# docs_fts_content

c1: EFTA00019464
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019464.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: EOUSA-2020-003382, ABC News
Date: Tue, 07 Jul 2020 20:17:06 +0000
Attachments: EXEMPTION_MEMO.docx
Good afternoon,
Here is a new FOIA request regarding United States V. Jeffrey Epstein. I am attaching a standard
exemption document for you. Please try to send it back on or about July 14th, 2020.
The requester entered his request directly into the portal rather than a PDF.:
"Dear records officer, Pursuant to FOIA, I request a copy of the 5 years of banking records of
Jeffrey Epstein from "Insitution-1" referenced by SDNY in a Jul 12, 2019 letter to Richard
Berman (see Page 11 of supporting document). Please acknowledge receipt of this request.
Thank you. Exact Source: Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19"
Thank you!
EFTA00019464


c1: EFTA00018583
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018583.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
HADDON
MORGAN
FOREMAN
PH
www.hmflaw.com
August 9, 2020
VIA EMAIL
Assistant United States Attorney
New York, New York 10007
Re: Conferral Concerning Use of Discovery Materials GM_00000847-962
Dear
Ms. Maxwell is actively litigating issues related to disclosure of confidential material
in
V. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) and a related appeal in the
United States Court of Appeals for the Second Circuit, 20-2413.
We intend to ask Judge Nathan for permission to refer to and attach, as exhibits, the
above referenced discovery materials which relate to the Government's efforts to
obtain civil litigation discovery material ("the Unsealing Materials") in two, settled,
civil matters in which Ms. Maxwell was named a defendant. These materials would
be disclosed to Judge Preska and designated as part of the appendix to Ms. Maxwell's
appeal in the Second Circuit. We have no objection, at this point, to filing the
materials under seal in both courts.
In your letter to defense counsel dated August 5, 2020 you designated the Unsealing
Materials as Confidential. We understand that the Unsealing Materials were filed ex
parte and remain sealed in the miscellaneous actions. The documents, however, do
not contain confidential information as that term is defined in paragraph 8 of the
Protective Order entered by Judge Nathan. The Unsealing Materials are ex parte
pleadings filed by the Government, transcripts of ex parte hearings regarding those
pleadings, and ex parte rulings on the pleadings. As least one set of individuals
outside this prosecution, the Boies, Schiller & Flexner lawyers cooperating with the
Government, are aware of the Unsealing Materials. Moreover, these are the types of
pleadings that the Second Circuit has characterized as judicial documents with a
presumptive right of public access. See Brown V. Maxwell, 929 F.3d 41, 47 (2d Cir.
2019). Ms. Maxwell, under paragraph 9 of the Protective Order in this case, notifies
EFTA00018583

=== Page 2 ===
August 9, 2020
Page 2
the Government that she objects to the confidential designation and requests that the
Government withdraw the designation.
The relevance of these documents to the unsealing protocol currently in process
before Judge Preska and the related appeal are readily apparent and I believe that the
government should, in the interest of justice, agree to these requests. If that is not the
case, I am happy to confer further about the issue as soon as possible. The Second
Circuit Court of Appeals established an expedited briefing schedule and Judge Preska
ordered that the parties in 15 Civ. 7433 meet regarding modification to the unsealing
protocol by August 10, 2020. Accordingly, we will need to raise this issue with Judge
Nathan this week.
Please let me know your position on the matter and, if you would like to discuss the
request further, your availability on August 10 or 11, 2020.
Very truly yours,
Jeffrey S. Pagliuca
EFTA00018584


c1: EFTA00018224
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018224.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Chronology
Date
Event
Source
7/3/19
Contraband phone seized from NT
7/6/19
JE booked into MCC
7/23/19
JE found unresponsive in cell w/NT and calls
guard
JE and NT removed from cell and search
BS assumes correct
executed
JE claims NT assaulted him
BE assumes
JE on suicide watch
7/23/19
Sometime between 7/23 and 7/27, NT found
through
the note
7/27/19
7/24/19
BB gets messages from NBC re: claims against
NT
7/25/19
News outlets carry story NT assaulted JE
Client OK's BB talking to press and he refuted
JE's claim and attacked prison conditions
TR disagreed with that decision
7/27/19
BB visited NT and NT told him JE left him a
BB response/TR seems to
note in his book. Asked guard if NT could go
corroborate that NT told BB
retrieve it and guard said no. BB told NT to
the note was in his book
give it to next lawyer that visits him.
BB called JW, who was going to visit later that
BB response
day and told him he would be getting a doc
from NT
JW went later that day and NT gave him the
BB response
note, which he still has.
7/28/19
BB's first investigator said he could not
BB response
authenticate the note
7/29/19
BB's second investigator said he could not
BB response
authenticate the note
7/29/19
BB advised TR about the note and what to do.
BB response, which seems to
be corroborated by TR
7/29/19
JE removed from suicide watch and placed in
different cell (not with NT) in SHU
7/30/19
BB's co-counsel spoke with TR again and read
BB response
note to him. BB spoke w/TR twice and TR
also raised concerns re: authenticity of note.
8/2/19
BB and co-counsel away and no discussions re:
BB response
through
note
8/6/19
8/9/19
NY cleared of causing JE's injuries
8/10/19
JE found dead in his cell
EFTA00018224

