
)
See Attachment A
)
)
SEARCH AND SEIZURE WARRANT
To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Southern
District of
New York
(identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before
(not to exceed 14 days)
in the daytime 6:00 a.m. to 10 p.m.
at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USMJ Initials
I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box)
for
days (not to exceed 30).
until, the facts justifying, the later specific date of
Date and time issued:
Judge's signature
City and state:
New York, NY
Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and title
EFTA00028412

=== Page 26 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Case No.:
Date and time warrant executed:
Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
EFTA00028413

=== Page 27 ===
ATTACHMENT A
I. Premises to be Searched-Subject Premises
1.
The premises to be searched (the "Subject Premises") are described as a nearly
19,000 square foot multi-story single-family residence located at 9 East 71st Street, New York,
New York, and include all locked and closed containers found therein. A photograph of the front
entrance to the Subject Premises is included below:
Google
II. Items to Be Seized
1. This warrant authorizes executing agents to photograph, video record and otherwise
document the full interior of the Subject Premises, including any items, furnishings, or possessions
therein.
2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows:
a. Evidence concerning occupancy or ownership of the Subject Premises,
including utility and telephone bills, mail envelopes, addressed correspondence,
diaries, statements, identification documents, address books, telephone
directories, and photographs of its occupant(s).
b. Evidence concerning the layout, furnishings, decorations, and floor pattern of
the Subject Premises, including photographs and blueprints of the Subject
Premises.
2017.08.02
EFTA00028414


c1: EFTA00027301
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027301.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
August 5, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These discovery materials
are stamped with control numbers SDNY_GM_02753644 through SDNY_GM_02753697.
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. Recently, 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.
EFTA00027301

=== Page 2 ===
Page 2
An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
Files Recovered from Discs
Confidential
Seized from Epstein NY
SDNY GM 02753644
SDNY GM 02753684
Residence
De-Designated Images from
Confidential
SDNY GM 02753685
SDNY GM 02753692
Epstein's Electronic Devices
SDNY GM 02753693
SDNY GM 02753695
Missouri Records
Confidential
SDNY GM 02753696
SDNY GM 02753696
JPMorgan Chase Return
Confidential
SDNY GM 02753697
SDNY GM_02753697
Oxford Letter, 11-07-1995
Confidential
Please note that the files recovered from discs seized from Jeffrey Epstein's New York
residence and the De-Designated Images from Epstein's Electronic Devices are being produced to
you with html files that contain thumbnails of each image and any recovered metadata next to each
thumbnail. In order to view the full size image from a particular row in the html file, click on the
thumbnail, which will automatically open up the full size image from within the folder structure
maintained in the folder entitled "Files." Use of these html files does not require Internet access,
but does require that the file structure within the folder entitled "Files" remain unchanged.
Additionally, certain of the files that were recovered from the discs seized from Epstein's New
York residence are not viewable on the FBI's system. In the interest of completeness, however,
we are producing to you every file that was recovered from those discs, including those that are
not openable or viewable.
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,
United States Attorney
by:
Assistant United States Attorneys
EFTA00027302


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=== Page 1 ===
From:
To:
Subject: RE: travel approval request
Date: Tue, 28 May 2019 14:04:26 +0000
Importance: Normal
To clarify, the cancelled trip was a long-scheduled personal trip. Because of the work travel scheduled for this week, I had
to cancel my outbound personal travel flight, and I was charged $100 for that cancellation (which I paid for personally).
I'm just wondering if that's reimbursable because I wouldn't have been charged that fee if it wasn't for the work trip I now
am going on this week.
thanks,
From:
Sent: Tuesday, May 28, 2019 09:49
To:
Subject: RE: travel approval request
Just a quick question regarding the cancelled trip for this Thursday (5/30/19). Was this trip booked through CWT by phone
or online? If either scenario, l'll need the cancelled record locator to see if it's refundable, and ask them to send me a
document stating it was refunded to your government travel card. Thanks.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Sunday, May 26, 2019 2:31 PM
To:
Subject: FW: travel approval request
Hi
I have a trip scheduled for this week that just got final approval late Friday night, so I made reservations on E2 this
weekend and wanted to let you know in case you need to do things for authorization and/or if you want to consolidate
the reservations (unfortunately I couldn't figure out how to do everything together so ended up with three different
reservations-I'm sorry about that!).
Because I had a previously-scheduled trip to San Francisco on this Thursday,
approved my second leg flight to go
straight there (rather than coming back to NYC). The reservations I made are:
Tuesday, May 28, flight from LGA to PBI
-
JetBlue, departing 1:27 p.m. (arriving 4:25 p.m.)
Tuesday, May 28, hotel in West Palm Beach
EFTA00027760

=== Page 2 ===
-
Hilton West Palm Beach, from May 28 to May 30
Thursday, May 30, flight from PBI to SFO (with layover in ATL)
-
Delta, departing 5:30 a.m. (arriving ATL at 7:12 a.m., departing ATL at 8:10 a.m.) arriving SFO at 10:22 a.m.
If these need to be canceled and re-booked as one itinerary, that's totally fine, I just didn't want to wait until the day
before to at least make the reservations.
Last question is, I had to cancel my New York to San Francisco flight previously scheduled for Thursday morning (because
there were no flights late enough to be after our final interviews in Florida on Wednesday, or early enough to get me back
to New York on Thursday) which incurred a $100 cancellation fee. Is it possible to be reimbursed for that?
Please let me know if any questions at all, apologies again for any inconvenience, and thanks as always.
From:
Sent: Friday, May 24, 2019 21:24
To:
Cc:
Subject: Re: travel approval request
Approved
Sent from my iPad
On May 24, 2019, at 7:21 PM,
wrote:
-- I have previously-scheduled travel to San Francisco next Thursday for a wedding, and the way our victims have
asked to schedule our meetings for our Florida trip, there's no flight back to New York after we expect the interviews to
end on Wednesday (so I couldn't get back to NYC to catch my Thursday morning flight). Is it permissible for me to just
book the second leg of the work trip straight to San Francisco, rather than back to New York? I'd have to take a 5:30
a.m. flight but that way we could do the interviews with all the victims we'd like to meet with. Sorry for any
inconvenience but wanted to check - - thank you!
From:
Sent: Friday, May 24, 2019 16:01
To:
Subject: RE: travel approval request
Thanks
- have a great weekend.
From:
Sent: Friday, May 24, 2019 15:55
To:
Cc:
is
is
Subject: Re: travel approval request
All approved.
Sent from my iPad
EFTA00027761

=== Page 3 ===
On May 24, 2019, at 2:57 PM,
wrote:
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).
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
EFTA00027762

=== Page 4 ===
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West
Palm Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return
on Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00027763


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=== Page 1 ===
From:
To: "Weinstein, Marc A." <marc.weinstein@hugheshubbard.com>
Subject: Accepted: Epstein Estate
Date: Mon, 09 Nov 2020 16:01:01 +0000
Importance: Normal
Attachments: unnamed
EFTA00028118


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=== Page 1 ===
SONDEE
RACINE DOREN PLC
ATTORNEYS
310 WEST FRONT STREET
MAURICE A. BORDEN
JEFFREY L. JOCKS
SUITE 300
KARRIE A. ZEITS
TRAVERSE CITY. MICHIGAN 49684
TEL (231) 947-0400
RONALD W. SONDEE. OF COUNSEL
JOHN P. RACINE, JR.. OF COUNSEL
FAX (231) 947-0748
W. PETER DOREN, OF COUNSEL
www.sondeeracine.com
May 13, 2021
Assistant United States Attorney
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
Re: Interlochen Center for the Arts - Grand Jury Subpoena dated March 26, 2021
Dear
As you know, I represent Interlochen Center for the Arts ("Interlochen"). Enclosed
please find executed custodian certifications along with a document production on behalf of
Interlochen in response to the subpoena duces tecum that was served by your office on the
custodian of records for Interlochen. The enclosed flash drive includes those responsive
documents with a bates range of INT000001 through INT000096.
Consistent with our prior communications, Interlochen is committed to cooperating fully
with your office.
The submission of this letter and the materials enclosed herewith is without prejudice to,
and with full reservation of, all privileges, rights, and protections. Interlochen requests that this
letter and the materials attached hereto be treated as exempt from disclosure, under the Freedom
of Information Act, 5 U.S.C. § 552 ("FOIA"), and as confidential pursuant to 28 C.F.R. $ 16.8.
We submit these materials to you with the understanding that your office's request for
this information is relevant and material to a valid law enforcement purpose. We further submit
these materials to you with the understanding that they will remain confidential unless and until
they are made public by the Court.
Finally, we submit these materials to you with the understanding that, in the event that
any privileged or work-product protected documents are produced, inadvertent or otherwise,
your office will promptly destroy each copy of any such document that is in the possession,
custody, or control of the United States. See, e.g., Fed. R. Civ. P. 26(b)(5)(B).
EFTA00029339

=== Page 2 ===
Assistant United States Attorney
Page 2
May 13, 2021
If you have any questions or concerns, please do not hesitate to contact me.
Sincerely,
SONDEE RACINE & DOREN, PLC
MR
Jeffrey L. Jocks
JLJ: jm
Enclosure
EFTA00029340


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=== Page 1 ===
STATE
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
New York, New York 10007
May 21, 2021
VIA FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the disc containing discovery materials pertinent to Ghislaine Maxwell
(02879-509) is
!
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
Assistant United States Attorneys
EFTA00028579


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From:
(USANYS)"
To:
(USANYS) [Contractor]"
Subject: RE: Subpoenas to Serve
Date: Mon, 19 Aug 2019 16:06:08 +0000
Don't need to scan the OB211 form in. For the fax confirmations, I'm good with you just retaining the record.
From:
(USANYS) [Contractor]
Sent: Monday, August 19, 2019 11:54 AM
To:
(USANYS)
Subject: RE: Subpoenas to Serve
They are all sent. Do I need to resave the subpoenas with the OB211 attached in pdf form? I just printed them separately
and combined them in hard copy form. Also, with the fax confirmations shall I scan them and merge them with the
subpoenas with which they were served?
From:
(USANYS)
Sent: Saturday, August 17, 2019 3:55 PM
To:
(USANYS) [Contractor]
Subject: Subpoenas to Serve
Can you send all of these out? All Epstein related. To each of them can you attach the OB211 form at the end, which I've
also attached. Thanks!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00027225


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=== Page 1 ===
From:
To:
Subject: Travel approval request
Date: Tue, 09 Jul 2019 23:38:12 +0000
Importance: Normal
Traveler,
Please have your legal asst. create a travel auth. in E2 for
to officially fund & approve today. Thanks
Each time you book a trip, you should check these links to see the maximum lodging allowed for your destination city & if
the office will be able to reimburse you for room taxes.
Click here - is the city lodging tax exempt?
State/City tax exempt link https://usanet.usa.doj.gov/staffs/RMP/_layouts/15/WopiFrame2.aspx?
sourcedoc=/staffs/RMP/RMP%20Document%2OLibrary/TravelStateTaxExemption.pdf&action=default
https://www.gsa.gov/travel/plan-book/state-tax-exemption-information-for-government-charge-cards
If applicable, print & submit form to hotel front desk Lodging taxes will no longer be reimbursed for cities that allow an
exemption.
Click here Per diem Rates link - the maximum lodging reimbursable for your destination is Per diem Rates link
Misc. fees maybe considered part of the per night rate & may need to be factored into the total per night cost
PIV Card Driven Link - E2 Solutions, select USA identity provider OR Password Driven link - Click here to log back into the System.
You or your legal asst. should create an E2 travel auth. & book air, rail & or hotel in E2 E2 Solutions, today
Be sure to complete the process by clicking send to approver at the end,. This is the only way your request can reach
for approval.
Rental Cars
Travelers must reserve rental cars via E2-E2 Solutions to ensure the rental car company is under the U.S. Government Car Rental Agreement.
Only Compact or Economy vehicles are authorized. Contact travel coordinator for acceptable justifications/ authorization for bother vehicle classes
Refueling charges charged by the rental car company cannot be reimbursed Be sure to gas up BEFORE you return the car
For travel to TDY sites that are less than 400 miles in distance, the GOV must be used when available. If the GOV is not available, the traveler
should then consider the least
costly economy rental vehicle
The traveler must decline insurance coverage within CONUS but accept the coverage when traveling in OCONUS and foreign locations areas.
Receipts/ Expense claims must be submitted the day after the trip is completed
From:
Sent: Tuesday, July 09, 2019 2:09 PM
To:
is
Cc:
is
Subject: RE: travel approval request
Thanks!
From:
Sent: Tuesday, July 9, 2019 2:08 PM
To:
EFTA00028357

=== Page 2 ===
Cc:
Subject: RE: travel approval request
Approved for the travel and necessary conference room.
Thank you for correctly setting your priorities.
From:
Sent: Tuesday, July 09, 2019 2:00 PM
To:
is
Cc:
Subject: RE: travel approval request
Hi
In connection with the Epstein case (2018R01618), we would like to request permission to travel this week for victim
interviews in Palm Beach, Florida. Our agents will be there starting tomorrow, through Sunday, and our current plan is for
some combination of our team
(
and me) to be there from Thursday** through Sunday. And also same as
last time, we'd like to ask permission to reserve a conference room at the hotel for those four days.
Thanks very much,
***we would never miss the BBQ.
From:
Sent: Wednesday, June 12, 2019 3:28 PM
To:
Cc:
is
Subject: RE: travel approval request
Approved.
From:
Sent: Wednesday, June 12, 2019 2:51 PM
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,
EFTA00028358

=== Page 3 ===
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).
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.
EFTA00028359

=== Page 4 ===
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.
Assistant U.S. Attorney
Southern District of New York
EFTA00028360


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Subject: RE: Sarah Sacks
Date: Thu, 08 Oct 2020 14:58:21 +0000
Very odd.
From:
)
Sent: Thursday, October 08, 2020 10:55 AM
To:
(USANYS)
Subject: RE: Sarah Sacks
Well she never filed a notice on the docket or communicated with me.
From:
(USANYS)
Sent: Thursday, October 8, 2020 10:54 AM
To:
Subject: RE: Sarah Sacks
Hmmm. There are emails from her in this FOIA production about a PI coming to visit "her client."
From:
Sent: Thursday, October 08, 2020 10:53 AM
To:
(USANYS)
Subject: RE: Sarah Sacks
Not to my knowledge.
From:
(USANYS)
Sent: Thursday, October 8, 2020 10:40 AM
To:
Subject: Sarah Sacks
Does she represent Epstein or Tartaglione?
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
Tel:
Fax:
EFTA00029517


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=== Page 1 ===
From:
To:
Subject: RE:
Date: Mon, 04 May 2020 14:30:40 +0000
Attachments: 2020-04-
+ebd.05.04.20.docx
I've gone back through the memo and softened/modified a number of my comments. Do you want to hold off on sending
back to the team until
reaches out? Since we're not telling them to cut the
section (yet), I would be inclined
to send this back now so they can start working through our comments, and then
can reach out later today? I also
think it would be helpful both to morale and to getting
up to speed to have
review the memo as drafted before
telling them to cut the
section.
From:
Sent: Monday, May 4, 2020 10:16 AM
To:
(USANYS)
Cc:
Subject:
Hey
-
Are you able to reach out to the team to set something up for the next couple days? We are about to flip our edits to
their memo back to them, and I want to be sure we have the teleconference with you before this memo is finalized.
Thanks!
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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
(USANYS)"
)"
Cc:
(USANYS)"
Subject: inquiry from Daily News for upcoming Epstein story
Date: Fri, 28 Feb 2020 21:16:13 +0000
Stephen Brown is working on a story about the ongoing investigation into possible co-conspirators of Jeffrey Epstein. The
story will probably appear in Monday's editions of the News. He's seeking (but not expecting, necessarily) guidance on
the following:
The investigation is looking into Ghislaine Maxwell and
Did massage recipients know the girls giving the massages were underage?
Re Epstein's girlfriend
is she viewed as a victim?
EFTA00028040


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=== Page 1 ===
From:
(USANYS)"
To: Christian Everdell
"Mark S. Cohen"
>, Bobbi Sternheim
>, , "Laura
Menninger"
>, , Jeff Pagliuca
Cc:
)"
)"
,
)"
Subject: US V. Maxwell, 20 Cr. 330 (AJN)
Date: Wed, 15 Sep 2021 20:54:12 +0000
Attachments: 2021.09.15_GM_Government_Letter_re_Flatley.pdf;3503-001.pdf
Counsel,
Please see attached.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00029600


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=== Page 1 ===
From:
)"
To:
Conlon
Roberta Kaplan
Jenna Dabbs
"Alexandra Elenowitz-Hess"
Cc:
)"
)"
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Date: Thu, 11 Jul 2019 00:59:22 +0000
Importance: Normal
I'm sorry, this got cut off, let me try one more time -
As you may already know, pursuant to the Crime Victims' Rights Act, specifically 18 U.S.C. 3771(a)(4), a crime victim has
the right to be reasonably heard at certain public proceedings in the district court, including proceedings involving
release. Accordingly, we wanted to be in touch consistent with our responsibilities and obligations-and your client's
rights-under that statute, to see whether your client would like to be heard in any fashion, whether through a
submission, a representation that we can include in our bail submission due Friday, or some other form. Of course no
requirement or obligation, but we would be happy to discuss it if that would be useful.
To the extent this information is useful in your consideration, I can say that we expect to vigorously oppose bail, as we
indicated to the judge we would in the proceedings earlier this week.
Would it make sense to set up a brief call sometime tomorrow, if any of you want to discuss? I should be able to make
myself available whenever is convenient for you (and likely will be just me, as the remainder of the team will be traveling).
thank you,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Wednesday, July 10, 2019 20:57
To:
Conlon'
>; 'Roberta Kaplan'
>; 'Jenna Dabbs'
>; 'Alexandra Elenowitz-Hess'
Cc:
is
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Hi all,
As you may already know, pursuant to the Crime Victims' Rights Act, specifically 18 U.S.C. 3771(a)(4), a crime victim has
the right to be reasonably heard at certain public proceedings in the district court, including proceedings involving
release. Accordingly, we wanted to be in touch consistent with our responsibilities and obligations-and your client's
rights-under that statute, to see whether your client would like to be heard in any fashion, whether through a
submission, a representation that we can include in our bail submission due Friday, or some other form. Of course no
requirement or obligation, but we would be happy to discuss it if that would be useful.
To the extent this information is useful in your consideration, I can say that while I don't want to prejudge the
EFTA00028421

=== Page 2 ===
Would it make sense to set up a brief call sometime tomorrow, if any of you want to discuss? I should be able to make
myself available whenever is convenient for you (and likely will be just me, as the remainder of the team will be traveling).
thank you,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
Subject: RE: draft response to Epstein defense preservation requests
Date: Fri, 09 Aug 2019 17:21:56 +0000
I'm totally available to update it this afternoon if there are edits today, but realistically I don't think the defense can make
much more hay about having gotten a response on the 9th versus the 12th
From:
(USANYS)
Sent: Friday, August 09, 2019 13:20
To:
Cc:
(USANYS)
is
is
)
Subject: Re: draft response to Epstein defense preservation requests
If we don't get this out until Monday is that a problem?
Sent from my iPhone
On Aug 8, 2019, at 5:56 PM,
wrote:
No problem, thanks, and the edits were all straightforward. Updated version attached, everything incorporated, and can
go to
- I'm out of commission the next couple hours but back after that.
thanks,
From:
(USANYS)
Sent: Thursday, August 08, 2019 16:36
To:
is
(USANYS)
Cc:
is
Subject: RE: draft response to Epstein defense preservation requests
Sorry for the delay. Combined edits from both of us, attached. Can you take a look and clean up - we would then like to
give
at least the option of weighing in before we send to defense counsel.
From:
Sent: Thursday, August 8, 2019 11:44 AM
To:
(USANYS)
>;
(USANYS)
Cc:
is
-
Subject: RE: draft response to Epstein defense preservation requests
Wanted to bump this from Tuesday, especially since I know you guys are out tomorrow - hopefully we can send it out
today? Happy to incorporate any edits etc. Thanks.
EFTA00027921

=== Page 2 ===
From:
Sent: Tuesday, August 06, 2019 15:01
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: RE: draft response to Epstein defense preservation requests
This has been in the works for a little while, due to various other things that have come up in the interim, but we didn't
want it to get lost given the discovery motion schedule. The attached is based on our conversations with
including
his email with suggested language for the prefatory language, and responds to the two attached defense letters. Happy
to discuss anytime and to incorporate comments and suggestions.
thanks,
Assistant U.S. Attorney
Southern District of New York
<2019-08-08, JE, letter to defense re preservation requests.docx>
EFTA00027922


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)
[Contractor]"
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
Subject: RE: Epstein and SDNY in 2016
Date: Mon, 12 Oct 2020 21:01:13 +0000
Agreed. To my knowledge, we've never spoken to
about or heard about a second meeting or a meeting about a
perjury charge, so while I don't know that such a meeting occurred, I'm not sure we're in a position right now to push
back.
From:
(USANYS)
Sent: Monday, October 12, 2020 4:54 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS) ;
(USANYS) ;
(USANYS) ;
(USANYS)
Subject: Re: Epstein and SDNY in 2016
Don't think there much we can do here so I'd leave it alone.
Sent from my iPhone
On Oct 12, 2020, at 4:37 PM,
(USANYS) [Contractor]
wrote:
Stephen Brown is filing his story shortly on the Epstein investigation (which includes discussion of the apparent decision
by the Office in 2016 not to pursue the matter). If there's any guidance you think we can and should provide, please let
us know in the next hour.
From:
(USANYS) [Contractor]
Sent: Friday, October 9, 2020 11:15 AM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: FW: Epstein and SDNY in 2016
Stephen Brown at the Daily News is working on a story for next Tuesday about Epstein, Maxwell, and pitches made by
victims' lawyers to
in 2016 that "went nowhere." His email below explains further. His actual questions
are at the end of his email. He has no expectations about guidance, but would appreciate any. Don't know if we should
be forwarding this to
presumably Stephen could contact her on his own.
From: Brown, Stephen
Sent: Thursday, October 8, 2020 4:40 PM
To:
(USANYS) [Contractor]
Subject: Epstein and SDNY in 2016
Hi Jim, Here's a rundown of the story I'm working on. Am seeking guidance from SDNY on the office's thinking at the
time, if FBI was looped in, and who the decision-maker was on this. Apologies for the long email but I figure better to
provide as much detail as possible. My editors are pretty interested in this one.
On Feb. 29, 2016, Epstein victims' attorneys Stan Pottinger, Brad Edwards and Peter Skinner met with then-AUSA
and pitched her on an investigation of the Epstein scheme. I'm told
had questions about
establishing venue, the South Florida NPA, statute of limitations issues and the general DOJ tradition of not second-
guessing another US Attorney. She wondered if the attorneys were proposing an investigation of new conduct, or rather
a re-do of the South Florida case. (This is all from sources familiar).
According to Edwards's book, the team of attorneys left the meeting feeling hopeful.
The AUSA acted confident that a case would be brought against Epstein for crimes committed against
and
others in New York. Of course, first
EFTA00029499

=== Page 2 ===
she had to have facts, witnesses, evidence, and victims of a New York crime.
We assured the prosecutor that the number of victims in New York far exceeded
those discovered in Florida. The group walked out excited that New
York was finally going to bring a case against Epstein. I said to David and
Pete, "Don't hold your breath, the Southern District obviously doesn't know
who they're dealing with yet."
The effort went nowhere, as far as the victims' attorneys know. Then, after attorneys David Boies and Sigrid McCawley
took Maxwell's depositions in the
case, Boies re-approached SDNY, I'm told. The meeting took place in August or
September between Boies, Pottinger and Kramer. They pitched SDNY on charging Maxwell with perjury. They also
believed Epstein, who was paying Maxwell's legal bills, was in a perjury conspiracy. They saw this as a work-around to
concerns about the NPA etc.
But that also went nowhere. Obviously everything changed after the Miami Herald articles and SDNY opened an
investigation under Berman.
In addition to the headline that SDNY initially passed on tackling the case, this story will also note how the contact
between victims' attorneys and SDNY relates to the perjury counts in Maxwell's criminal case. She's said in filings she
was the victim of a "perjury trap," presumably set by Boies in cahoots with SDNY. (From her perspective).
Questions:
Why didn't SDNY pursue the Epstein case in 2016?
Why didn't it pursue perjury counts?
Did SDNY contact the FBI or South Florida prosecutors about Epstein during that period?
Who was the decision maker after Kramer met with the victims' attorneys?
Did Preet make the call?
This story is tentatively scheduled for Tuesday, so this is not super urgent. Hope to hear from you tomorrow.
Thanks,
Stephen Rex Brown
Manhattan Federal Court reporter
NY DAILY NEWS
EFTA00029500


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From:
To:
Subject: Gov't Letter re MV-3 and Victim v2.docx
Date: Sun, 07 Nov 2021 14:16:58 +0000
Attachments: Gov't_Letter_re_MV-3_and_Victim_v2.docx
Not so sure about this letter. Seems like we need to give
a few more hooks. Some thoughts in the attached. Let
me know if you want to connect briefly before you connect with the team.
EFTA00028208


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=== Page 1 ===
Event: New Time Proposed: Meet re: Epstein
Start Date: 2019-06-28 19:00:00 +0000
End Date: 2019-06-28 19:30:00 +0000
Organizer:
)
Location:
Office
Class: X-PERSONAL
Comment:
Date Created: 2019-06-28 19:07:52 +0000
Date Modified: 2019-06-28 19:07:52 +0000
Priority: 5
DTSTAMP: 2019-06-28 18:56:56 +0000
EFTA00028669


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Aircraft info
Date: Tue, 28 Jan 2020 17:04:47
Attachments: SIMPLE_FLIGHT_PLANS_N331JE_(2010-2020).xlsx;
SIMPLE_FLIGHT_PLANS_N491GM_(2000-2009).xlsx;
SIMPLE_FLIGHT_PLANS_N491GM_(2010-2020).xlsx;
SIMPLE_FLIGHT_PLANS_N722JE_(2010-2014).xlsx;
SIMPLE_FLIGHT_PLANS_N722JE_(2015-2020).xlsx
I am sending some of the Flight Plan information that you requested. This information pertains to the helicopters that we
discussed, including N491GM (for which we are still uncertain on the exact dates of ownership.) I hope that there is some
useful information in here. Hopefully, you have someone who is good with Excel. That's the best way to be able to analyze
or quickly find the information you might be looking for.
I have included a few notes here to help you understand the information, but if you have questions, you can give me a
call.
The first thing you are probably going to wonder about are the dates which are part of the Dept Time, Dest Time columns,
but also system tracking dates (more easily understandable) all the way to the right. You'll eventually notice that the
earliest information on this batch of information is from 2007. It was around that time that we started keeping these
records.
The Airport Codes are the ICAO codes. The easiest way to figure out the departure and destination is to either google the
airport identifier or use the list at this site: https://en.wikipedia.org/wiki/ICAO_airport_code
All airports in the continental US begin with the ICAO code K. So if you see a three letter code, it is likely in the US, and
would be prefaced with "K" in the ICAO code. For example, BOS (Boston Logan International Airport is KBOS). JFK is KJFK.
All times (DEPT TIME, DEST TIME, ETA) are in Universal Coordinated Time (UTC) which we use in aviation. The format in
these columns is: CDDTTTT. "C" is an internal code, "DD" is the day, and "TTTT" is the time, UTC, in 24-hour format.
DEPT DOM and DEST DOM reflect whether the Departure or Destination locations are Domestic. This should provide
some context for the airport codes, but I left that in, since international flights should have (are required to file) eAPIS
information, and these columns might make it easier for you to find those flights.
The FIX column isn't likely to be very helpful, but it refers to navigational fixes. It could provide additional clues to
understanding where the flight went, but your best bet is to focus on the Dept and Dest. FIX has some very specific
scenarios where it may be useful, but generally speaking it isn't worth a lot of time and energy, since the dept./dest. and
times and dates are more relevant. The same is true with the ROUTE column.
The MSG TYPE corresponds to the following Codes:
ARR Arrival
AM Amendment
CHG Change
CNL Cancel
DEP Departure
DFP Defense Flight Plan (DVFR)
DM Departure
FP Flight Plan
FPL Flight Plan
LCM Lockheed Message (normally that a callsign received a verbal briefing)
UZ Border crossing
Hopefully you will all be able to find some decent leads or solidify some of your timelines of interest based on the
information provided.
V/r,
EFTA00027585

=== Page 2 ===
Special Agent
Law Enforcement Assistance Program (LEAP)
Federal Aviation Administration, AXE-810
From:
Sent: Tuesday, January 14, 2020 11:26 AM
To:
Cc:
Subject: RE: Aircraft info
Please call when you get this information.
I have attached Registration information for N331JE and N722JE. N722JE is the entire aircraft registration file. N331JE is
just the section that appeared to contain all relevant information to your case. I can give you the entire file if you think
there is more that might be applicable, and certified copies of the entire files can be obtained if they need to be used in
court. In my experience, sending the entire aircraft registration file from the start usually is daunting for the investigators,
and leads to tons of questions just trying to figure out what might be relevant. Sometimes aircraft files are 300 pages or
more, and that can be frustrating when maybe only 20 were relevant to the SUBJECT.
I have also attached the LLC Documents for Hyperion Air LLC which is the registered owner for both N331JE and N722JE.
I have attached the Airman File for the SUBJECT, which is encrypted due to PII. I will send the password in a follow-on e-
mail. I looked at the medical file, but I believe the information contained therein has limited value to your investigation. I
have created a separate encrypted document with only the information that may be helpful, so that you can evaluate
potentially relevant information while maintaining medical privacy. If the information in the airman file or the document I
created turns out to be critical evidence for your case, then certified copies of the airman and/or medical file can be
obtained at a later date.
As I mentioned previously, I want to clarify some details regarding the helicopters. What I found appeared to be slightly
different from what was included in the original e-mail to me below.
N722JE
nicknamed Air Ghislaine 2
Helicopter
Sikorsky S-76C
Aircraft Serial Number: 760750
Date Current Registration issued: 17 July 2019
Current Registered Owner: Hyperion Air LLC
Current Registration Signed By: Lawrence P. Visoski, Jr.
Aircraft Purchased from: ASI Wings LLC
Date of Purchase: 13 June 2019
Seller Signature: James D. Clark
Special Registration Number Issued on: Paperwork not properly submitted by requestor
Requested Special Registration Number: N162AE
Date Requested Special Registration Number: 16 September 2011 (one year authorization)
Bill of Sale: 18 July 2011
Aircraft Purchased by ASI Wings, LLC from: Freedom Air International, Inc
Aircraft Registered by: Freedom Air International, Inc
Registration of Aircraft on 02 August 2010 Signed By: Darren K. Indyke
Name Change To: Shmitka Air Inc
Name Change From: Air Ghislaine Inc
Date of Registered Owner Name Change: 11 February 2010
Requested Special Registration Number: N722JE
Special Registration Number Issued on: 10 March 2010
Date Requested Special Registration Number: 11 February 2010
Aircraft Registered by: Air Ghislaine, Inc.
Registration of Aircraft on 29 December 2008 Signed By: Larry Visoski
EFTA00027586

=== Page 3 ===
Aircraft Purchased from Sikorsky on: 30 December 2008
Aircraft Assigned Registration Number: N750A
N331JE
Helicopter
Bell 430
Aircraft Serial Number: 49078
Date Current Registration issued: 19 November 2019
Current Registered Owner: Hyperion Air, LLC
Current Registration Signed By: Lawrence Visoski
Aircraft Purchased from: Hyperion Air, Inc.
Date of Purchase: 12 August 2013
Seller Signature: Darren K. Indyke
Special Registration Number Placed on Aircraft: 25 June 2012
Requested Special Registration Number: N331JE
Special Registration Number Issued on: 04 June 2012
Date Requested Special Registration Number: 22 May 2012
Aircraft Purchased from: Bovale Developments, Inc.
Date of Purchase: 06 March 2012
Seller Signature: William P. Merriam Jr
Aircraft Registration Number: N901RL
N491GM
Helicopter
Bell 407
I have not yet been able to identify the serial number for N491GM which should lead to the registration documents. If you
know who the aircraft was sold to, or what registration number it currently uses, I would be able to obtain those
documents.
Finally, does this surname have any relevance to your case (potential pilot of one of the aircraft)? VAN HEURCK
V/r.
Law Enforcement Assistance Program (LEAP)
Federal Aviation Administration, AXE-810
From:
Sent: Friday, December 6, 2019 1:18 PM
To:
Cc:
Subject: Aircraft info
Hi
It was nice talking with you yesterday. Thanks for your assistance with this. Please see the below email of aircraft
information.
Below are the aircrafts we believe Maxwell has/had been using. The helicopter we know that she personally piloted, while
the jets we know her to be a passenger. You'll notice some of the aircrafts will be associated with Jeffrey Epstein, as she
traveled with him frequently. Any information you are able to provide would be helpful. If there is additional passenger
manifests for each of these aircrafts we'd like to know that as well. I know we discussed that sometimes that's not
available. As you can imagine, this case is high profile, so I appreciate any discretion you can make on your part.
Please let me know if I left something out that would be able to assist you in any way.
Thanks again,
Special Agent
FBI New York
Child Exploitation/Human Trafficking
EFTA00027587

=== Page 4 ===
From:
Sent: Friday, December 06, 2019 1:02 PM
To:
Subject: Aircraft info
Hello!
Below is the info for the helicopters and the private jet.
Name: Ghislaine Noelle Maxwell
Certificate: Private Pilot
Date of Issue: 10/2/2007
Helicopter: Rotorcraft
0 Sikorsky S-76C; nicknamed Air Ghislaine 2
Likely Serial Number: 760750
0 States certificate was issued on 7/17/2019
Helicopter Info:
Tail Number: N722JE
Type: 2008 Keystone Helicopter S-76C
Prior Registration: Freedom Air International Inc, 103 Folk Rd St 202 Wilmington, DE 19803
Old Tail Number: N331JE
o Serial Number: 49078
0 States certificate was issued on 9/6/2013
2nd Helicopter:
Bell Jet Ranger
Tail Number: N491GM
Nicknamed: Air Ghislaine 1
Private Jet:
Tail Number: N212JE
Serial Number: 5173
Type: GV SP (G550) Fixed Wing Multi Engine
Certificate Issued: 3/31/2017
Tail Number: N120JE
Serial Number: 1085
Type: G-IV Fixed Wing Multi Engine
Certificate Issued: 5/30/2013
Tail Number: N909JE
0 Serial Number: 151
Type: G1159B
Certificate Issued: 11/18/2013
Tail Number: N908JE
0 Serial Number: 20115
Type: Boeing 727-31
Certificate Issued: 1/25/2001
Let me know if you need anything else,
EFTA00027588


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=== Page 1 ===
Event: Accepted: Jeffrey Epstein Estate/Southern Country International
Bank/USVI
Start Date: 2020-04-03 15:00:00 +0000
End Date: 2020-04-03 16:00:00 +0000
Location: Conference Line Call-In (see below)
Class: X-PERSONAL
Comment:
Date Created: 2020-04-02 12:21:16 +0000
Date Modified: 2020-04-02 12:21:16 +0000
Priority: 5
DTSTAMP: 2020-04-02 12:06:08 +0000
Attendee:
(USAVI)
EFTA00028350


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=== Page 1 ===
PROFFER AGREEMENT
With respect to the meeting of
"Client") and her attorney, Joseph
Nascimento, Esq., with Assistant United States Attorneys
and
to be
held on July 12, 2019 ("the meeting"), the following understandings exist:
(1) THIS IS NOT A COOPERATION AGREEMENT. The Client has agreed to
provide the Government with information, and to respond to questions, so that the Government
may evaluate Client's information and responses in making prosecutive decisions. By receiving
Client's proffer, the Government does not agree to make a motion on the Client's behalf or to enter
into a cooperation agreement, plea agreement, immunity or non-prosecution agreement. The
Government makes no representation about the likelihood that any such agreement will be reached
in connection with this proffer.
(2) In any prosecution brought against Client by this Office, except as provided below the
Government will not offer in evidence on its case-in-chief, or in connection with any sentencing
proceeding for the purpose of determining an appropriate sentence, any statements made by Client
at the meeting, except (a) in a prosecution for false statements, obstruction of justice or perjury
with respect to any acts committed or statements made during or after the meeting or testimony
given after the meeting; or (b) if, at any time following the meeting, Client becomes a fugitive
from justice.
(3) Notwithstanding item (2) above: (a) the Government may use information derived
directly or indirectly from the meeting for the purpose of obtaining leads to other evidence, which
evidence may be used in any prosecution of Client by the Government; (b) in any prosecution
brought against Client, the Government may use statements made by Client at the meeting and all
evidence obtained directly or indirectly therefrom for the purpose of cross-examination should
Client testify; and (c) the Government may also use statements made by Client at the meeting to
rebut any evidence or arguments offered by or on behalf of Client (including arguments made or
issues raised sua sponte by the District Court) at any stage of the criminal prosecution (including
bail, all phases of trial, and sentencing) in any prosecution brought against Client.
(4) The Client understands and agrees that in the event the Client seeks to qualify for a
reduction in sentence under Title 18, United States Code, Section 3553(f), United States
Sentencing Guidelines, Sections 2D1.1(b)(18) or 5C1.2, or Fed. R. Crim. P. 35(b), the Office may
offer or use at any stage of the criminal proceeding any statement made by Client during the
meeting, and all evidence obtained directly or indirectly therefrom, to the extent such use is
consistent with Section 402 of the First Step Act of 2018.
(5) To the extent that the Government is entitled under this Agreement to offer in evidence
any statements made by Client or leads obtained therefrom, Client shall assert no claim under the
United States Constitution, any statute, Rule 410 of the Federal Rules of Evidence, or any other
federal rule that such statements or any leads therefrom should be suppressed. It is the intent of
this Agreement to waive all rights in the foregoing respects.
01.14.2019
EFTA00027643

=== Page 2 ===
(6) If this Office receives a request from another prosecutor's office for access to
information obtained pursuant to this Proffer Agreement, this Office may furnish such information
but will do so only on the condition that the requesting office honor the provisions of this
Agreement.
(7) It is further understood that this Agreement is limited to the statements made by Client
at the meeting and does not apply to any oral, written or recorded statements made by Client at
any other time. No understandings, promises, agreements and/or conditions have been entered
into with respect to the meeting other than those set forth in this Agreement and none will be
entered into unless in writing and signed by all parties.
(8) The understandings set forth in paragraphs 1 through 7 above extend to the continuation
of this meeting on the dates that appear below.
(9) Client and Attorney acknowledge that they have fully discussed and understand every
paragraph and clause in this Agreement and the consequences thereof.
Dated: West Palm Beach, Florida
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
by:
Client
Assistant United States Attorney
MA Attorney for Client
Dates of Continuation
Initials of counsel, Client, AUSA, witness
9/10/19
5/14/21
[by video]
8/20/21
9/30/21
10/1/21
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=== Page 1 ===
Event: Accepted: Epstein Meeting (Please hold the time)
Start Date: 2020-01-16 19:00:00 +0000
End Date: 2020-01-16 20:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-01-11 01:09:34 +0000
Date Modified: 2020-01-11 01:09:34 +0000
Priority: 5
DTSTAMP: 2020-01-10 18:55:26 +0000
Attendee:
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=== Page 1 ===
From:
"
To:
Subject:
3500
Date: Thu, 07 Oct 2021 20:49:47 +0000
Attachments:
.pdf;
;
Here are the 302 and notes from the prior
interview.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
Cell:
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UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT
ORAL ARGUMENT STATEMENT (Local Rule 34.1(a))
TO REQUEST ORAL ARGUMENT, FILL OUT THIS FORM AND FILE IT WITH THE CLERK
WITHIN 14 DAYS AFTER THE FILING OF THE LAST APPELLEE BRIEF.
IF THIS FORM IS NOT TIMELY FILED, YOU WILL NOT BE PERMITTED TO ARGUE IN PERSON.
Short Title of Case:
Docket No.:
Name of Party:
Status of Party (e.g., appellant, cross-appellee, etc.):
Check one of the three options below:
I want oral argument.
An attorney whose preference depends on whether other
-
attorneys will argue should consider conferring before
I want oral argument only if
requesting argument. After the appeal has been
at least one other party does.
scheduled for oral argument, a motion by counsel to forgo
oral argument, even on consent, may be denied.
I do not want oral argument.
If no party wants oral argument, the case will be decided on the basis of the written briefs. If you want oral
argument, you must appear in Court on the date set by the Court for oral argument.
The Court may determine to decide a case without oral argument even if the parties request it.
If you want oral argument, state the name of the person who will argue:
Name:
(An attorney must be admitted to practice before the Court in accordance with Local Rule 46.1.)
If you want oral argument, list any dates (including religious holidays), that fall in the interval from 6 to 20 weeks
after the due date of this form, that the person who will argue is not available to appear in Court:
ANYONE WHO WANTS TO ARGUE MUST UPDATE THE COURT IN WRITING OF ANY CHANGE IN
AVAILABILITY. THE COURT MAY CONSIDER A FAILURE TO UPDATE ABOUT AVAILABILITY WHEN
DECIDING A MOTION TO POSTPONE A SET ARGUMENT DATE.
Filed by:
Print Name:
Date:
Signature:
(Revised December 2011)
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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: updates
Date: Sat, 06 Jul 2019 22:00:04 +0000
Importance: Normal
Awesome, thanks! I'll loop you in if I get any calls from the search team. I spoke to the agents doing the approaches of
Maxwell/R
our agents are doing the other approaches) today, so they should call us with
updates tonight.
From:
Sent: Saturday, July 6, 2019 5:56 PM
To:
is
Subject: FW: updates
I'm logged on remotely and available to write supplemental warrants if the FBI finds additional items that we want to
seize. Also happy to help with anything else that may come up.
From: Berman, Geoffrey (USANYS)
Sent: Saturday, July 6, 2019 5:54 PM
To:
Cc:
(US
is
is
Subject: Re: updates
Epstein is in custody. Search warrants being executed now. Geoff
On Jul 6, 2019, at 12:44 PM, Berman, Geoffrey (USANYS)
wrote:
tells me that he is confirmed on board. Wheels up. Geoff
On Jul 6, 2019, at 11:10 AM,
)
wrote:
Good morning all-
asked me to pass along two quick updates. First, Judge Moses signed the search warrant this morning.
Second, our case agent told us that FBI received a flight manifest from CBP last night. The passengers listed are
Epstein and two pilots. Of course, that is subject to change, and I'm told that FBI will try to get confirmation of the
passengers after the flight takes off.
Assistant United States Attorney
Southern District of New York
(212) 637-2225
EFTA00028381

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c0:
=== Page 1 ===
From:
"
(NY) (FBI)"
To:
)"
>,
)"
Cc:
"
(
)"
Subject: FW:
medical list
Date: Fri, 07 Feb 2020 21:27:18 +0000
FYI
Original Message
From:
[mailto:
Sent: Wednesday, January 29, 2020 2:31 AM
To:
(NY) (FBI)
Cc:
(RO) (FBI)
(NY) (FBI)
Subject: Re:
medical list
Hi
After Monday's bizarre and insulting appearance of Geoffrey Berman, please may I arrange a call with you all, at your earliest
convenience.
Best
> On 17 Jan 2020, at 19:17,
(NY) (FBI)
wrote:
>
V
> Hi
as
stated I thought since I haven't spoken to you before this would be a good opportunity. I also spoke to the case
agent
and thought we could call you together; to answer any questions that we are able about the case.
V
> Would you be free January 22? I'm thinking
g. Let me know if that would work for you. If so - let
us know what time and a number to contact you at.
>
> Have a great weekend and looking forward to speaking with you.
V
V
>
> -
V
> On Jan 17, 2020 1:11 PM,
(RO) (FBI)"
wrote:
> Good evening
>
> As promised, attached is a complete medical list that the
provides for those seeking medical services.
>
> You will see in the document that there are psychological services listed on page 22.
V
>
copied here, would like to go over this list with you and assist you in choosing a therapist. I will leave it to you two to
connect at a time convenient for you both. You may even decide to see more than one doctor until you decide with whom you're
comfortable.
V
> Thank you again for your patience this month.
V
> Have a great weekend!
EFTA00027554

=== Page 2 ===
V V V V V V V V YYY
Victim Services Manager
> FBI
Region
> Email:
EFTA00027555


c1: EFTA00027926
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027926.pdf
c6: pdf
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c0:
=== Page 1 ===
From:
"
(USANYS)"
To: "Berman, Geoffrey (USANYS)"
Cc:
(USANYS)"
Subject: RE: Briefings
Date: Wed, 20 Feb 2019 23:25:51 +0000
Importance: Normal
From: Berman, Geoffrey (USANYS)
Sent: Tuesday, February 19, 2019 6:31 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
(USANYS)
V.
(USANYS)
Subject: Re: Briefings
You can leave off Epstein
On Feb 19, 2019, at 6:23 PM,
(USANYS)
wrote:
I have asked the teams to get
detailed briefing memos by tomorrow, and will turn them to you by Thursday
morning, on the following:
-
Epstein
If there's anything else you'd like to include
let us know.
Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
EFTA00027926


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 131 Filed 02/05/21 Page & of 3
DIPARTMENT
OF
U.S. DEPARTMENT OF JUSTICE
*
Federal Bureau of Prisons
THERE
USDC SDNY
Metropolitan Detention Center
OF
DOCUMENT
BUREAU
ELECTRONICALLY FILED
DOC #:
80 29h Street
DATE FILED: 2/2/21
Brooklyn, New York 11232
January 25, 2021
BY ECF
Having considered the request
submitted by the Bureau of Prisons
The Honorable Alison J. Nathan
2/2/21
("BOP") that the Court vacate its
United States District Court
Southern District of New York
Alim
Netto
January 15, 2021 Order, Dkt. No. 117,
as well as the Government's and the
40 Foley Square
New York, NY 10007
Defendant's responses, Dkt. Nos. 129,
ALISON J. NATHAN
United States District Judge
130, the Court hereby DENIES the
BOP's request to vacate the Order.
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
so ORDERED.
Ghislaine Maxwell, Reg. No. 02879-509
Dear Judge Nathan:
This letter is written in response to Order granted on January 15, 2021, concerning Ghislaine
Maxwell, Reg. 02879-509., an inmate currently confined at the Metropolitan Detention Center ("MDC") in
Brooklyn, New York. The MDC Brooklyn respectfully requests that Your Honor vacate the Order given
MDC Brooklyn was not given the opportunity to object to defense counsel's claims, although the objection
had been reiterated to the U.S. Attorney's Office numerous times.
Defense counsel expressed various concerns regarding Ms. Maxwell's confinement limiting her
access to discovery. However, Ms. Maxwell has received a significant amount of time to review her
discovery. On November 18, 2020, the Government provided the MDC Brooklyn with a laptop for Ms.
Maxwell to use to review discovery. Ms. Maxwell has been and will continue to be permitted to use that
laptop to review her discovery for thirteen (13) hours per day, five (5) days per week. In addition to the
Government laptop, she has access to the MDC Brooklyn discovery computers. Although defense counsel
has indicated that the MDC Brooklyn discovery computers are not equipped to read all of her electronic
discovery, the computers are capable of reviewing most of the electronic discovery. Despite defense
counsel's claim that Ms. Maxwell's lacks sufficient time to fully review her discovery, her consistent use of
Government laptop and MDC Brooklyn's discovery computers undercuts this claim.
Moreover, Ms. Maxwell continues to have contact with her legal counsel five (5) days per week, three
(3) hours per day via video-teleconference and via telephone; this is far more time than any other MDC
inmate is allotted to communicate with their attorneys.
EFTA00028163

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 131 Filed 02/05/21 Page 3 of 3
We respectfully request that Your Honor vacate the order of January 15, 2021, and allow the
institution to resume the prior schedule of laptop access, Monday through Friday, 7:00 AM - 8:00 PM.
Respectfully submitted,
/s/
Staff Attorney
MDC Brooklyn
Federal Bureau of Prisons
EFTA00028164


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Date: Fri, 14 May 2021 15:40:29 +0000
This is all set.
From:
Sent: Friday, May 14, 2021 10:42 AM
To:
[Contractor]
i
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: FW: Subpoena to Interlochen Center for the Arts
Could you please add the attached to the subpoena folder and to the next discovery production? Thanks!
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, May 13, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
Attached is what went in the mail today.
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: Wednesday, May 12, 2021 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
EFTA00029342

=== Page 2 ===
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on this.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Monday, April 26, 2021 10:32 AM
To:
)
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm working on it and hope to have it complete and ready in the next couple of days.
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: Monday, April 26, 2021 at 9:28 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Could you please let us know when you expect to produce these materials?
Thanks very much,
EFTA00029343

=== Page 3 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, March 26, 2021 5:33 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Just confirming receipt. Also, I'm hopeful that we can have everything gathered by April 12th. However, I'll be out of the
office for the next week so it might be delayed. Will that be a problem?
In addition, and just for confirmation's sake, you are ok that we will make reasonable efforts to notify the
parents/students of the subpoena prior to compliance with the subpoena correct?
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, March 26, 2021 at 3:37 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
Thanks again for taking the time to speak with me this morning. As we discussed, I'm attaching a subpoena for additional
student records.
Thank you,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:41 PM
To:
Cc:
)
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Sounds good. Yes, that is the best number.
EFTA00029344

=== Page 4 ===
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, March 25, 2021 at 4:40 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Thanks so much-let's plan to talk at 9:30 tomorrow morning, if that works for you. Is this the best number to reach you
then: 231-947-0400
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:32 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm available between 9am and 10am, and then again after 11am.
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
EFTA00029345

=== Page 5 ===
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, March 25, 2021 at 3:41 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Are you available for a quick call tomorrow morning?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, January 7, 2021 11:10 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
231-947-0400
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, January 7, 2021 at 10:37 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff- what is the best number to reach you this morning? Thanks.
Sent from my iPhone
EFTA00029346

=== Page 6 ===
On Jan 5, 2021, at 3:21 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me.
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: Monday, January 4, 2021 at 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
That would be great, thanks. Would Thursday at 11:30 work for you?
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Sure. Does Wednesday or Thursday morning work?
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: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
EFTA00029347

=== Page 7 ===
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Are you available for a call sometime in the next few weeks? We have one or two follow up
questions that would be helpful to talk through.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, December 30, 2020 2:37 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
Sorry about the delay. Interlochen doesn't have any other documents regarding tuition payment information or
payments by Epstein or Epstein entities.
Let me know if you have any other questions.
Thanks,
Jeff Jocks
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: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
EFTA00029348

=== Page 8 ===
From:
)
Sent: Monday, November 16, 2020 3:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
is
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. I'm following up on our conversation from earlier this month to see if you have any updates on
the categories of documents we discussed.
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 11:15 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
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,
EFTA00029349

=== Page 9 ===
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.
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
EFTA00029350

=== Page 10 ===
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,
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
EFTA00029351

=== Page 11 ===
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: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com>, "Donnini, George B." <donnini@butzel.com>
Cc:
)"
i
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
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.
EFTA00029352

=== Page 12 ===
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, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
)"
=
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
EFTA00029353


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=== Page 1 ===
From:
To:
Subject: RE:
Date: Thu, 12 Aug 2021 21:11:36 +0000
Attachments: 2020.04.24_Opposition_to_Thomas_Motion_to_Compel_-_final.docx;
2020.04.24_Govt_Opposition_to_Thomas_Motion_to_Compel_-_ECF_filed.pdf
Weird. This should be it.
From:
Sent: Thursday, August 12, 2021 2:03 PM
To:
Subject:
Hi
In the prosecution team memo folder there is a file labled "OppositiontoThomasmotion." I can't open
it. Do you have the file? Thanks.
EFTA00027306


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=== Page 1 ===
From:
Jeffrey Epstein
To:
Jes Staley
Sent:
9/28/2010 9:22:17 PM
Subject:
prince Andrew would like much more to represent casanov in china than tim collins
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to
, and
destroy this communication and all copies thereof,
including all attachments.
Confidential Treatment Requested by JPMorgan Chase
JPM-SDNY-00001091
EFTA00029434


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=== Page 1 ===
CG
COHEN & GRESSER LLP
Christian R. Everdell
November 8, 2021
BY EMAIL
United States Attorney's Office
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Re: United States V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Counsel:
Pursuant to the Court's Order dated June 2, 2021 (Dkt. 297), we write to provide the
government with the defense's disclosures under Rule 16(b)(1)(A) and (b)(1)(B) of the Federal
Rules of Criminal Procedure.
As the government is aware, the defense is under no obligation to present a defense case
and whether we will do so remains subject to the developments at trial. Nevertheless, in
accordance with the Court's order, we provide below a preliminary list of documents that the
defense may use in its case-in-chief, should we decide to present a defense case.
We note that Rule 16(b)(1)(A) requires disclosure only of documents and other items that
are "within the defendant's possession, custody, or control; and [that] the defendant intends to
use in the defendant's case-in-chief at trial." Fed. R. Crim. P. 16(b)(1)(A) (emphasis added).
Rule 16(b)(1)(A) does not require the defense to disclose, for example, potential impeachment
evidence or documents that the defense may use to refresh a witness's recollection during the
government's case-in-chief. See United States V. Medearis, 380 F.3d 1049, 1057 (8th Cir. 2004)
(Rule 16(b)(1)(A) does not require disclosure of impeachment evidence); United States V. Moore,
208 F.3d 577, 579 (7th Cir. 2000) (same); United States V. Hatfield, No. 06 Cr. 550 (JS), 2009 WL
10673619, at *1-2 (E.D.N.Y. Apr. 22, 2009) (same) (citing Medearis and Moore); see also United
States V. Gray-Burriss, 791 F.3d 50, 57-58 & n.2 (D.C. Cir. 2015) (using documents to refresh
recollection of government's witnesses not covered by Rule 16); United States V. King, 703 F.2d
119, 126 n.6 (5th Cir.1983) (noting that "even though the documents were excluded from
evidence" because of defendant's failure to make a Rule 16 disclosure, "[d]efense counsel was
allowed to use the documents to refresh the recollection of witnesses").
EFTA00028274

=== Page 2 ===
November 8, 2021
Page 2
We also note the following: First, the defense continues to investigate and prepare its case
for trial, which is still three weeks away. The defense has not made final determinations about
which documents it may use in the defense case-in-chief, should we decide to present one.
Indeed, those decisions will depend heavily on developments at trial. Second, the defense may
receive documents from Rule 17 subpoenas or other document requests which the defense may
want to use in any case-in-chief. Third, the government is still producing Rule 16 discovery, 3500
material, and Giglio material, which may require additional investigation and may, in turn, yield
additional documents that the defense may wish to use in any case-in-chief.
To that end, the defense reserves its right to supplement these disclosures. The defense
further recognizes that its disclosure obligations under Rule 16 are ongoing, and we will produce
any additional Rule 16 materials to the government as we identify them. See Fed. R. Crim. P.
16(c).
Defense Rule 16 Disclosure
Pursuant to Rule 16(b)(1)(A), below is the preliminary list of the documents that the
defense may use should it elect to present a case-in-chief. We have attached copies of the
documents listed below if they were not provided to the defense by the government in discovery.
Otherwise, we provide the Bates numbers for the produced documents. Because we have already
provided the government with the defense expert notice, which referenced articles, reports, and
other materials they relied upon to prepare their testimony, we have not repeated that information
here. See Fed. R. Crim. P. 16(b)(1)(B) & (b)(1)(C).
1. AT&T phone records
SDNY_GM_00514773-00514915
Certification - attached as Exhibit A
2. Federal Express records
SDNY_GM_00338750-343831
Certification - attached as Exhibit B
List of certified invoices (highlighted in yellow) - attached as Exhibit C
3. Customs and Border Patrol records
SDNY_GM_02753139-02753143
SDNY_GM_00000799-00000833
4. Interlochen records
SDNY_GM_00004784-00005076
SDNY_GM_02753433-02753440
SDNY_GM_02753466-02753528
Additional records - attached as Exhibit D
EFTA00028275

=== Page 3 ===
November 8, 2021
Page 3
5. Shopper's Travel records
SDNY_GM_00006061-00006079
6. Larry Visoski flight manifests
SDNY_GM_00405330-00405565
SDNY_GM_00405788-00405969
7. General Release, Epstein Victims' Compensation Program
(
Attached as Exhibit E
8. General Release, Epstein Victims' Compensation Program
Not attached - pending release by Judge Koeltl in Doe V. Indyke, 20 Civ. 484
(JGK) (S.D.N.Y. 2020)
9. Floorplans, Palm Beach residence
SDNY_GM_00328519-00328521
10. Palm Beach Police Department incident reports
E.g., 3501.014-004
11. Jeffrey Epstein Non-Prosecution Agreement
Attached as Exhibit F
12. February 29, 2016 Meeting Materials
SDNY_GM_02742753-02742762
SDNY_GM_02742878-02742892
SDNY_GM_02742895-02742962
Sincerely,
/s/ Christian R. Everdell
Christian R. Everdell
COHEN & GRESSER LLP
cc:
All counsel of record (by email)
EFTA00028276


c1: EFTA00027528
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027528.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Chris Dilorio
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Date: Wed, 23 Oct 2019 13:55:40 +0000
Attachments: IMG_7021.jpg
Inline-Images: image.png
From: Chris Dilorio
Sent: Thursday, July 18, 2019 11:54 AM
To
Subject: Fw: Apollo/ Epstein/Kushner connection
Healthcare fraud is pretty serious shit.
What SECURITIES LAWS should be
https://www.law.cornell.edu/uscode/text/18/1347
EFTA00027528

=== Page 2 ===
18 U.S. Code § 1347 - Health care fraud | U.S.
Code | US Law | LII / Legal Information
Institute
to obtain, by means of false or fraudulent pretenses,
representations, or promises, any of the money or property
owned by, or under the custody or control of, any health care
benefit program,
www.law.cornell.edu
Colleran got off pretty easy, eh?
Certainly LOOKS like CRIMINAL fraud and
NOT
CIVIL fraud
Trump:
'acting' Asst DOJ Readler becomes JUDGE Readler just like that
https://en.wikipedia.org/wiki/Chad_Readler
Chad Readler - Wikipedia
August 23, 1972 (age 46) Pontiac, Michigan, U.S.: Education:
University of Michigan (BA, JD): Chad Andrew Readler (born
August 23, 1972) is a United States Circuit Judge of the United
States Court of Appeals for the Sixth Circuit and former Principal
Deputy and former Acting Assistant Attorney General for the
en.wikipedia.org
The criminality associated with this White House is off the charts.
Calk: Lorber
Lorber/Elliman/Icahn: Frost/Honig/Stetson
AND
Alpha Capital: Martin Schlaff: MY CLAIMS
Ladenburg/Gruntal: Refco/Bawag
Also Schlaff AND: Englander/Nordlicht/Kushners
abusive naked shorting to facilitate $$ laundering: Sedona/ Scan Graphics
My claims: NITE/VIRT: Refco on steroids
also CDEL
Frost brings down the WH
Frost/Honig/Stetson: Therapix/FSDDF
Urban: FSDDF/NITE/VIRT
Blackstone: Luckiest fuckers on the Street: Here glitchy glitchy
Epstein: Schwarzman
Epstein: Black
Black/Schwarzman: Kushner (my BX SEC TCR)
EFTA00027529

=== Page 3 ===
SEC: dropped Apollo charges: Avakian/Heiss
SEC NITE/VIRT obstruction: Jay/Sull Crom/Fishman
1MDB: PHUN/Nordlicht/AIPAC: Greek shippers
Economou/EKONOMOU
Bistricers
Feinberg: Danaos
Trump attorney: EKONOMOU
Barr 1MDB waiver: AQR
Cheers!
Follow me on Twitter
I'll follow back
lololol
From: Chris Dilorio
Sent: Saturday, July 13, 2019 7:31 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
More
Trump Ohio fundraiser
Brian Colleran
https://www.cleveland.com/politics/2019/07/donald-trump-coming-to-cleveland-friday-for-fundraiser-at-
nursing-home-magnates-house.html
Donald Trump coming to Cleveland Friday for
fundraiser at nursing home magnate's house -
cleveland.com
CLEVELAND, Ohio - Republican President Donald Trump is
visiting Cleveland on Friday for a private fundraiser at the home
of nursing home executive Brian Colleran, sources with
knowledge of the
www.cleveland.com
https://www.justice.gov/opa/pr/three-companies-and-their-executives-pay-195-million-resolve-false-claims-act-
allegations
EFTA00027530

=== Page 4 ===
Three Companies and Their Executives Pay $19.5
Million to Resolve False Claims Act Allegations
Pertaining to Rehabilitation Therapy and Hospice
Services
| OPA | Department of Justice
Ohio based Foundations Health Solutions Inc. (FHS), Olympia Therapy Inc.
(Olympia), and Tridia Hospice Care Inc. (Tridia), and their executives, Brian
Colleran (Colleran) and Daniel Parker (Parker), have agreed to pay
approximately $19.5 million to resolve allegations pertaining to the submission
of false claims for medically unnecessary rehabilitation therapy and hospice
www.justice.gov
Another Honig $$$ laundering shell
Intergetics
Millenium
NMC
Regent
take your pick
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0000072170&owner=exclude&count=40&hidefilings=0
https://www.sec.gov/Archives/edgar/data/72170/000114420410011488/0001144204-10-011488-index.htm
Colleran
https://www.sec.gov/Archives/edgar/data/72170/000114420408023159/0001144204-08-023159-index.htm
Cheers!
Christopher Dilorio
and
From: Chris Dilorio
Sent: Thursday, July 11, 2019 8:07 AM
To:
EFTA00027531

=== Page 5 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
Mr Berman,
Thanks for the shout out, but I'm not a journalist
lololol
Just a very long list of credible information I have provided to the grossly corrupt SEC et al scumbags
Janey, update my various TCR's and derivatives. Separate but related Janey. Separate but related.
Hey, is Jay still working on his NITE/VIRT/Sull Crom disclosures?
https://www.nytimes.com/2019/07/10/business/jeffrey-epstein-net-worth.html
Jeffrey Epstein's Infinite Means' May Be a Mirage
Mr. Epstein, facing sex-trafficking charges, has long been hailed as a financial
wizard. He got rich with the help of two wealthy connections, but there is little
evidence he's a billionaire.
www.nytimes.com
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Monday, July 8, 2019 6:25 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Greetings Grossly corrupt SEC scumbags et al
IMDS: S Florida $$$ laundering shell facilitated by the SEC
Highlighted in my 2013 TCR filed with prestigious Berger Montague
EFTA00027532

=== Page 6 ===
More AML flags than be counted
MASSIVE naked short position
MY claims
SEC cover up. Now, re started so it can be unleashed on the investing public yet again.
Martin Schlaff/Balmore/Alpha Cap
https://www.haaretz.com/israel-news/business/martin-schlaf-is-behind-5-million-investment-in-collplant
1.5457018
Martin Schlaff: Bag Man
But it gets MUCH better
Graftech
SEC reporting
pronounced "Graft etc"
https://www.sec.gov/Archives/edgar/data/931148/000119312516427770/0001193125-16-427770-index.htm
EDGAR Filing Documents for 0001193125-16-427770
GrafTech Global Enterprises Inc. (Filer) CIK: 0000940404 (see all company filings) IRS No.: 061415602 | State
of Incorp.:DE | Fiscal Year End: 1231 Type: 15-15D | Act
www.sec.gov
https://www.haaretz.com/israel-news/elections/.premium-the-netanyahu-milikowsky-ties-could-be-on-the-
way-to-an-fbi-investigation-1.7090960
The FBI may be about to probe Netanyahu's
ties to cousin Milikowsky
***
www.haaretz.com
Wall Street / CNBC Wiz Karen Finerman
"Save Graft etc"
https://www.sec.gov/Archives/edgar/data/931148/000119312515018174/d857124dex991.htm
EX-99.1 - sec.gov
Exhibit 1 "SAVE GRAFTECH" GROUP NOMINATES FULL SLATE OF SEVEN DIRECTORS TO GRAFTECH BOARD
NEW YORK, January 23, 2015 - Save GrafTech, an investor group led by Nathan Milikowsky, a holder of
over 15 million shares, or over 11.2%, of the common stock of GrafTech International Ltd. (NYSE: GTI), today
sent a letter to the GrafTech Board of Directors disclosing that it has submitted a
www.sec.gov
EFTA00027533

=== Page 7 ===
pg 57 of this SEC reviewed public offering
https://www.sec.gov/Archives/edgar/data/931148/000104746919000874/a2237872zs-1.htm
www.sec.gov
(1) Includes 2,625,000 shares of common stock that the underwriters have the option to purchase from the
selling stockholder. (2) Estimated solely for the purpose of calculating the amount of registration fee in
accordance with Rule 457(c) under the Securities Act of 1933, as amended, based upon the average of the
high and low sales prices of the registrant's common stock as reported by the
www.sec.gov
2018 revenue up 244% vs 2017 due to sharp increase in graphite electrode pricing
BUT, graphite electrode prices rose significantly in 2017
and
FELL in 2018
https://agmetalminer.com/tag/graphite-electrodes/
graphite electrodes Archives - Steel, Aluminum, Copper, Stainless, Rare
Earth, Metal Prices, Forecasting |
MetalMiner
Needle coke, a crude oil derivative, accounts for 40-44% (depending on the year) of the cost to produce
one metric ton of electrodes. Graftech, one of the leaders in graphite electrode production
agmetalminer.com
the Graftech/Graft etc balance sheet is complete fraud as well
insolvent
JP Morgan strikes again
Grossly corrupt SEC "protecting Main Street as usual"
Fraud certainly not limited to the OTCM
Mr Teotia,
congrats on taking Wes Bricker's job
no doubt you're working hard on those KCG 2Q 2017 financials not "published" by Mr Transparency Dougie
Cifu.
Where would a $4 billion+ write down of naked short fails put the NITE/VIRT fraud on the list of egregious
SEC accounting fraud failures?
Top 5?
Let me know if I can help
In furtherance of the conspiracy
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Wednesday, June 26, 2019 6:07 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
EFTA00027534

=== Page 8 ===
From: Chris Dilorio
Sent: Tuesday, June 25, 2019 2:31 PM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Friday, May 24, 2019 7:27 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Friday, May 24, 2019 7:23 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Getting warmer Ms Strauss
https://www.justice.gov/usao-sdny/pr/bank-ceo-stephen-m-calk-charged-corruptly-soliciting-presidential-
administration
Bank CEO Stephen M. Calk Charged With Corruptly
Soliciting A Presidential Administration Position In
Exchange For Approving $16 Million In Loans | USAO-
SDNY I Department of Justice
Audrey Strauss, the Attorney for the United States, Acting Under Authority
Conferred by 28 U.S.C. § 515, William F. Sweeney Jr., the Assistant Director-in-
EFTA00027535

=== Page 9 ===
Charge of the New York Field Office of the Federal Bureau of Investigation
("FBI"), and Patricia Tarasca, the Special Agent-in-Charge of the New York
5
www.justice.gov
But, this is the beginning of the story
not the end
Calk/Lorber/Elliman: Trump
Lorber: New Valley Corp
https://www.sec.gov/Archives/edgar/data/106374/000095014405003084/g93826e10vk.htm
Apollo Moscow/Kremlin development
AND
Ladenburg Thalman
I asked in previous correspondence:
Does ANYONE believe Frost risked BILLIONS to "MAKE" a few million?
Frost was laundering a few millions.
https://www.barrons.com/articles/sec-charges-phillip-frost-1536608366
SEC Charges Against Phillip Frost Might Just
Be the Tip of the Iceberg
The U.S. Securities and Exchange Commission filed stock fraud
charges late last week against billionaire drug entrepreneur Phillip
Frost and a group of associates, accusing them of making $27
million in pump-and-dump stock schemes
www.barrons.com
Alpha Capital Anstalt Liechtenstein
in my 2013 TCR: Money laundering/Miami based Imaging Diagnostics (see my IMDS e mails)
Bag Men
Also: "Greek Shipping company" FreeSeas (See my FreeSeas TCR)
Despite overwhelming evidence of money laundering, you will find no reference to it in SEC complaints.
https://www.sec.gov/news/press-release/2018-182
SEC.gov | SEC Charges Microcap Fraudsters for Roles in Lucrative Market
Manipulation Schemes
The Securities and Exchange Commission today charged a group of 10 individuals and 10 associated
entities for their participation in long-running fraudulent schemes that generated over $27 million from
EFTA00027536

=== Page 10 ===
unlawful stock sales and caused significant harm to retail investors who were left holding virtually worthless
www.sec.gov
No mention of AML despite glaring red flags
No mention of executing Broker Dealers: Penny stock trading fairies
The SEC has kept Alpha Capital Anstalt up and running so the activity detailed in my complaints can continue.
And it does
https://whalewisdom.com/filer/alpha-capital-anstalt
ALPHA CAPITAL ANSTALT Top Holdings - - WhaleWisdom
Alpha Capital Anstalt is based out of Vaduz Liechtenstein. Whalewisdom has at least 6 13D filings, 158 13G
filings, and 5 Form 4 filings The firm has no submitted 13F filings and does not appear to be an investment
advisor.
whalewisdom.com
Now: Lorber/Calk/Elliman: New Valley: shell
Ladenburg/Frost/Alpha Cap Anstalt $$$ laundering shells
Apollo/Lorber: Moscow/Kremlin "development"
"Tip of the Iceberg" indeed
In furtherance of the conspiracy.
Cheers!
Christopher Dilorio
Whistleblower
From: Chris Dilorio
Sent: Thursday, May 23, 2019 5:59 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
EFTA00027537

=== Page 11 ===
So:
Leon Black/ Apollo/Schwarzman: Trump Kushner
Black/Apollo/Schwarzman: Epstein
Black/Apollo/Schwarzman: Putin/RU
https://www.reuters.com/article/russia-putin-fund-idUSL5E7KG0SI20110916
UPDATE 2-Putin gets SWF, PE backing for
Russia fund
* Apollo's Black shares platform with Putin
www.reuters.com
https://www.swfinstitute.org/news/33645/u-s-treasury-sanctions-russian-direct-investment-fund/amp
Black/Apollo/Schwarzman: money laundering shells
https://www.businessinsider.com/blackstone-dodged-a-bullet-with-knight-capital-2012-8
Blackstone Dodged A Bullet With Knight
Capital - Business Insider
A trader consulted by Business Insider said that Blackstone envied
Knight Capital's market-making team, which executed an average
of more than $20 billion trades last year and is designated market
www.businessinsider.com
https://www.sec.gov/Archives/edgar/data/1082278/000092242313000183/0000922423-13-000183-index.htm
Knight/Trimark/Optimark born out of "worthless paper"/ Russian/US Mafia/ money laundering shell: Ashton
Technologies
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001003740&owner=exclude&count=40&hidefilings=0
https://ag.ny.gov/press-release/us-attorney-lynch-and-nys-attorney-general-spitzer-announce-20-defendants-
indicted-50
U.s. Attorney Lynch And N.y.s. Attorney General Spitzer Announce 20
Defendants Indicted In $50 Million Boiler Room Stock Fraud Scheme I New
York State Attorney General
LORETTA E. LYNCH, United States Attorney for the Eastern District of New York, ELIOT SPITZER, New York
State Attorney General, BARRY W. MAWN, Assistant Director-in-Charge of the Federal Bureau of
EFTA00027538

=== Page 12 ===
Investigation in New York, and RICHARD H. WALKER, Director of the Division of Enforcement of the
Securities and Exchange Commission, today announced the unsealing of an indictment charging 20
ag.ny.gov
Spitzer taken down by RUSSIAN hooker
https://nypost.com/2016/02/16/spizter-accuser-a-young-jobless-ex-hooker-who-lives-a-life-of-luxury/
Spitzer accuser was a $5K-a-night hooker
who lives life of luxury - New York Post
The Russian vixen who accused Eliot Spitzer of choking her at The
Plaza hotel is a divorced, globe-trotting beauty who once bared
all the dirty details of her life as a $5,000-a-night hooker, The
nypost.com
Any questions?
Cheers traitorous scumbags!
Christopher Dilorio
From: Chris Dilorio
Sent: Sunday, May 19, 2019 8:03 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
I reiterate:
The SEC is a grossly corrupt criminal organization bought and paid for by criminals who threaten the integrity of
our markets to the clear and very egregious detriment of the investing public it is sworn to protect.
http://www.marketrap.com/article/view_article/9152/bernard-madoffthe-mafia-and-the-friends-of-michael.
milken
EFTA00027539

=== Page 13 ===
Bernard Madoff, the Mafia, and the Friends of Michael Milken - Market Rap
- The Investor Empowerment Community
In 2005, Patrick Byrne, the CEO of Overstock.com and future Deep Capture investigative reporter, began a
public crusade against illegal naked short selling (hedge funds and brokers creating phantom stock to
manipulate stock prices down). He said, over and over, that the crime was destroying public companies and
had the potential to trigger a systemic meltdown of our financial markets.
www.marketrap.com
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Friday, May 17, 2019 6:22 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Wednesday, May 15, 2019 11:27 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Today (5/15/19) the grossly corrupt scumbags at the SEC approved ANOTHER massive fraud on the investing
public:
https://www.sec.gov/Archives/edgar/data/1665300/999999999519001111/xslEFFECTX01/primary_docxml
The "genius f'n quant" AQR/Greek shipping
/Economou/DRYS/ORIG/Astra/Nautilus/Navios/Gerber/AIPAC/Nordlicht/Glass/1MDB/Knitowski/Caneum/Trym
etris/Liquid etc etc etc money laundering shell.
Well done!
BTW, HOW is the George Economou/ Georgios EKONOMOU SEC "investigation" coming along anyway?
https://en.wikipedia.org/vwiki/George_Economou_(shipbuilder)
EFTA00027540

=== Page 14 ===
George Economou (shipbuilder) - Wikipedia
George Economou or Georgios Ekonomou (Гешруюс Olkovójiou, born 1953) is a Greek billionaire
shipowner, CEO of DryShips Inc. and Ocean Rig, and the owner of Cardiff Marine.Economou owns oil
tankers as well as dry bulk ships and manages them through Cardiff Marine. He was on the Forbes
Magazines list of the world's billionaires on place 707.
en.wikipedia.org
What a coincidence:
https://www.vanityfair.com/news/2018/03/andrew-ekonomou-donald-trump-legal-team/amp
Trump's Last Line of Defense Against Mueller
Is an Obscure Medieval Historian
Andrew Ekonomou had a "mid-life crisis" and became an expert
on Byzantium. Now he's helping lead the president's legal team in
the Russia investigation.
www.vanityfair.com
Dude is DEFINITELY not getting the attention he deserves
Then again,
WHO actually believes Marc Bistricer of Toronto Canada was INVESTING in the $$$ laundering Ekonomou
shell known as DryShips?
https://seekingalpha.com/article/4096781-strong-court-case-dryships-kalani
Very Strong Court Case Against DryShips And
Kalani - DryShips Inc. (NASDAQ:DRYS)
|
Seeking Alpha - Stock Market Insights
I
Seeking Alpha
Source: rgrdlaw.com (court document) In 2012, DRYS generated
$1.23 billion in total revenue, yet posted a $246 million loss. In
fact, the company has been posting losses every year for the last
seekingalpha.com
"Charity not the motive"
https://www.tradewindsnews.com/legal/1738610/kalani-claims-charity-not-a-motive-for-dryships-aid
EFTA00027541

=== Page 15 ===
Kalani claims charity not a motive for DryShips
aid I TradeWinds
Kalani claims charity not a motive for DryShips aid Marc Bistricer-
led investment house says it had risk and profit in mind lending
to George Economou's struggling public company, not attempt to
www.tradewindsnews.com
The Toronto connection runs MUCH deeper though
The overlap with AQR blank check shells and Polar Asset Mgmt Toronto
The Toronto based Bistricer and EKONOMOU
Bistricers in New Jersey TOO!
AND
DAVID Bistricer happens to be a real estate developer
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001649096&owner=exclude&count=40&hidefilings=0
1 Bistricer/Clipper "investor"
Toronto based C I Investments
https://www.sec.gov/Archives/edgar/data/1649096/000116364819000009/0001163648-19-000009-index.htm
Check out this Reg D offering Bistricer/ Clipper did in Jan 2016
https://www.sec.gov/Archives/edgar/data/1649096/000161577416004014/xslFormDX01/primary_doc.xml
$130,000 Reg D offering for this Bistricer/Clipper publicly traded "real estate" company was done with an
Atlanta based firm called H&L Equities
Atlanta is home of the obscure Trump Russia Counsel Andrew EKONOMOU
Nothing to see here.
Of Course, then there's the Hail Mary pass Kushner threw on his Toronto based Brookfield deal for 666 5th
Avenue
https://www.thestar.com/news/world/2019/03/12/toronto-based-brookfield-faces-scrutiny-from-democrats-
over-deal-with-kushner-company.html
Toronto-based Brookfield faces scrutiny from
Democrats over deal with Kushner company
|
The Star
The real estate giant says politics were not at all involved in its
decision to acquire a New York office tower from the family of
Jared Kushner, President Donald Trump's son-in-law and senior
aide.
www.thestar.com
EFTA00027542

=== Page 16 ===
which was brokered by Apollo/Epstein Degenerate Black/Harris/Rowan
https://therealdeal.com/2018/11/15/brookfield-turns-to-appllo-for-666-fifth-financing/
666 Fifth | Brookfield | Apollo Global
Management
Private equity company Apollo Global Management is funding
Brookfield Property Partners' redevelopment of 666 Fifth Avenue
with a $300 million-plus mezzanine loan, sources told The Real
Deal
therealdeal.com
Apollo and other Kushner financing pal Blackstone just happen to be BOTH granted free reign on the US
insurance/annuity industry.
Crazy shit huh?
Greek shipping Bag man Georgios Ekonomou meets Jared Kushner
But it gets better still:
Stephen Feinberg: Cerberus
https://www.bloomberg.com/news/articles/2018-05-11/trump-chooses-cerberus-s-feinberg-tolead-spy-
advisory-panel
Trump Chooses Cerberus's Stephen Feinberg
to Lead Spy Advisory Panel - Bloomberg
President Donald Trump has chosen billionaire investor Stephen
Feinberg to lead his intelligence advisory board, the White House
said Friday. Trump intends to appoint Feinberg, the co-founder
and
www.bloomberg.com
Bawag/Refco
Virtu first bid for Knight post "glitch"
and now: Money Laundering Bank HSH
Stephen Feinberg: Scum of the Earth meet Georgio EKONOMOU
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001369241&owner=exclude&count=40&hidefilings=0
Janey, IG update my various pending TCR's and complaints
Yours VERY TRULY
And INFINITELY smarter than anyone on this e mail list
Christopher J Dilorio
EFTA00027543

=== Page 17 ===
Whistleblower
From: Chris Dilorio
Sent: Monday, May 13, 2019 5:41 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Saturday, May 11, 2019 8:00 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Monday, May 6, 2019 6:38 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Greetings grossly corrupt SEC et al scumbags
As with ALL of my allegations: beyond a shadow of a doubt, 100% accurate
https://www.sec.gov/litigation/complaints/comp17673.htm
Complaint: SEC V.
EFTA00027544

=== Page 18 ===
COMPLAINT. Plaintiff United States Securities and Exchange Commission ("Commission") alleges as
follows: SUMMARY. 1. This case involves a $15 million "pump and dump" scheme involving the securities
of Environmental Solutions Worldwide, Inc. ("Environmental"), a public company whose common stock is
registered with the Commission under the Securities Exchange Act of 1934 ("Exchange Act"), and is
www.sec.gov
ESWW was a money laundering shell.
The SEC knows it. The degenerate Epstein knows it. The Degenerate Leon Black/Kushner BFF/ Milken
proteges/Marc Rowan/Apollo knows it.
The DOJ/IRS knows it.
IG, I have repeatedly offered to come to SEC DC HQ to have the brightest minds at the SEC totally humiliate me
by refuting my allegations 1 by 1. The grossly corrupt SEC scumbags have never taken me up on my generous
offer. For the very simple reason that ALL of my allegations are accurate and true.
So, I again put the offer out there:
refute my claims OR go to jail for the criminal obstruction ACTIVELY being facilitated by your office and the SEC.
So, let's give these scumbags the insurance/annuities market.
This will NOT end well for tens of thousands of Americans.
Who "green lighted" this take over of the insurance industry by PE/Hedge funds?
https://www.forbes.com/sites/antoinegara/2018/02/01/apollo-and-blackstone-pick-insurance-as-their-next-
bet-to-disrupt-wall-street/#5d647dbe7689
Apollo And Blackstone Pick Insurance As Their
Next Bet To Disrupt Wall Street - Forbes
For decades, Wall Street's gambit in insurance was to write
policies and use the float as a source of capital for new
investments. It's a staple of Berkshire Hathaway and copycats like
Markel and
www.forbes.com
Cheers!
Christopher Dilorio
Whistleblower
From: Chris Dilorio
Sent: Thursday, May 2, 2019 3:35 PM
To:
EFTA00027545

=== Page 19 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
IG,
This was a blatant attempt to intimidate a whistleblower. "HE" (I think a male although very effeminate voice)
was an anonymous, coward, scumbag who threatened me. AND then called me another 11/12 times after that.
This is a VERY serious matter. Felony. I intend to see "him" prosecuted to the fullest extent of the law. Within
weeks of filing a complaint against the SEC and you.
I obviously have hit a nerve.
https://www.nbcnews.com/politics/white-house/white-house-tells-official-who-gave-kushner-security-
clearance-don-n997476
White House whistleblower speaks out on
security clearance controversy
Carl Kline was supposed to appear before House committee staff
Tuesday to face questions related to his handling of White House
security clearances.
www.nbcnews.com
Cheers!
Christopher Diiorio (no L's scumbag)
From: Chris Dilorio
Sent: Thursday, April 25, 2019 6:27 AM
To:
EFTA00027546

=== Page 20 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
ESWW: A money laundering NASDAQ/OTCM shell
Milken degenerate Leon Black/Joshua Harris: Apollo
AND
Jeffrey Epstein
The SEC has known for years that Epstein is running a extortion/Ponzi/Slush Fund
My Claims AGAIN
https://seekingalpha.com/article/3715526-environmental-solutions-worldwide-revisiting-holding-gone-dark-
can-sleep-better-night?mod=mw_quote_news
Environmental Solutions Worldwide: Revisiting
A Holding That's Gone Dark, So I Can Sleep
Better At Night - Environmental Solutions
Worldwide, Inc. (OTCMKTS:ESWW) I Seeking
Alpha - Stock Market Insights I Seeking Alpha
New CEO and recent trading activity warranted a review of a
holding that no longer files. Based on the environment, difficult
y/y comparisons and results from competitors, 2015 is likely a
down year.
seekingalpha.com
"Not credible"???
How about the SEC's OWN words?
https://www.bloomberg.com/news/articles/2018-10-01/sec-spots-a-way-to-starve-the-most-suspicious-penny-
stocks
EFTA00027547

=== Page 21 ===
SEC Spots a Way to Starve the Most
Suspicious Penny Stocks - Bloomberg
"If a company is a dark company and listed in the OTC market
and hasn't put out financials for six months, maybe it shouldn't
be quoted or offered to retail investors," Redfearn said
www.bloomberg.com
See my comment letters on this subject.
The SEC INTENTIONALLY puts the investing public at risk of frauds like this and thousands others like it.
The core biz at NITE/VIRT,CDEL etc and the reason WHY the OTCM exists: Abusive naked shorting publicly
traded shells to facilitate money laundering.
Shells go dark only AFTER a massive fraud has been perpetrated on the investing public: Main Street
ANOTHER "genius" degenerate: Apollo
the grossly corrupt SEC: Bought and paid for by common criminals and degenerates
IG, I have time for that REQUIRED 3rd party cc today
Call me
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Sunday, April 14, 2019 1:04 PM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
A little Steffie Avakian//Heiss/O'Melveny/Wilmer Hale/ Apollo/Kushner Home Cooking!
https://www.omm.com/professionals/howard-e-heiss/
EFTA00027548

=== Page 22 ===
Howard E. Heiss - O'Melveny & Myers
Howard Heiss has an extensive litigation practice focused on
government regulatory investigations and enforcement actions,
grand-jury investigations, and the defense of clients in criminal
cases, with a particular emphasis on securities matters.
www.omm.com
https://www.sec.gov/Archives/edgar/data/1411494/000119312508077312/ds1.htm
Form S-1 - SEC.gov
Table of Contents. The information in this prospectus is not complete and may be changed. The securities
may not be sold until the registration statement filed with the Securities and Exchange Commission is
effective.
www.sec.gov
https://www.wilmerhale.com/en/people/jamie-gorelick
Jamie Gorelick | WilmerHale
Jamie Gorelick's career has spanned the legal, policy and corporate landscapes. As one of Washington's
best-known litigators, Ms. Gorelick has represented corporations and individuals in a wide array of matters,
particularly in the regulatory and enforcement arenas, involving issues as diverse as antitrust,
environmental regulation, securities enforcement, national security regulation, etc.
www.wilmerhale.com
https://www.wilmerhale.com/en/insights/news/former-director-of-the-fbi-robert-mueller-i-joins-wilmerhale
Former Director of the FBI Robert Mueller III
Joins WilmerHale
WilmerHale is pleased to announce that Robert S. Mueller III is
joining the firm as a partner after serving as the sixth Director of
the Federal Bureau of Investigation (FBI), a position he took one
week prior to the September 11 attacks and held for 12 years
under two presidents.
www.wilmerhale.com
https://www.sec.gov/biography/avakian-stephanie
EFTA00027549

=== Page 23 ===
SEC.gov | Stephanie Avakian
Stephanie Avakian was named Co-Director of the U.S. Securities and Exchange Commission's Division of
Enforcement in June 2017, after serving as Acting Director since December 2016.
www.sec.gov
SEC drops Apollo investigation after Kush Jr met with Harris at the WH
and Apollo gives Kush's some $$$$
And, Apollo gets $60 bil+ in inflows in 2018
Did I miss something?
Cheers!
You corrupt fucking scumbags
Christopher Dilorio
From: Chris Dilorio
Sent: Saturday, April 13, 2019 11:30 AM
To:
Subject: Apollo/ Epstein/Kushner connection
Find a shell
Find a fraud
Enviromental Solutions Worldwide Inc
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001082278&owner=exclude&count=40&hidefilings=0
Florida?
Pennsylvania?
or
Canada?
EFTA00027550

=== Page 24 ===
Welcomed on Cromwell/Wimpfheimer OTCM
De registered in 2015 and Frozen in time
Literally
http://esvgroup.com/esw-group-corporate/our-board/
Our Board - ESW Group®
MARK YUNG Mr. Yung is Co-Founder and Managing Principal of
OCV Management, LLC ("OCV"), an investor, owner and operator
of technology and life science companies based in Los Angeles.
Previously, Mr. Yung was a Managing Director at Orchard Capital
Corp., a firm he joined in 2006. Through his affiliation with [...]
eswgroup.com
Dozens of filings by former Milken (ahem) right hand man Leon Black, Apollo, his family Trust, et al
Then,
There's this:
Has anyone (anyone) ever seen Pedophile Jeffrey Epstein on the other side of a trade?
The ONLY SEC filing of Epsteins' Financial Trust Company Inc is in
wait for it
Leon Black/Apollo Environmental Solutions Worldwide
https://www.sec.gov/Archives/edgar/data/1082278/000090901211000390/0000909012-11-000390-index.htm
Enter the Amicus blocking release of Epstein docs
Krieger, Kim and Lewin
https://www.kkllp.com/
Krieger Kim & Lewin LLP
We are committed to providing the highest level of partner-driven representation in order to efficiently
achieve client objectives. Over the last decade, we have conducted and supervised dozens of federal
criminal trials involving some of the highest profile and most sensitive matters prosecuted by the United
States Government.
www.kklllp.com
Financial fraud appears to be a specialty of this recently formed/SDNY Alum firm
Now,
it gets VERY interesting
https://www.cnbc.com/2018/02/28/apollo-citigroup-loaned-kushner-companies-millions-new-york-times.htm
EFTA00027551

=== Page 25 ===
Trump: Kushner's security clearance is up to
Kelly
Kushner even discussed the possibility of a White House job for
the founder of private equity firm Apollo, the New York Times
reported on Tuesday.
www.cnbc.com
Where another Milken protégé/Apollo founding partner Josh Harris was considered for a White House job
"Coindences"
https://nypost.com/2018/03/02/sec-dropped-probe-month-after-firm-aided-kushner-company/
SEC dropped probe month after firm aided
Kushner company
The feds last year dropped an investigation into a financial
company a month after the firm gave Jared Kushner's family real
estate business a $180 million loan, a new report said Friday.
There
---
nypost.com
Oh, baby
$60 billion+ inflows in 2018 for Apollo
https://www.businesswire.com/news/home/20180802005343/en/Apollo-Global-Management-LLC-Reports
Quarter-2018
Apollo Global Management, LLC Reports
Second Quarter 2018 Results I Business Wire
NEW YORK--(BUSINESS WIRE)--Apollo Global Management, LLC
(NYSE:APO) (together with its consolidated subsidiaries, "Apollo")
today reported results for the second quarter ended June 30,
2018.
www.businesswire.com
Mr's Krieger,Kim,Boltz et al:
Discovery will be a hoot!
EFTA00027552

=== Page 26 ===
Fucking A
I am good
Cheers!
Christopher Dilorio
EFTA00027553


c1: EFTA00027439
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027439.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
Bcc: "USAHUB-USAJournal111"
Subject: FW: victim notification
Date: Wed, 09 Dec 2020 00:00:19 +0000
Embedded: FW:_victim_notification.msg
Sender:
Subject: FW: victim notification
Message-Id:
OM>
To:
EFTA00027439


c1: EFTA00029195
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00029195.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To
Co
Subject:
Date: Tue, 17 Dec 2019 19:51:58 +0000
Attachments: Introductory_Email_
2-16-19.pdf
Inline-Images: image001.jpg
Dear
Attached please find the email I mistakenly addressed to
-
refer to her as
by mistake and have
since apologized.
Frankly, I was not sure whether I should contact you or
At any rate, after you have an opportunity to look at the
attached email, let me know how we should proceed.
Sincerely,
9150 Wilshire Blvd., Suite 241
Beverly Hills. California 90212-3429
CONFIDENTIALITY
This e-mail is for the personal and exclusive use of the recipient(s) named above. It contains confidential information from
Its contents are not only to
remain absolutely confidential, but may also be subject to the attorney-client privilege or coverage under the work-product doctrine. If you have received this transmission and are
not the intended recipient(s) or his/her agent, please be advised that any disclosure, use, review, copying, selling, dissemination, publication, or distribution of this transmission is
strictly unauthorized and prohibited. If you have received this transmission in error, please notify the sender at the number above, return the original e-mail by mail, and delete
the e-mail file from your computer. Postage is guaranteed. Your cooperation is appreciated. Thank you.
EFTA00029195


c1: EFTA00027100
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027100.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
N
)"
)"
Subject: The Day Jeffrey Epstein Told Me He Had Dirt on Powerful People - The New York Times
Date: Tue, 13 Aug 2019 01:41:55 +0000
https://www.nytimes.com/2019/08/12/business/jeffrey-epstein-interview.html
Sent from my iPhone
EFTA00027100


c1: EFTA00029144
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00029144.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: [EXTERNAL EMAIL] - Call w/ SDNY re: discovery, Epstein
investigation
Start Date: 2020-10-23 15:00:00 +0000
End Date: 2020-10-23 15:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-10-22 17:27:03 +0000
Date Modified: 2020-10-22 17:27:03 +0000
Priority: 5
DTSTAMP: 2020-10-22 17:01:44 +0000
Attendee:
EFTA00029144


c1: EFTA00027752
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027752.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: BOBBI C STERNHEIM
To:
)"
)"
)"
Cc: Christian Everdell
>, , Laura Menninger
>, Jeff Pagliuca
Subject: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Fri, 15 Oct 2021 21:55:04 +0000
Attachments: Defense_Reply_to_Dkt_350.pdf; ATT00001.htm
Good afternoon-
Attached is a courtesy copy of today's ECF filing.
Bobbi
EFTA00027752


c1: EFTA00028620
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028620.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Joe Nascimento
To:
)"
Cc:
(USANYS)"
)"
Subject: Re:
)
- Epstein
Date: Fri, 14 May 2021 18:55:34 +0000
Attachments:
Proffer_Letter.PDF
Hi
,
Thanks again for your time today. Attached, please find a copy of the proffer agreement with updated initials.
Have a nice weekend,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Friday, May 14, 2021 at 11:34 AM
To: Joe Nascimento
Cc:
(USANYS)"
>, ,
)"
Subject: RE:
)
- Epstein
Hi Joe,
Attached is the proffer agreement for today-I'll discuss this at the beginning of our meeting, but in terms of mechanics
it's fine with me if you and your client sign after the proffer, and you can just email it to me whenever that's done.
Thanks,
From: Joe Nascimento
Sent: Monday, April 26, 2021 9:53 AM
To:
Cc:
(USANYS)
is
)
Subject: Re:
- Epstein
EFTA00028620

=== Page 2 ===
Perfect, I received the invite with the link. Unfortunately (or fortunately sometimes) WebEx has been a part a
daily part of my life the past year, so we should be OK. See you all then, let me know if you need anything
further from us in the meantime.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Apr 26, 2021, at 9:31 AM,
)
wrote:
Hi Joe,
Thanks very much. Let's plan for May 14th at 12 p.m., if that works for you. I'll send a WebEx link for the
videoconference shortly. Please let us know if you have any tech issues/questions about WebEx.
Thanks,
From: Joe Nascimento
Sent: Wednesday, April 21, 2021 1:53 PM
To:
Cc:
(USANYS)
is
Subject: Re:
- Epstein
Good afternoon,
I spoke with
and she can make herself available the following dates:
May 3, 4 (before 2pm), 5, 6, 12, 13 or 14.
She is going to take the day off of work, so no need to do it after-hours (thank you for the offer). Let me know if you
need additional availability.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
EFTA00028621

=== Page 3 ===
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
<image001.jpg>
From:
)
Date: Friday, April 16, 2021 at 1:31 PM
To: Joe Nascimento
Cc:
(USANYS)
)
Subject: RE:
)
- Epstein
Thanks very much - let's plan for 9:30 a.m. on Monday, if that works for you. Should I just call your desk line, or would
you prefer a different number?
Thanks,
From: Joe Nascimento
Sent: Friday, April 16, 2021 1:00 PM
To:
Cc:
(USANYS)
is
)
Subject: Re:
)
- Epstein
Hi
,
Yes, I'm free Monday morning between 9:30 and 12 or Tuesday between 11-3. If that doesn't work for you, I
can try to move something around. Let me know.
Have a nice weekend,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
EFTA00028622

=== Page 4 ===
On Apr 16, 2021, at 11:58 AM,
)
wrote:
Hi Joe,
Hope you're doing well. Are you available for a call sometime early next week? Nothing urgent, but we wanted to talk
with you about potentially scheduling an interview (by video conference) with your client for sometime in early May.
Thanks,
From: Joe Nascimento
Sent: Monday, March 8, 2021 1:54 PM
To:
Cc:
is
Subject: Re:
- Epstein
Yes, 10:30 works for me. Thank you!
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
From:
Date: Monday, March 8, 2021 at 1:32 PM
To: Joe Nascimento
Cc:
)
i
)
Subject: RE:
)
- Epstein
Hi Joe,
Thanks, hope all is well with you. We're free for a call at 10:30 tomorrow morning, would that work for you?
Thanks,
From: Joe Nascimento
Sent: Monday, March 8, 2021 1:24 PM
To:
Cc:
is
Subject: Re:
- Epstein
EFTA00028623

=== Page 5 ===
Hi
,
I hope you are well. Please let me know if you have 5 min for a quick call.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 2, 2020, at 11:09 AM,
)
wrote:
Hi Joe,
Thanks for reaching out, we were planning to email you. We continue to appreciate your client's cooperation with
our investigation, and her status from our perspective has not changed. We'll be in touch going forward, and
-
All the best,
From: Joe Nascimento
Sent: Thursday, July 2, 2020 11:07 AM
To:
Cc:
is
Subject: Re:
- Epstein
Good morning,
Hope you are all well. Just wanted to check in after seeing the reports of Ghislaine's arrest.
If you need anything from us,
let us know.
-Joe
EFTA00028624

=== Page 6 ===
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Feb 21, 2020, at 3:53 PM,
)
wrote:
Joe,
We very much appreciated that, and we just wanted to let you know that the lack of communication separate from
that discussion shouldn't be interpreted in any way negatively. We'll certainly be in touch again when we're able.
thanks again,
From: Joe Nascimento
Sent: Wednesday, February 19, 2020 15:03
To:
Cc:
is
)
Subject: Re:
- Epstein
We really appreciate this email. I was able to speak with
a few weeks ago and gave the green light to share
name and information provided with anyone necessary in your investigation. We will wait to hear from
you if you need anything further.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
EFTA00028625

=== Page 7 ===
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Monday, February 17, 2020 at 3:40 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Joe,
We just wanted to check in very briefly-we had been hopeful that we'd be able to circle back with you earlier, but
our investigation is currently still ongoing, so at the very least we wanted to let you know that we continue to
appreciate both your client's prior assistance and her willingness to assist in the future. Nothing in our
investigation since we were last substantively in touch has changed our view of your client, and we hope to be able
to be in touch with you in the coming weeks with an update. In the interim, we do continue to view her status as
we've previously conveyed, and please let us know if any issues arise on your end.
thank you,
From:
Sent: Saturday, November 30, 2019 14:42
To: Joe Nascimento
Cc:
is
Subject: Re:
- Epstein
Hi Joe,
Thanks for checking in
,
so no issues on our end, but we appreciate
your following up.
Thanks,
Sent from my iPhone
On Nov 30, 2019, at 8:54 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check-in as
EFTA00028626

=== Page 8 ===
Please let us know if you need anything from us.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 9, 2019, at 9:47 PM,
)
wrote:
Joe,
We will meet tomorrow at the same place as last time- the Hilton in West Palm Beach, on Okeechobee
Blvd. My cell is
when you arrive. My colleague,
will be joining us,
and he can be reached at
Thanks,
Sent from my iPhone
On Sep 4, 2019, at 10:46 PM, Joe Nascimento
wrote:
Yes, we will be there.
Sent from my iPhone
EFTA00028627

=== Page 9 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 5:32 PM,
)
wrote:
Hi Joe,
Thanks for letting us know. Let's plan to meet on Tuesday. Would 11:30 work?
Thanks,
From: Joe Nascimento
Sent: Wednesday, September 4, 2019 10:13 AM
To:
^
Cc:
>;
Subject: Re:
- Epstein
Good morning,
Yes, we had to hunker down for 2 days but were spared. Thanks. For next week, the 10th, 11th or
13th work best for me. Look forward to hearing from you.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
EFTA00028628

=== Page 10 ===
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 10:04 AM,
)
wrote:
Hi Joe,
Hope the storm missed you this week, and that you and your client are doing okay.
Our team is working out some scheduling issues today, and we should know more by this
afternoon. I'll plan to reach out then to discuss scheduling, if that's okay.
Thanks,
Sent from my iPhone
On Aug 30, 2019, at 9:52 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check in to see if you still planned to travel south given the storm. Current
estimates show a landing (somewhere) Tuesday with very bad weather on Wednesday. Airports
might close (which will answer my question), but that's a guess.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 21, 2019, at 2:40 PM,
)
wrote:
Hi Joe,
Thanks very much, we'll plan to see you then. We'll most likely meet at a conference space at a hotel in
West Palm Beach, and I'll let you know closer in time which location.
EFTA00028629

=== Page 11 ===
Thanks,
From: Joe Nascimento
Sent: Monday, August 19, 2019 6:37 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
,
Both the time and date work for us. Let me know the location when you have it confirmed.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 19, 2019, at 11:11 AM,
)
wrote:
Joe,
Following up on scheduling, we were wondering if your client is available for a proffer on September
4th. We're flexible on timing that day, but we would propose meeting at 12:30 p.m., if that works.
Thanks,
From: Joe Nascimento
Sent: Wednesday, August 7, 2019 4:53 PM
EFTA00028630

=== Page 12 ===
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
I just wanted to follow up re the August 14th meeting. Is it possible to schedule for early afternoon
(anytime after 1)? I have proactive cooperation ongoing in another case involving multiple
jurisdictions, and they are looking to meet the morning of 8/14. I understand if your schedule is
already set, and will work around it.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Friday, August 2, 2019 at 3:34 PM
To: Joe Nascimento
Cc:
)"
,
Subject: RE:
)
- Epstein
Joe,
Thanks, much appreciated. If possible, it would be helpful to hold August 14th for a meeting, and we'll
follow up to firm up plans as we get closer. If there are any conflicts with that date, please let us
know, we're happy to be flexible.
Thanks,
From: Joe Nascimento
Sent: Thursday, August 1, 2019 8:10 PM
To:
Cc:
is
EFTA00028631

=== Page 13 ===
Subject: Re:
- Epstein
Hi
I do not have any travel plans during the month of August, nor does
September is a busy
month with two trials set, and I will be traveling out of the country from Sept 17-30, but I will do
everything to be as flexible as possible.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, August 1, 2019 at 6:10 PM
To: Joe Nascimento
Cc:
)"
Subject: RE:
)
- Epstein
Joe,
As we start thinking about scheduling a next meeting with
we were wondering if you
could please let us know if there are any particular weeks that would not work for you or your client
for a meeting in Florida (in particular, we don't want to interfere with anyone's summer vacation
plans).
We will of course be in touch to talk about a next meeting in more detail, but in the first instance it
would be helpful to get a sense of your schedules, for planning purposes.
Thanks,
EFTA00028632

=== Page 14 ===
From: Joe Nascimento
Sent: Wednesday, July 17, 2019 6:25 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
,
That works for me. Please call me on my cell
(
). Thanks.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 17, 2019, at 5:58 PM,
)
wrote:
Hi Joe,
Following up, we were wondering if you were available for a call to discuss next steps. We're
available on Friday at 2:30, if that works, but let us know if there are other times that would be
more convenient for you.
Thanks,
From: Joe Nascimento
Sent: Saturday, July 13, 2019 12:39 PM
To:
Cc:
is
Subject: Re:
- Epstein
Good afternoon,
EFTA00028633

=== Page 15 ===
It was a pleasure to meet you yesterday. In light of the recent filing and media reports
As always, feel free to contact me at any time if we can be of further assistance. Look forward to
meeting again.
-Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, July 11, 2019 at 9:07 PM
To: Joe Nascimento
Cc:
)"
>, ,
)"
Subject: RE:
) - Epstein
Hi Joe,
We will be at the Hilton in West Palm Beach, at 600 Okeechobee Blvd. Please call me when you are
here, and we will meet you in the lobby.
Thanks,
From: Joe Nascimento
Sent: Thursday, July 11, 2019 9:02 PM
To:
Cc:
is
Subject: Re:
- Epstein
Good evening,
Have you set a location for our meeting tomorrow?
Thanks,
EFTA00028634

=== Page 16 ===
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 10, 2019, at 12:03 PM,
)
wrote:
Thank you, we will plan to see you then in West Palm Beach. We are still coordinating
logistics, and we will let you know that morning the address where we should meet.
Since we will be traveling, please feel free to call my cell if you need to reach us for any
reason:
Thanks,
Sent from my iPhone
On Jul 10, 2019, at 11:39 AM, Joe Nascimento
<mailto:
wrote:
Of course
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. B<x-apple-data-detectors://2/0>rd<x-apple-data-
detectors:/2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
EFTA00028635

=== Page 17 ===
e.
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com/>
On Jul 10, 2019, at 11:34 AM,
mailto:
wrote:
Joe,
Would it be possible to meet earlier, perhaps at noon on Friday? Thank you.
Sent from my iPhone
On Jul 9, 2019, at 10:51 PM, Joe Nascimento
<mailto:
<mailto:
wrote:
,
Can we meet Friday, early afternoon (around 1-1:30)? Please send me your proffer letter.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. B<x-apple-data-detectors./2/0>rd<x-apple-data-
detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors.//2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com>http:/www.crimlawfirm.com/
On Jul 9, 2019, at 4:56 PM,
)
<mailto:
<mailto:
wrote:
Joe,
We ended up slotting in a few things in the interim, but we're still good for 6:30 for sure.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Tuesday, July 09, 2019 16:43
To:
)
EFTA00028636

=== Page 18 ===
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: Re:
)
- Epstein
Hi
,
I got done a little earlier today - do you want to bump up our call time?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors/2/0> Avenue<x-
apple-data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors.//2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com><http://www.crimlawfirm.com/>
On Jul 9, 2019, at 10:02 AM, Joe Nascimento
<mailto:
<mailto:
wrote:
Hi
,
Are you still free for a call?
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
<mailto:
<mailto:
www.crimlawfirm.com-http://www.crimlawfirm.com--http/www.crimlawfirm.com
From:
)"
<mailto:
<mailto:
Date: Sunday, July 7, 2019 at 10:19 PM
To: Joe Nascimento
<mailto:
<mailto:
Cc:
)"
<mailto:
EFTA00028637

=== Page 19 ===
<mailto:
)"
<mailto:
<mailto:
Subject: RE:
)
- Epstein
Joe,
Sure, thanks - and yes, quite the weekend. If it's alright with you, let's do 10:00 a.m. on
Tuesday - you can reach us at
,
or we can also call you then if that's easier,
whatever you prefer.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Sunday, July 07, 2019 18:51
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
)
<mailto:
<mailto:
Subject: Re:
)
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you. Let's set
a time for Tuesday morning (the earlier the better for me). Let me know what works for
you.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors.//2/0> Avenue<x-
apple-data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors.//2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com http//www.crimlawfirm.com -http:/www.crimlawfirm.com/
On Jul 7, 2019, at 4:04 PM,
)
EFTA00028638

=== Page 20 ===
<mailto:
<mailto:
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak with you.
I expect our schedules may be somewhat unpredictable tomorrow; would it work to set a
time to talk on Tuesday? We can schedule it for before you meet with
if that's
,
helpful. Or if you'd like to talk sooner, we could schedule a time later today, or check in
tomorrow about a possible afternoon discussion. Please let us know what you prefer, and
we look forward to being in touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
<mailto:
<mailto:
Sent: Saturday, July 06, 2019 22:55
To:
<mailto:
<mailto:
Subject:
)
- Epstein
Begin forwarded message:
From:
<mailto:
<mailto:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
Subject:
)
- Epstein
My former partner, Alan Ross, represented
), prior to
his passing in 2018. Agent
served
with a grand jury subpoena earlier
today, and as Alan's former partner and FL Bar appointed inventory attorney, she has
contacted me. Unfortunately, I am unable to meet with her until Tuesday, but I would
appreciate a few minutes of your time at your convenience as I am getting up to speed.
Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
Joe
EFTA00028639

=== Page 21 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3<x-apple-data-detectors:/2/0>rd<x-apple-data-detectors./2/0>Avenue<x-
apple-data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com--http://www.crimlawfirm.com/
EFTA00028640


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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: Gary Bloxsome
Cc:
)"
, Daniel Cundy
N
Jennifer Richardson
,
,
)"
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Reference materials further to our call
Date: Wed, 23 Sep 2020 22:37:43 +0000
Embedded: RE:_Reference_materials_further_to_our_call.msg
Sender:
Subject: RE: Reference materials further to our call
Message-Id:
<CY1P110MB0342CD55B72F34BC1B7D8A8892380@CY1P110MB0342.NAMP110.PROD.OUTLOOK.CO
M>
To:
Cc:
Cc:
EFTA00028537


c1: EFTA00027837
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027837.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Travel Authorization 10982117 approved by
now awaiting further
approval
Date: Mon, 27 Jan 2020 18:45:23 +0000
Importance: Normal
Dear
Travel authorization 10982117 has been approved by
now awaiting further approval.
Trip ID: 10982117
Traveler name:
Purpose:
- Epstein investigation
- Witness Interviews
Destination: Stockholm, Sweden
Dates: 2020-02-03 - 2020-02-07
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
E2 Manual Login (User ID and Password):
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# T0007
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.
EFTA00027837


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=== Page 1 ===
Court Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the United States District Court for the Southern District of New York, 40 Foley Square, in the
Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the
following date, time and place:
Appearance Date:
November 29, 2021
Appearance Time: 9:00 a.m.
Appearance Place:
40 Foley Square, Courtroom 906
to testify and give evidence in the following matter:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
PERSONAL APPEARANCE IS REQUIRED
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
August 28, 2021
AUDREY STRAUSS
United States Attorney for the
UNITED STATES DISTRICT COURT
Southern District of New York
Assistant United States Attorney
RICT FOR THE YORK
One St. Andrew's Plaza
New York, New York 10007
Email:
Telephone:
rev. 02.01.12
EFTA00029588


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=== Page 1 ===
From:
)"
To: Laura Menninger
)"
,
Bobbi Sternheim
N
"BOBBI C STERNHEIM"
Jeff Pagliuca
"Mark S. Cohen"
Cc:
(USANYS)"
)"
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - meet and confer
Date: Thu, 29 Apr 2021 23:00:26 +0000
Attachments: 2021-04-30_Gov't_Letter_to_Manley_(draft_to_defense).pdf
Counsel,
Regarding Mr. Manley's letter, I'm attaching a draft of the letter we would plan to him tomorrow. Please let us know if
you'd like to confer further about this, and we'd be happy to schedule a call for tomorrow.
Thanks,
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)
is
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
EFTA00029138

=== Page 2 ===
To:
>; Bobbi Sternheim
>; 'BOBBI C
STERNHEIM'
>; Laura Menninger
>; Jeff Pagliuca
>; Mark S. Cohen
Cc:
in
(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
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
EFTA00029139


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: Fwd: Mark Epstein Threats (Possible Media)
Date: Fri, 26 Jun 2020 23:41:57 +0000
Poor
Begin forwarded message:
From:
(USANYS)"
Date: June 26, 2020 at 5:37:22 PM EDT
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
)"
(USANYS)"
Subject: Mark Epstein Threats (Possible Media)
Pardon the interruption:
A quick update on the Mark Epstein threats, in case this affects anyone. For those not previously involved with this, a
fraudster in Iran has been tormenting Mark Epstein by email and text, pretending to be about 15 different people using
fake email addresses and some spoofing. These personalities are variously offering to sell (Mark) Epstein money about
his brother's "murder," extorting him for money by threatening to kill his kids, etc. The principal unifying thread is an
attempt to get Epstein to send "them" $25K in bitcoin. Despite the now-obvious fact that the source is a fraud (which
Epstein's attorney knows and has repeatedly told him), Epstein keeps emailing with him, which only eggs the guy on.
I'm writing now just to advise you that the latest threat is to provide media outlets information that Mark Epstein was
involved in his brother's sex crimes. This too is almost certainly a bluff. Nonetheless, in case the perpetrator actually
does try to pass something off to the media, I wanted to give everyone a heads up where it was coming from. If you
want more information, let me know.
Thanks,
EFTA00028319


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=== Page 1 ===
From: "postmaster@msgsvr.voip.usa.doj.gov" <postmaster@msgsvr.voip.usa.doj.gov>
To:
Cc:
Subject: Voice Message Attached from
- EPSTEIN WEIL
Date: Fri, 04 Nov 2016 16:51:15 +0000
Attachments:
wav
Time: Nov 4, 2016 12:51:15 PM
Click attachment to listen to Voice Message
EFTA00029067


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
July 8, 2019
VIA ECF
The Honorable Henry Pitman
United States District Court
Southern District of New York
United States Courthouse
500 Pearl Street
New York, New York 10007
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Pitman:
The Government respectfully submits this letter in advance of the bail hearing scheduled
for July 9, 2019, in the above-captioned case. For the reasons set forth herein, the Court should
issue a permanent order of detention of the defendant; he cannot meet his burden of overcoming
the presumption that there is no combination of conditions that would reasonably assure his
continued appearance in this case or protect the safety of the community were he to be released.
As set forth below, the charges in this case are exceptionally serious: the defendant is
alleged to be a serial sexual predator who preyed on dozens of minor girls over a period of years,
and he now faces a potentially massive prison sentence predicated on substantial and multifaceted
evidence of his guilt. Moreover, in light of the strength of the Government's evidence and the
substantial incarceratory term the defendant would face upon conviction, there is an extraordinary
risk of flight, particularly given the defendant's exorbitant wealth; his ownership of and access to
private planes capable of international travel; and his significant international ties. Indeed, the
arrest of the defendant occurred when he arrived in the United States on his private jet after having
returned from a multi-week stay abroad.
Finally, and as detailed herein, the Government has real concerns-grounded in past
experience with this defendant-that if allowed to remain out on bail, the defendant will attempt
to pressure and intimidate witnesses and potential witnesses in this case, including victims and
their families, and otherwise attempt to obstruct justice. As a result, he poses both an acute danger
to the community, including some of its most vulnerable members, and a significant risk of flight.
The defendant thus cannot overcome the statutory presumption that detention is appropriate in this
case.
EFTA00028297

=== Page 2 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 2
BACKGROUND
A. Overview
On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed
indictment (the "Indictment") charging the defendant with one count of sex trafficking of minors,
in violation of 18 U.S.C. $ 1591, and one count of conspiracy to commit sex trafficking of minors,
in violation of 18 U.S.C. $ 371.
As charged by the grand jury, the facts underlying the charges in the Indictment arise from
a years-long scheme to commit and perpetuate the sexual abuse of underage girls. In particular,
beginning in at least 2002, the defendant enticed and recruited dozens of minor girls to engage in
sex acts with him, for which he paid the victims hundreds of dollars in cash.
He undertook this activity in at least two different locations, including his mansion in
Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the
"Palm Beach Residence"). In both New York and Florida, the defendant perpetuated this abuse in
similar ways. Victims were initially recruited to provide "massages" to the defendant, which
would be performed nude or partially nude, would become increasingly sexual in nature, and
would typically include one or more sex acts, including groping and direct or indirect contact with
victims' genitals. The defendant paid his victims hundreds of dollars in cash for each separate
encounter.
Moreover, the defendant actively encouraged certain of his victims to recruit additional
girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying
these victim-recruiters hundreds of dollars for each additional girl that they brought to him. In this
fashion, the defendant created a vast network of underage victims for him to exploit, in locations
including New York and Palm Beach.
The defendant's victims were as young as 14 years old when he abused them. Many of his
victims were, for various reasons, often particularly vulnerable to exploitation. The defendant
intentionally sought out-and knew that he was abusing-minors. Indeed, in some instances, his
victims expressly told him they were underage before or during the period in which he abused
them.
In creating and maintaining a network of minor victims whom he abused, the defendant
worked with others, including employees and associates who facilitated his exploitation of minors
by, among other things, contacting victims and scheduling their sexual encounters with the
defendant, both in New York and in Florida.
B. The Defendant
Jeffrey Epstein designed, financed, and perpetrated this scheme, both as its main participant
and through his direction of others, including certain of his employees, to further facilitate his
rampant abuse of minor girls.
EFTA00028298

=== Page 3 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 3
As has been widely reported, the defendant is extraordinarily wealthy, and he owns and
maintains luxury properties and residences around the world, including in Manhattan, New York;
Palm Beach, Florida; Stanley, New Mexico; and Paris, France. Additionally, Epstein owns a
private island in the U.S. Virgin Islands which, as noted above, is believed to be his primary
residence in the United States. His mansion in Manhattan alone-a multi-story townhouse
reported to be one of the largest single residences in all of Manhattan, which previously housed a
school and which he owns through an LLC-has been valued for tax purposes at approximately
$77 million. Entities controlled by the defendant also own at least two private jets in active service,
at least one of which is capable of intercontinental travel.
As described further below, the defendant possesses three active United States passports,
and his international connections and travels are extensive. For example, in addition to
maintaining a residence in Paris, France, as described above, in the past 18 months alone, the
defendant has traveled abroad, via private jet, either in or out of the country on approximately
more than 20 occasions.
In or about 2005, the defendant was investigated by local police in Palm Beach, Florida, in
connection with allegations that he had committed similar sex offenses against minor girls. The
investigation ultimately also involved federal authorities, namely the U.S. Attorney's Office for
the Southern District of Florida ("SDFL") and the FBI's Miami Office and included interviews
with victims based in the Palm Beach area, including some of the alleged victims relevant to Count
One of the instant Indictment.¹
In fall 2007, the defendant entered into a non-prosecution agreement with the SDFL in
connection with the conduct at issue in that investigation, which the non-prosecution agreement
identifies as including investigations into the defendant's abuse of minor girls in the Palm Beach
area. The Southern District of New York was not a signatory to that agreement, and the defendant
was never charged federally.2 In June 2008, the defendant pled guilty in state court to one count
of procuring a person under the age of 18 for prostitution, a felony, and one count of solicitation
of prostitution, a felony. As a result, the defendant was designated as a sex offender with
registration requirements under the national Sex Offender Registration and Notification Act.
1 The non-prosecution agreement, further discussed below, was entered into at the conclusion of
the SDFL investigation and did not purport to cover any victims outside of the State of Florida.
As noted above, the instant Indictment expressly alleges the existence of dozens of victims who
were abused in this District in addition to dozens of victims who were abused in Florida.
2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the
Second Circuit that absent an express provision to the contrary in the agreement, one District is
not bound by the terms of an agreement entered into between a defendant and a U.S. Attorney's
Office in another district. See page 6, infra.
EFTA00028299

=== Page 4 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 4
ARGUMENT
I.
Applicable Law
Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to
order a defendant's detention pending trial upon a determination that the defendant is either a
danger to the community or a risk of flight. 18 U.S.C. $ 3142(e) ("no condition or combination of
conditions would reasonably assure the appearance of the person as required and the safety of any
other person and the community"). A finding of risk of flight must be supported by a
preponderance of the evidence. United States V. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United
States V. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be
supported by clear and convincing evidence. United States V. Ferranti, 66 F.3d 540, 542 (2d Cir.
1995); Chimurenga, 760 F.2d at 405. In addition, a court may also order detention if there is "a
serious risk that the [defendant] will
attempt to obstruct justice, or
to threaten, injure, or
intimidate, a prospective witness or juror." 18 U.S.C. $ 3142(f)(2)(B); see United States V.
Friedman, 837 F.2d 48 (2d Cir. 1988).
The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the
nature and circumstances of the crimes charged; (2) the weight of the evidence against the person;
(3) the history and characteristics of the defendant, including the person's "character
[and]
financial resources"; and (4) the seriousness of the danger posed by the defendant's release. See
18 U.S.C. $ 3142(g). Evidentiary rules do not apply at detention hearings and the government is
entitled to present evidence by way of proffer, among other means. See 18 U.S.C. $ 3142(f)(2);
see also United States V. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (government entitled
to proceed by proffer in detention hearings); Ferranti, 66 F.3d at 542 (same); United States V.
Martir, 782 F.2d 1141, 1145 (2d Cir. 1986) (same).
Where a judicial officer concludes after a hearing that "no condition or combination of
conditions will reasonably assure the appearance of the person as required and the safety of any
other person and the community, such judicial officer shall order the detention of the person before
trial." 18 U.S.C. $ 3142(e)(1). Additionally, where, as here, a defendant is charged with
committing an offense involving a minor victim under 18 U.S.C. $ 1591, it shall be presumed,
subject to rebuttal, that no condition or combination of conditions will reasonably assure the
appearance of the defendant as required and the safety of the community. 18 U.S.C.
$ 3142(e)(3)(E).
II.
Discussion
The defendant should be detained pending trial. For the reasons set forth below, it is
difficult to overstate the risk of flight and danger to the community if the defendant is released,
and for those reasons, the defendant cannot overcome the statutory presumption in favor of
detention in this case.
EFTA00028300

=== Page 5 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 5
A. The Defendant Poses an Extreme Flight Risk
Each of the relevant factors to be considered as to flight risk - the nature and circumstances
of the offense, the strength of the evidence, and the history and characteristics of the defendant -
counsel strongly in favor of detention.
1. The Nature and Circumstances of the Offense and the Strength of the Evidence
The "nature and circumstances" of this offense plainly favor detention. 18 U.S.C.
$
3142(g)(1) (specifically enumerating "whether the offense. involves
a
minor
victim"
as
a
factor in bail applications). Indeed, the crime of sex trafficking of a minor is so serious that for a
defendant charged with that offense, there is a presumption that no condition or combination of
conditions will reasonably assure the appearance of the defendant as required and the safety of the
community. 18 U.S.C. $ 3142 (e)(3)(E). Here, as specified in the Indictment, the defendant's
conduct was committed serially, over a period of years, and affected dozens of victims.
The seriousness of the charge is also reflected in the penalties the defendant faces, which
include up to 45 years of incarceration for Counts One and Two of the Indictment.³ As the Second
Circuit has noted, the possibility of a severe sentence is a significant factor in assessing the risk of
flight. See United States V. Jackson, 823 F.2d 4, 7 (2d Cir. 1987); see also United States V. Cisneros,
328 F.3d 610, 618 (10th Cir. 2003) (defendant was a flight risk because her knowledge of the
seriousness of the charges against her gave her a strong incentive to abscond); United States V.
Townsend, 897 F.2d 989, 995 (9th Cir. 1990) ("Facing the much graver penalties possible under the
present indictment, the defendants have an even greater incentive to consider flight."). Here, the
defendant is facing a statutory maximum of decades in prison. Even in the absence of means-
which, as discussed in detail below, the defendant has in abundance-this fact alone would provide
a compelling incentive for anyone to fail to appear. It is particularly compelling for a defendant
who is 66 years old and therefore faces the very real prospect of spending the rest of his life in
prison if convicted.
The likelihood of a substantial period of incarceration is buttressed by the strength of the
evidence. As set forth in the Indictment, the evidence in this case is strong. The Indictment alleges
that the defendant sexually abused dozens of minor victims, and the conspiracy count lists
numerous overt acts committed in furtherance of the defendant's crimes.4
3 The current penalties for violations of 18 U.S.C. $ 1591 include a 10 year mandatory minimum
sentence. However, that punishment was created through an amendment to the statute in 2006.
The penalty for a violation of Section 1591 during the period charged in the Indictment, and
therefore relevant here, was a maximum of 40 years' imprisonment.
4 With respect to the evidence in this case, the Court should start its analysis by accepting that the
Indictment is sufficient, on its own, to establish probable cause that the defendant committed the
crimes of sex trafficking and sex trafficking conspiracy. Contreras, 776 F.2d at 54. ("Were an
evidentiary hearing addressing the existence of probable cause required in every $ 3142(e) case in
which an indictment had been filed, the court would spend scarce judicial resources considering
EFTA00028301

=== Page 6 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 6
Multiple victims, including several specified in the Indictment, have provided information
against the defendant. That information is detailed, credible, and corroborated, in many instances,
by other witnesses and contemporaneous documents, records and other evidence-including, as
further detailed below, evidence from a search of the New York Residence on the night of the
defendant's arrest that reflects an extraordinary volume of photographs of nude and partially-nude
young women or girls. Such corroborating evidence includes documents and other materials, such
as contemporaneous notes, messages recovered from the defendant's residence that include names
and contact information for certain victims, and call records that confirm the defendant and his
agents were repeatedly in contact with various victims during the charged period. Put simply, all
of this evidence - the voluminous and credible testimony of individuals who were sexually abused
by the defendant as minors, each of whom are backed up by other evidence - will be devastating
evidence of guilt at any trial in this case and weighs heavily in favor of detention.
Finally, it bears noting that neither the age of the conduct nor the defendant's previous non-
prosecution agreement ("NPA") with a different federal district pose any impediment to his
conviction. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283,
which was amended in 2003 to permit the prosecution of sex offenses against minor children, and
operates to extend the limitations period for conduct that was timely as of the date of the
amendment, to any time during the lifetime of the minor victim. See United States V. Chief, 438
920, 922-25 (9th Cir. 2006) (finding that because Congress extended the statute of limitations
for sex offenses involving minors during the time the previous statute was still running, the
extension was permissible); United States V. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL
4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same).
Moreover, with respect to the NPA, that agreement, to which the Southern District of New
York was not a party, which by its express language pertained exclusively to the SDFL
investigation, and which did not purport to bind any other Office or District, does not preclude
prosecution in this District for at least two reasons. First, it is well settled in the Second Circuit
that "a plea agreement in one U.S. Attorney's office does not, unless otherwise stated, bind
another." United States V. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) ("A plea agreement binds
only the office of the United States Attorney for the district in which the plea is entered unless it
affirmatively appears that the agreement contemplates a broader restriction.") (citing United States
V. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). This is true even if the text of the
agreement purports to bind "the Government." See Annabi, 771 F.2d at 672. This analysis
similarly extends to a non-prosecution agreement. See United States V. Laskow, 688 F. Supp. 851,
854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is an explicit statement
to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States
Attorney that are not parties to the agreement. This position is at odds with the law in this Circuit,
which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can
that which a grand jury had already determined, and have less time to focus on the application of
the presumptions and the $ 3142(g) factors in deciding whether the defendant should be
detained.").
EFTA00028302

=== Page 7 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 7
affirmatively establish that a more expansive interpretation was contemplated.") (citing Annabi,
771 F.2d at 672). Second, the Indictment charges conduct not covered by the NPA, namely
conduct that occurred in New York. As noted above, the prior NPA includes a list of several dozen
identified victims identified in the prior investigation, all of whom were abused in the State of
Florida, and none of whom are a part of the conduct charged in Count Two of the instant
Indictment.
Each of these factors-the seriousness of the allegations, the strength of the evidence, and
the possibility of lengthy incarceration-creates an extraordinary incentive to flee. And as further
described below, the defendant has the means and money to do so.
2. The Characteristics of the Defendant
The history and characteristics of the defendant also strongly support detention. The
defendant is extraordinarily wealthy and has access to vast financial resources to fund any attempt
to flee. Indeed, his potential avenues of flight from justice are practically limitless.
As the defendant acknowledged in his most recent New York State sex offender
registration, he has six residences, including two in the U.S. Virgin Islands (including his own
private island), and one each in Palm Beach, Florida; Paris, France; New York, New York; and
Stanley, New Mexico. The most recent estimated value of the defendant's New York City mansion
alone is more than $77 million. The most recent tax-assessed value of the defendant's Palm Beach
estate is more than $12 million. The defendant's primary residence is a private island in the U.S.
Virgin Islands, a place where any sort of meaningful supervision would be all but impossible.
Moreover, the defendant has access to innumerable means to flee. His sex registration
documentation of "current vehicles" lists no fewer than 15 motor vehicles, including seven
Chevrolet Suburbans, a cargo van, a Range Rover, a Mercedez-Benz sedan, a Cadillac Escalade,
and a Hummer II. These cars are registered in various states and territories including the Virgin
Islands, New York, Florida, and New Mexico. The defendant also has access to two private jets,
giving him the ability to leave the country secretly and on a moment's notice and to go virtually
anywhere he wants to travel. He is a very frequent international traveler and regularly travels to
and from the United States by private plane. In particular, between January 1, 2018, and the
present, U.S. Customs and Border Patrol has logged approximately more than 20 flights in which
Epstein was traveling to or from a foreign country. Indeed, he was arrested at Teterboro Airport
arriving on just such a private international flight after having spent approximately three weeks
abroad. Extensive international travel of this nature further demonstrates a risk of flight. See, e.g.,
United States V. Anderson, 384 F. Supp. 2d 32, 36 (D.D.C. 2005). There can be no assurance that,
upon release, the defendant would suddenly lack access to such means of travel.
Finally, the defendant has no meaningful ties that would keep him in this country. The
defendant has no known immediate family. He is not married and has no children. He has friends
and associates worldwide, as demonstrated by his extensive international travel, and his
professional obligations, if any, can and seemingly are plainly capable of being handled by the
defendant remotely. Simply put, there would be no meaningful reason for the defendant to remain
in the country, while he would have every incentive (and every resource needed) to flee.
EFTA00028303

=== Page 8 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 8
Nor would home confinement with electronic monitoring reasonably assure the
defendant's presence as required. At best, home confinement with electronic monitoring would
merely reduce his head start should he decide to flee. See United States V. Zarger, No. 00 Cr. 773,
2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application
for bail in part because home detention with electronic monitoring "at best
limits a fleeing
defendant's head start"); see also United States V. Casteneda, No. 18 Cr. 047, 2018 WL 888744,
at *9 (N.D. Cal. Feb. 2018) (same); United States V. Anderson, 384 F.Supp.2d 32, 41 (D.D.C.
2005) (same); United States V. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y.
Oct. 10, 2002) (same).
Finally, there can be little doubt that the defendant is in a position to abandon millions of
dollars in cash and property securing any potential bond and still live comfortably for the rest of
his life. These resources, and the ease with which the defendant could flee and live outside the
reach of law enforcement-particularly considering his vast wealth and lack of meaningful ties to
this District-make the risk of flight exceptionally high in this case, particularly when considered
in conjunction with the strength of the government's case and the lengthy sentence the defendant
could receive if convicted.
B. The Defendant Poses a Risk of Danger to the Community and of Engaging in
Obstruction of Justice
The release of the defendant, under any conditions, would pose a significant threat to the
community and to the ongoing investigation.
As described above, where there is probable cause to believe that an individual has
committed an offense under 18 U.S.C. $ 1591, it is presumed that no condition or combination of
conditions can reasonably assure the safety of the community. 18 U.S.C. $ 3142(e)(3). Here, not
only is the defendant charged with very serious sex crimes against minors, he has already
previously admitted to-and been convicted of-engaging in related conduct. Specifically, in
June 2008, the defendant pled guilty in state court to one count of procuring a person under the
age of 18 for prostitution, a felony, and he currently is a registered sex offender, including under
classification level three in New York-defined as presenting a "high" risk of committing another
sex crime and harm to the community. While the conduct presently alleged does not post-date the
2008 conviction, it nevertheless underscores the risk he poses to the community if released.
Additionally, and in connection with the investigation of the defendant's offense in Florida,
there were credible allegations that the defendant engaged in witness tampering, harassment, or
other obstructive behaviors. In fact, according to publicly-filed court documents, there were
discussions between prosecutors and the defendant's counsel about the possibility of the defendant
pleading guilty to counts relating to "obstruction," as well as "harassment," with reference to
18 U.S.C. § 1512, which criminalizes "[t]ampering with a witness, victim, or informant." For
example, in a communication from the defendant's then-counsel to prosecutors in SDFL, his
counsel set forth a possible factual proffer that included statements that the defendant had
"attempted to harass both [redacted] delay and hinder their receipt of a [redacted] to attend an
official proceeding" and that the defendant "in particular, changed travel plans and flew with both
EFTA00028304

=== Page 9 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 9
[redacted] to the United States Virgin Islands rather than to an airport in New Jersey in order to
attempt to delay their receipt of what Mr. Epstein expected to be a [redacted]" and "further verbally
harassed both [redacted] in connection to this attempt to delay their voluntary receipt of process
all in violation of 18 USC 1512(d)(1)."5 Doe V. United States, 08 Civ. 80736 (S.D. Fla.), Dkts.
361 at 3-4, 361-7 through 361-11. In addition to 18 U.S.C. $ 1512(d), prosecutors also proposed
that the defendant could plead guilty to 18 U.S.C. $ 403, that is, a knowing or intentional violation
of the privacy protection of child victims and child witnesses, to which the defendant's counsel
replied: "Already thinking about the same statutes." Id. Dkt. 361-11. They also discussed a
possible obstruction plea that "could rely on the incident where Mr. Epstein's private investigators
followed [redacted] father, forcing off the road." Id. Dkt. 361-10.
The defendant's apparent previous willingness to obstruct a federal investigation, harass or
tamper with witnesses, and hire private investigators that "forc[ed] off the road" the father of an
individual relevant in the investigation is alarming. It should especially weigh on the Court's
consideration here because the defendant was apparently willing to take those steps before even
being charged and thus facing federal indictment; the incentive to interfere in the Government's
case here, where an Indictment has been returned, is exponentially greater. And as discussed
above, the defendant has nearly limitless means to do so.
Finally, despite having been previously convicted of a sex offense involving an underage
victim, the defendant has continued to maintain a vast trove of lewd photographs of young-looking
women or girls in his Manhattan mansion. In a search of the New York Residence on the night of
his arrest, on July 6-7, 2019, pursuant to judicially-authorized warrants, law enforcement officers
discovered not only specific evidence consistent with victim recollections of the inside of the
mansion, further strengthening the evidence of the conduct in the charged Indictment, but also at
least hundreds-and perhaps thousands-of sexually suggestive photographs of fully- or partially-
nude females. While these items were only seized this weekend and are still being reviewed, some
of the nude or partially-nude photographs appear to be of underage girls, including at least one girl
whose counsel has informed the Government was underage at the time the relevant photographs
were taken. Additionally, some of the photographs referenced herein were discovered in a locked
safe, in which law enforcement officers also found compact discs with hand-written labels
including the following: "Young [Name] + [Name]," "Misc nudes 1," and "Girl pics nude." The
defendant, a registered sex offender, is not reformed, he is not chastened, he is not repentant;6
rather, he is a continuing danger to the community and an individual who faces devastating
evidence supporting deeply serious charges.
5 The redactions above are contained in the publicly filed version of the quoted document.
6 See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator,
N.Y. Post (2011) ("I'm not a sexual predator, I'm an "offender," the financier told The Post
yesterday. 'It's the difference between a murderer and a person who steals a bagel."); Philip
Weiss, The Fantasist, New York Magazine (2007) ("It's the Icarus story, someone who flies too
close to the sun,' I said. 'Did Icarus like massages?' Epstein asked.").
EFTA00028305

=== Page 10 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 10
CONCLUSION
As set forth above, in this case, the risk of flight in this case is extraordinarily real. The
defendant is extremely wealthy, has extensive foreign contacts, and is charged with serious
offenses that carry a potential statutory sentence of up to 45 years' imprisonment-even a fraction
of which could result in the defendant, who is 66 years old, spending the rest of his life in jail. In
sum, the defendant's transient lifestyle, his lack of family or community ties, his extensive
international travel and ties outside the country, and his vast wealth, including his access to and
ownership of private planes, all provide the defendant with the motive and means to become a
successful fugitive. Further, the nature of the offenses he is alleged to have perpetrated-the abuse
dozens of underage, vulnerable girls-along with his demonstrated willingness to harass,
intimidate and otherwise tamper with victims and other potential witnesses against him, render his
dangerousness readily apparent.
As such, the Government respectfully submits that the defendant cannot and will not be
able to meet his burden of overcoming the strong presumption in favor of detention, that there are
no conditions of bail that would assure the defendant's presence in court proceedings in this case
or protect the safety of the community, and that any application for bail should be denied.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
By:
Assistant United States Attorney
Southern District of New York
Tel:
Cc:
Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant
Hon. Richard M. Berman, United States District Judge
EFTA00028306


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=== Page 1 ===
From:
"
To:
Cc:
Subject: NYLJ article
Date: Mon, 11 May 2020 21:19:15 +0000
Attachments: NYLJMay6.pd.pdf
In case you missed it, attached is an article written by Evan Barr about Prince Andrew and "zero cooperation."
Chief, Criminal Division
United States Attorney's Office, SDNY
EFTA00027442


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=== Page 1 ===
Questionnaire for Official Foreign Travel
United States Attorneys' Offices and the Executive Office for United States Attorneys
Last Revised: April 28, 2016
A separate questionnaire is required for each EOUSA/USAO employee who is traveling.
Part I. Traveler Information and Scope of Travel
Full Name
Office (e.g., EOUSA, USAO-ALN, etc.)
USAO-SDNY
Position Title
E-mail Address
AUSA
Telephone Number
Departure Address (City and State)
New York, New York
Departure Date (from Home or Office)
Return Date (to Home or Office)
02/03/2020
02/06/2020
Country of Birth
Place of Birth
Foreign Locations
City
Province (if applicable)
Country
Destination 1
Stockholm
Sweden
Destination 2
Destination 3
Destination 4
Q1: Are you traveling to more than four destinations? If yes,
YES
NO
attach an additional sheet listing the additional destinations.
Q2: Have you completed your travel reservations? If yes, please
attach a detailed flight itinerary, your lodging information, and
YES
NO
any other transportation reservations. If no, please STOP and
make your travel reservations before proceeding.
Q3: Have you already obtained OIA's approval? If yes, please
attach OIA's approval e-mail. If you are traveling for civil
YES
NO
purposes, you do not need OIA's approval to travel. For others,
submit a completed questionnaire to OIA to obtain approval.
Q4: Do you have an official passport that is valid for at least six
YES
NO
months from the date you will arrive in the foreign country?
Q5: Have you submitted a request for an official passport to
YES
NO
EOUSA and is the request currently pending?
Q6: Has the Department of State granted you a waiver of the
requirement for an official passport? If yes, please attach the
YES
NO
State Department's e-mail granting a waiver.
EFTA00027830

=== Page 2 ===
Q7: Do any of your destinations require a visa for travel under
an official passport? If applicable, submit the required materials
YES
NO
to EOUSA to obtain visas prior to departure.
Q8: For the passport under which you will be traveling, please provide the following data:
Passport Issuing
Passport Number
Passport Expiration
Passport Type (e.g.,
(note pending, if
Date (note pending, if
Tourist, Official)
Country
applicable)
applicable)
Official
USA
Q9: Are you traveling to a high-threat area?
YES
NO
Q10: Have you completed HTSOS training in the last five
years? If yes, please attach the training certificate if you are
YES
NO
traveling to a high-threat area.
Q11: Have you completed FACT training in the last five years?
If yes, please attach the training certificate, if you are traveling
YES
NO
to a high-threat area.
Q12: What is your security clearance level? If you have access
Secret
Top Secret
to TS-SCI, you must complete a DOJ-504 and provide it to your
DOSM and receive a security briefing prior to departure.
TS-SCI
Other
Q13: Do you plan to take any government-furnished equipment
(including "bring your own device" equipment) out of U.S.
YES
NO
territory? If yes, submit a request to your IT Systems Manager.
Q14: Will any travel expenses be paid for, or reimbursed, by a
source external to the EOUSA/USAO community? If yes, seek
YES
NO
advance approval from GCO or RMP, as necessary.
Q15: Do your travel arrangements include actual lodging
YES
NO
expenses (i.e., lodging expenses in excess of OCONUS rates)?
Q16: Do your travel arrangements include premium class travel
YES
NO
(e.g., travel accommodations above coach class)?
Q17: Have you already received country clearance from the
State Department through the eCC system? If yes, please attach
YES
NO
the eCC notification that provides country clearance.
Q18: EOUSA requests eCC country clearance for nearly all
EOUSA and USAO travelers. The clearance is required prior to
YES
NO
departure. Shall EOUSA request eCC clearance for you?
Q19: If you do not have eCC authorization to travel, and you
do not want EOUSA to request eCC clearance for you, what
office is requesting eCC clearance on your behalf? Note that
federal investigative agencies are not authorized to obtain eCC
clearance on behalf of EOUSA or USAO attorneys.
EFTA00027831

=== Page 3 ===
Part II. General Questions Applicable to All Foreign Travel
Q20: Who is paying for the travel?
USAO- SDNY
Q21: If foreign embassy personnel or consular or diplomatic officials have been consulted
regarding travel, please provide their names, titles, organizations and contact information.
N/A
Q22: If U.S. Embassy or consular personnel have been involved, please provide their names,
titles, section, and contact information.
N/A
Q23: If assistance from U.S. Embassy or consular personnel is required (e.g., a consular official
to administer an oath) or if office space at an Embassy or consulate is required, please specify. If
the Embassy is coordinating lodging, please include your credit card information.
N/A
Q24: If the assistance of a stenographer, court reporter, interpreter, or other service provider is
required in the foreign country, please provide specific details about when and where services
are required. EOUSA will relay the request to the State Department in the eCC system.
N/A
Q25: Please include any other comments or details that would help the Department of State
ensure that difficulties do not arise.
N/A
Q26: I am traveling
Abroad to Attend a Conference or Training Event (Complete Part III)
To a Country Other Than Canada on a Judicial Assistance Matter (Complete Part IV)
To Canada on a Judicial Assistance Matter (Complete Part V)
EFTA00027832

=== Page 4 ===
Part III. Additional Questions for Conferences and Training Events
Q27: What is the name of the conference event or training program?
Q28: What is the purpose of the conference event or training program?
Q29: What is the specific venue name and address for the conference event or training program?
Q30: Who are the primary points of contact for the conference event or training program? Please
include contact information (e.g., organizations, telephone numbers, and email addresses).
Part IV. Additional Questions for Travel to Countries Other Than Canada on Judicial
Assistance Matters
Q31: Please provide the names, titles, offices, districts, telephone numbers, and email addresses
of the individuals traveling abroad with you for purposes of conducting investigations,
interviews, depositions, inspections, etc. Include all federal, state or local U.S. officials who
intend to travel, as well as service providers who will be traveling with you (if applicable).
AUSA
AUSA
AUSA
FBI SA
Q32: Please provide the case name, USAO number, and court docket number.
In re Jeffrey Epstein, USAO # 2018R01618
Q33: What is the nature of the case (explain briefly in lay terms)? In what stage is the case?
How sensitive is the case in your estimation?
Investigation is ongoing and very sensitive.
EFTA00027833

=== Page 5 ===
Q34: What is the purpose of travel? In particular, specify what will be accomplished during
travel (e.g., interviewing witnesses, taking depositions, etc.).
Interviewing and debriefing a witness.
Q35: Please list the names and nationalities of persons to be interviewed or deposed, including
addresses and telephone numbers if available.
Jane Doe, Swedish
Q36: Is the prosecution of a foreign national foreseen? If so, provide name and nationality.
A subject of the investigation is Ghislaine Maxwell, who is believed to be a citizen of the United States, the United
Kingdom, and France.
Q37: Is a host country government official to be deposed or interviewed? Please provide name,
title, and whether the person has been contacted and has agreed to participate.
No.
Q38: Have foreign authorities (e.g., INTERPOL, foreign police) cleared the visit and are foreign
authorities prepared to cooperate? Please explain in detail and reference the names, titles, and
telephone numbers of the foreign contacts.
Yes.
EFTA00027834

=== Page 6 ===
Part V. Additional Questions for Travel to Canada on Judicial Assistance Matters
Q39: Please provide the names, titles, offices, districts, telephone numbers, and email addresses
of the individuals traveling abroad with you for purposes of conducting investigations,
interviews, depositions, inspections, etc. Include all federal, state or local U.S. officials who
intend to travel, as well as service providers who will be traveling with you (if applicable).
Q40: Please provide the case name, USAO number, and court docket number.
Q41: Briefly explain the background of the case (including the nature of the case, stage of the
case, special sensitivities associated with the case, and how much money is involved).
Q42: What is the purpose of travel? In particular, specify what will be accomplished during
travel (e.g., interviewing witnesses, taking depositions, etc.). Include the dates and times of the
interviewing, investigating or other activities. Why is travel to Canada necessary?
EFTA00027835

=== Page 7 ===
Q43: Names of persons to be interviewed or deposed, including dates of birth, nationality and
citizenship, phone numbers, and home or business address for each witness and any other
pertinent information that may assist in locating them. If this information is unavailable,
DFAIT will not grant clearance.
Q44: Provide confirmation that the interviews or depositions are voluntary and provide the
contact information for the persons who have contacted the witnesses/suspects (e.g., Royal
Canadian Mounted Police).
Q45: Provide the name and contact information for any legal representative(s) who may take part
in the proceedings, as well as that of their firm/organization.
Q46: If the prosecution of a foreign national is foreseen, please provide name and nationality.
Q47: If a Canadian government official is to be deposed or interviewed, provide name, title, and
whether the person has been contacted and has agreed to participate.
Q48: If INTERPOL, Canadian law enforcement, or another Canadian authority has cleared the
visit or if Canadian authorities are otherwise prepared to cooperate, explain in detail including
names, titles, and telephone numbers of the Canadian contact(s).
The completed questionnaire and attachments (e.g., itinerary, training certificate), should be:
Emailed to OIA to obtain OIA's approval for foreign travel (unless OIA approval has already been
obtained or unless travel is for civil purposes only)
Emailed to EOUSA (using the USAEO-Foreign Travel Mailbox)
Included as an attachment to the foreign travel authorization in E2 Solutions.
If you have any questions about foreign travel, please contact the EOUSA RMP Travel Unit by emailing USAEO-
Foreign Travel or by calling (202) 252-5600.
EFTA00027836


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=== Page 1 ===
90A-NY-3151227 Serial 44
FD-1057 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Electronic Communication
Title: (U) Items 1B37, 1B38 transfer to NY OCME
Date: 08/19/2019
From: NEW YORK
NY-C19
Contact:
,
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Synopsis: (U) Items 1B37, 1B38 transfer to NY OCME
Enclosure (s) : Enclosed are the following items:
1. (U) OCME Evidence Receipt
Details:
On 08/12/2019, TFO NYPD Det.
dropped off items 1B37 and
1B38 at the Office of the Chief Medical Examiner at approximately 11:56AM
for examination. An evidence receipt is attached in a 1A package.
UNCLASSIFIED
EFTA00027968


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=== Page 1 ===
From:
To:
Subject: RE: travel approval request
Date: Mon, 28 Oct 2019 13:27:20 +0000
Good morning
Have you finalized the dates and location for your trip to West Palm Beach, FL scheduled between Nov 3 - 5th? I'd like to
start the reservation process for the airfare, hotel and amount of days you'll need a conference room. Let me know ASAP
so your preferred options don't sell out. Thanks as always.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Tuesday, October 22, 2019 2:03 PM
To:
>
Cc:
is
is
is
Subject: RE: travel approval request
Thanks very much.
From:
Sent: Tuesday, October 22, 2019 14:00
To:
Cc:
is
is
is
Subject: RE: travel approval request
Approved for both and the conference room.
From:
Sent: Tuesday, October 22, 2019 1:55 PM
To:
Cc:
is
>;
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and
we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel on that Monday for the interview, please.
thanks very much,
EFTA00028468

=== Page 2 ===
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
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).
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
EFTA00028469

=== Page 3 ===
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.
Assistant U.S. Attorney
Southern District of New York
EFTA00028470


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=== Page 1 ===
From:
To:
)"
Cc:
Subject: FW: New documents:
Maxwell (Doc# 1078, S.D.N.Y. 1:15-cv-07433-LAP)
Date: Wed, 29 Jul 2020 19:06:15 +0000
Attachments: 2020-07-29_[01078-].zip
Inline-Images: image001.jpg
From:
Sent: Wednesday, July 29, 2020 2:35 PM
To:
y.
>;
Subject: FW: New documents:
V. Maxwell (Doc# 1078, S.D.N.Y. 1:15-cv-07433-LAP)
I wanted to alert you that Maxwell's counsel just filed the attached public filing in the
/. Maxwell case.
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: Wednesday, July 29, 2020 2:07 PM
To:
Subject: New documents:
V. Maxwell (Doc# 1078, S.D.N.Y. 1:15-cv-07433-LAP)
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
. Maxwell
Docket entry number: 1078
LETTER addressed to Judge Loretta A. Preska from Ty Gee dated July 29, 2020 re:
Reconsideration of the Courts July 23 Ruling. Document filed by Ghislaine Maxwell.
EFTA00027729

=== Page 2 ===
(Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5)
Exhibit E). (Gee, Ty) (Entered: 07/29/2020)
Date entered: 2020-07-29
VIEW CASE
https://app.pacerpro.com/cases/1833757
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
EFTA00027730


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE:
Date: Tue, 07 Jul 2020 14:28:19 +0000
Just got a call from
he spoke with Scarola and
and she is apparently willing to meet with us. He
seemed to have no compunction about meeting in person, and either his or Scarola's office, and they're all (including
)
local in West Palm. I told him we'd get back to him sometime this week on whether it makes more sense to do a
webex/zoom/ call rather than for us to fly, and we can circle up on that later today any time. Kind of an odd series of
developments with her, obviously, given the extreme difficulties we had in meeting with her previously, but here we are.
Assistant U.S. Attorney
Southern District of New York
EFTA00027348


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=== Page 1 ===
From:
"
)"
To:
)"
Subject: Accepted: Epstein discovery deadline
Date: Wed, 31 Jul 2019 16:15:57 +0000
Importance: Normal
Attachments: unnamed
EFTA00028075


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Accepted: TC with Reid Weingarten re Epstein
Date: Tue, 19 Nov 2019 20:17:12 +0000
Importance: Normal
Attachments: unnamed
EFTA00029192


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: CONFIDENTIAL: Coordinating Victim Interviews Against Jeffrey Epstein, 19 Cr. 490 (RMB)
Date: Tue, 13 Aug 2019 21:40:42 +0000
Or we use USAO funds to bring them in, via
From:
Sent: Tuesday, August 13, 2019 5:38 PM
To:
Cc:
Subject: FW: CONFIDENTIAL: Coordinating Victim Interviews Against Jeffrey Epstein, 19 Cr. 490 (RMB)
What case am I using to bring witnesses into SDNY. I can only bring people in for GJ, pretrial, trial and sometimes pre GJ.
For the last three witnesses it was pre-trial. But that was when we had an open indictment.
If you are interviewing more people in an investigation you are going to have to travel to them.
I am not giving anyone a hard time I just need to follow the rules.
Please let me know.
From: Colleen Mullen
Sent: Tuesday, August 13, 2019 5:20 PM
To:
Cc: Teri Gibbs
Arick Fudali
Subject: CONFIDENTIAL: Coordinating Victim Interviews Against Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear
I spoke to
yesterday and she confirmed that she is still interested in speaking with our clients.
is still available to meet with prosecutors on August 26, 2019 at 12:00 p.m. in New York.
Please let me know what information you need from me to arrange flights/hotel stay for Ms.
Additionally, you previously mentioned that there may be counseling resources available for our clients. Could
you send me that information as well?
Thank you,
EFTA00027107

=== Page 2 ===
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.
EFTA00027108


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=== Page 1 ===
From:
=
To:
Subject: Accepted: [EXTERNAL EMAIL] - Call w/ SDNY re: discovery, Epstein investigation
Date: Thu, 22 Oct 2020 17:04:20 +0000
Importance: Normal
Attachments: unnamed
EFTA00029143


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=== Page 1 ===
From:
)"
To:
Subject: FW: US V. Epstein
Date: Wed, 02 Jun 2021 17:12:33 +0000
Attachments: Copy_of_USVP00300765_-_Possible_PROD_BEG_BATES.xlsx
From:
Sent: Wednesday, June 2, 2021 1:00 PM
To:
Subject: RE: US V. Epstein
Hello
Please use the attached spreadsheet for this meeting.
From:
Sent: Tuesday, June 1, 2021 1:00 PM
To:
Subject: RE: US V. Epstein
Will do, thanks.
From:
Sent: Tuesday, June 1, 2021 12:58 PM
To:
Subject: RE: US V. Epstein
The day and time works. Just send me the dial-in information.
Thank you.
From:
Sent: Tuesday, June 1, 2021 12:32 PM
To:
Subject: RE: US V. Epstein
Hi
Yes definitely, let's have a call on Wednesday (tomorrow). Would 12:30pm work?
Thanks,
EFTA00028703

=== Page 2 ===
From:
Sent: Tuesday, June 1, 2021 10:45 AM
To:
Subject: US V. Epstein
Hello
I wanted to know if you had time this week for a call as me and the vendor wanted to discuss a few items with you from
our last call and give you something to review. It will be easier to discuss if we are all on the phone at the same time. Me
and the vendor can be available either Wednesday or Friday of this week. Please let me know what works for you.
Thank you.
EFTA00028704


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Subject: FW: Jeffrey Epstein
Date: Sun, 07 Jul 2019 17:15:04 +0000
Importance: Normal
Unbelievable work all!
From:
(USANYS)
Sent: Sunday, July 7, 2019 1:08 PM
To: D
Cc:
is
>;
is
(USANYS)
Subject: Jeffrey Epstein
Hey PCU - As you likely may have seen/heard at this point, last evening, we arrested Jeffrey Epstein on sex trafficking
charges. Epstein is in custody and will be presented and arraigned on an Indictment that will be unsealed tomorrow
morning.
The case is an incredibly important one - not only is the conduct extremely serious and deeply disturbing - but our
charges ensure that dozens if not more of Epstein's victims, girls who were as young as 14 at the time they were abused,
will finally have their day in court. It is an extraordinarily worthy prosecution and just the latest example of how this unit
will never shy away from bringing tough cases against powerful people who have committed grievous crimes.
Please join me and
in extending a very well-deserved congratulations to the team,
who
have worked tirelessly to make this case happen (and happen so quickly). They have done us all proud, and if you are
free, we hope you join us for the press conference formally announcing the charges, which should happen Monday
morning at 11.
&
EFTA00028362


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: Fwd: PC Unit -- Short Form Update.1.4.19.docx
Date: Sat, 05 Jan 2019 22:35:28 +0000
Importance: Normal
Attachments: PC_Unit__Short_Form_Update.1.4.19.docx; ATT00001.htm
Sent from my iPhone
Begin forwarded message:
From:
"
(USANYS)"
Date: January 4, 2019 at 5:42:37 PM EST
To:
(USANYS)"
Subject: PC Unit -- Short Form Update.1.4.19.docx
Updates attached
EFTA00029285


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=== Page 1 ===
From: "Berman, Geoffrey (USANYS)"
To: Jean James <jeanjames@telus.net>
Subject: Read: Fwd: VIDEO CHILD SEX TRAFFICKING - JEFFREY EPSTEIN CONNECTIONS
Date: Fri, 12 Jul 2019 10:45:23 +0000
Importance: Normal
EFTA00029522


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
,
)"
Subject:
TW 3500
Date: Thu, 11 Nov 2021 17:41:18 +0000
Attachments:
Hi,
Attached are notes to add to
TW folders.
Thanks!
EFTA00029581


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=== Page 1 ===
90A-NY-3151227 Serial 40
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Derivative
Date: 08/16/2019
Evidence NYC027713
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S), ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) CART-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Derivative Evidence NYC027713: One (1) Seagate
Barracuda 1000GB HDD, ST1000DM003, S/N S1D9GK9P, containing the Clone
Copy of 1B16 hard drive (Seagate Constellation ES 500GB HDD, ST500NM0011,
S/N Z1M1P207), collected via Tableau TX-1 S/N 000ECC58017194. Request ID
112048. Derivative Copy.
Item Type
Description
1B Digital
(U) NYC027713: One (1) Seagate Barracuda 1000GB HDD,
ST1000DM003, S/N S1D9GK9P, containing the Clone Copy of
1B16 hard drive (Seagate Constellation ES 500GB HDD,
ST500NM0011, S/N Z1M1PZ07), collected via Tableau TX-1
S/N 000ECC58017194. Request ID 112048. Derivative Copy.
Collected On: 08/12/2019 07:00 PM EDT
Seizing Individual:
Collected By:
Device Type: Hard Drive
Designation: Derivative
Number of Devices Collected: 1
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00027966

=== Page 2 ===
90A-NY-3151227 Serial 40
UNCLASSIFIED
Title: (U) Submission of CART Derivative Evidence NYC027713
Re: 90A-NY-3151227, 08/16/2019
UNCLASSIFIED
2
EFTA00027967


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=== Page 1 ===
From:
To:
Cc:
Subject: 2021-04-22 Gov't Letter Regarding NPA.v5.docx
Date: Fri, 23 Apr 2021 13:38:37 +0000
Attachments: 2021-04-22_Govt_Letter_Regarding_NPA.v5.docx
Hi
- Two small suggestions in the attached in track changes. Give me a call when you get into the office.
Thanks!
EFTA00027175


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=== Page 1 ===
From:
)"
To: Nathan NYSD Chambers
Cc:
)"
,
)"
Subject: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Date: Thu, 02 Jul 2020 14:25:39 +0000
Attachments: Maxwell_Indictment,_20_Cr._330_(AJN).pdf
Good morning,
The above-captioned case was wheeled out to Judge Nathan this morning. Attached please find the indictment.
The defendant was arrested at approximately 8:30am in New Hampshire, and the Government expects that she will be
presented before a Untied States Magistrate Judge in the District of New Hampshire this afternoon. The Government
intends to seek the defendant's detention, and if that application is denied in New Hampshire, the Government expects to
seek an appeal of that determination before Judge Nathan.
The AUSAs on this case are cc'd on this email, and I have listed our respective phone numbers below:
We would be very grateful if the Court would be able to set an initial conference date that the Government can convey at
this afternoon's presentment. We can be reached at any time should the Court have any questions.
Respectfully,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00028771


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=== Page 1 ===
From:
(NY) (FBI)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Re: Requested Documentation
Date: Sun, 11 Aug 2019 15:01:03 +0000
Sure -
, sending now
-
On Aug 11, 2019 10:59 AM,
(USANYS)"
wrote:
,
would you mind forwarding
the emails you sent me? I'm having trouble forwarding from my
phone given the file size. Thank you.
On Aug 11, 2019, at 10:37 AM,
(NY) (FBI) <
wrote:
-
Forwarded message
From:
Date: Aug 10, 2019 10:57 PM
Subject: Requested Documentation
To:
(NY) (FBI)"
V
Cc:
Please let me know if you need anything else.
Epstein Investigative Reports.pdf>
<Additional Psychology Notes.pdf>
EFTA00027262


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=== Page 1 ===
From: "Strauss, Audrey (USANYS)"
To:
)"
Cc:
(USANYS)"
(USANYS)"
"
(USANYS)"
)"
Subject: Re: Friendly Subpoena to
Attorney
Date: Fri, 26 Mar 2021 23:16:02 +0000
Approved
Sent from my iPhone
On Mar 26, 2021, at 12:05 PM,
)
wrote:
Hi Audrey,
The Maxwell team would like to send the attached "friendly subpoena" to
attorney
During our interviews in Florida,
informed me that he has a copy of the settlement agreement between
and Epstein, which resolved
2009 civil suit against Epstein.
is willing to provide us with a copy of the
agreement, but he indicated that he believes he needs a subpoena before he can do so. His firm has already provided
us with copies of all other court filings and deposition transcripts from the civil case voluntarily. The settlement
agreement resolving the case is relevant to our ongoing investigation into Maxwell's participation in the abuse of
and other underage girls.
Thanks,
Maurene
<2021.03.26, subpoena to
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=== Page 1 ===
From:
To:
)"
Cc:
)"
Subject: RE: travel approval request
Date: Tue, 28 May 2019 14:37:47 +0000
Importance: Normal
No problem, just wanted to check - thanks everybody for letting me know!
From:
Sent: Tuesday, May 28, 2019 10:37
To:
>
Cc:
is
is
Subject: RE: travel approval request
Okay, thanks for informing me
I'll know for the future if this situation arises again.
as per the attached email from
unfortunately the Government won't be able to refund the cancellation fee.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Tuesday, May 28, 2019 10:31 AM
To:
Cc:
>;
>;
Subject: RE: travel approval request
Regretfully, he cannot received a refund from the government.
From:
Sent: Tuesday, May 28, 2019 10:18 AM
To:
Cc:
is
is
Subject: FW: travel approval request
Importance: High
Good morning all,
clarified that the San Francisco trip below was actually a personal trip. He is asking about receiving a credit
card refund for cancelling his San Francisco trip due to a work-related business trip occurring the same day. Would he be
able to receive reimbursement for the $100 cancellation fee he received?
EFTA00028655

=== Page 2 ===
If possible, would I need to fill out a SF-1164 to process his reimbursement, or is there another form I would need to fill
out? Any info on how to proceed is appreciated. Thanks as always!
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Tuesday, May 28, 2019 9:49 AM
To:
Subject: RE: travel approval request
Just a quick question regarding the cancelled trip for this Thursday (5/30/19). Was this trip booked through CWT by phone
or online? If either scenario, l'll need the cancelled record locator to see if it's refundable, and ask them to send me a
document stating it was refunded to your government travel card. Thanks.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Sunday, May 26, 2019 2:31 PM
To:
Subject: FW: travel approval request
Hi
I have a trip scheduled for this week that just got final approval late Friday night, so I made reservations on E2 this
weekend and wanted to let you know in case you need to do things for authorization and/or if you want to consolidate
the reservations (unfortunately I couldn't figure out how to do everything together so ended up with three different
reservations-l'm sorry about that!).
Because I had a previously-scheduled trip to San Francisco on this Thursday,
approved my second leg flight to go
straight there (rather than coming back to NYC). The reservations I made are:
Tuesday, May 28, flight from LGA to PBI
-
JetBlue, departing 1:27 p.m. (arriving 4:25 p.m.)
Tuesday, May 28, hotel in West Palm Beach
-
Hilton West Palm Beach, from May 28 to May 30
Thursday, May 30, flight from PBI to SFO (with layover in ATL)
-
Delta, departing 5:30 a.m. (arriving ATL at 7:12 a.m., departing ATL at 8:10 a.m.) arriving SFO at 10:22 a.m.
If these need to be canceled and re-booked as one itinerary, that's totally fine, I just didn't want to wait until the day
before to at least make the reservations.
Last question is, I had to cancel my New York to San Francisco flight previously scheduled for Thursday morning (because
there were no flights late enough to be after our final interviews in Florida on Wednesday, or early enough to get me back
EFTA00028656

=== Page 3 ===
to New York on Thursday) which incurred a $100 cancellation fee. Is it possible to be reimbursed for that?
Please let me know if any questions at all, apologies again for any inconvenience, and thanks as always.
From:
Sent: Friday, May 24, 2019 21:24
To:
Cc:
Subject: Re: travel approval request
Approved
Sent from my iPad
On May 24, 2019, at 7:21 PM,
wrote:
-- I have previously-scheduled travel to San Francisco next Thursday for a wedding, and the way our victims have
asked to schedule our meetings for our Florida trip, there's no flight back to New York after we expect the interviews to
end on Wednesday (so I couldn't get back to NYC to catch my Thursday morning flight). Is it permissible for me to just
book the second leg of the work trip straight to San Francisco, rather than back to New York? I'd have to take a 5:30
a.m. flight but that way we could do the interviews with all the victims we'd like to meet with. Sorry for any
inconvenience but wanted to check - thank you!
From:
Sent: Friday, May 24, 2019 16:01
To:
Subject: RE: travel approval request
Thanks
- have a great weekend.
From:
Sent: Friday, May 24, 2019 15:55
To:
Cc:
is
Subject: Re: travel approval request
All approved.
Sent from my iPad
On May 24, 2019, at 2:57 PM,
wrote:
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).
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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.
EFTA00028658

=== Page 5 ===
Assistant U.S. Attorney
Southern District of New York
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From:
To:
Cc: "
Subject: Re: SDNY Opposition to Epstein Bail Motion
Date: Fri, 12 Jul 2019 22:27:49 +0000
Importance: Normal
Thank you.
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=== Page 1 ===
From: Jack Scarola
To:
)"
Cc:
)"
)"
Subject: Re:
Date: Tue, 10 Mar 2020 13:42:11 +0000
telephone number is
Multiple messages left at that number have elicited no response.
On Mar 9, 2020, at 3:34 PM,
)
wrote:
Jack,
Thanks for letting us know. Is there any contact information for Ms.
you can provide us with?
Thanks,
From: Jack Scarola
Sent: Monday, March 9, 2020 12:24 PM
To:
Cc:
);
Subject: Re:
My messages to
have not been responded to. I have no objection to your direct contact with her.
On Mar 9, 2020, at 10:32 AM,
)
wrote:
Jack,
I'm following up on our conversation from last week to ask if you've had a chance to speak with Ms.
regarding a
potential meeting with our team. We'd very much appreciate a chance to meet with her, and would be happy to address
any questions you or she might have if that's helpful.
If you no longer represent Ms.
,
please let us know so that we can reach out to her directly.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
| Privileged and Confidential I 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
EFTA00027346

=== Page 2 ===
attributed to the law firm. If you received this communication in error, please notify the sender immediately by
e-mail or by telephone at
and destroy all copies of the original message. Thank you.
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From:
To:
Cc:
Subject: prevailing party
Date: Fri, 15 Oct 2021 03:30:23 +0000
Attachments: prevailing_party.docx
Hey
Here's a short/rough drop in on this. If you could please add the citations to the respective dockets, that would be great,
thanks. The complaints are in their 3500 folders if you're looking for docket numbers.
brought the suit under her
real name, and the Victim-1 case is Doe V. Indyke.
Thanks so much for all the great work you're doing on the motions, really appreciate it.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00029302