=== Page 2 ===
8/21/19
Sternheim appointed
8/23/19
Disclosure of note to trial team w/BS present.
TR
He revealed he visited NT and NT told him a
letter was left in my book, etc. BS saw note on
the phone that day.
11/10/19
CNN report: BB quoted saying "notion Epstein
was murdered is ridiculous."
Also, said MMC guards threatened NT to "shut
up" and "stop talking." In a letter to Judge
Karas, BB wrote the message is that if NT
conveys info about the facility or about JE's
recent suicide, there will be a price to pay.
Also complained about deplorable conditions
at MCC.
1/5/20
BB appeared on 60 Minutes and said NT had
60 Minutes video on line.
info on prison conditions, JE's attempted
suicide and JE's suicide.
Recently, BB authenticated note (1/5/20 60
Ross letter
Minutes show has another note on line.
1/8/20
Sternheim report available for pick up
1/16/20
Barket Response to Sternheim report
2
EFTA00018225


c1: EFTA00018552
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018552.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Freddy Caraballo Proffer (re Epstein)
Start Date: 2019-09-05 14:30:00 +0000
End Date: 2019-09-05 15:30:00 +0000
Organizer:
Location: 1 St. Andrews - 303
Class: X-PERSONAL
Date Created: 2019-08-30 20:48:04 +0000
Date Modified: 2019-08-30 20:48:04 +0000
Priority: 5
DTSTAMP; 2019-08-30 17:40:34 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00018552


c1: EFTA00018920
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018920.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
A. (NY) (FBI)"
To:
(USANYS)"
Cc:
(DO) (FBI)"
,
,
J. (NY) (FBI)"
Subject: Fwd: UK / US Contact Details
Date: Mon, 09 Dec 2019 12:11:58 +0000
Attachments: To_G.Berman,_United_States_Attorney.pdf;1 image001.png
Inline-Images: image003.png; image004.jpg
Here is the information requested from London.
-
Forwarded message
From:
Date: Dec 9, 2019 7:05 AM
Subject: UK / US Contact Details
To:
A. (NY) (FBI)"
Cc:
Sir,
Please find attached a letter from DAC
addressed to the United States Attorney with details of the relevant legal
representative.
Kind regards,
Detective Sergeant
Staff Officer to Deputy Assistant Commissioner (Specialist Operations)
Telephone
MetPhone
Mobile
Email
Address 4th Floor, New Scotland Yard, Richmond Terrace, Victoria Embankment, London SW1A 2JL
CELEBRATING
100
YEARS
ITAN POLICE WOMEN
COUNTER
TERRORISM
ACT
ACTION
COUNTERS
POLICING
TERRORISM
EFTA00018920

=== Page 2 ===
NOTICE - This email and any attachments are solely for the intended recipient and may be confidential. If you have received
this email in error, please notify the sender and delete it from your system. Do not use, copy or disclose the information
contained in this email or in any attachment without the permission of the sender. Metropolitan Police Service (MPS)
communication systems are monitored to the extent permitted by law and any email and/or attachments may be read by
monitoring staff. Only specified personnel are authorised to conclude binding agreements on behalf of the MPS by email and
no responsibility is accepted for unauthorised agreements reached with other personnel. While reasonable precautions have
been taken to ensure no viruses are present in this email, its security and that of any attachments cannot be guaranteed.
EFTA00018921


c1: EFTA00019312
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019312.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
(USANYS)"
Subject: Epstein estate subpoena
Date: Mon, 21 Dec 2020 16:16:40 +0000
Hey
Do you happen to recall where things stood with the Epstein estate regarding the subpoena for images and videos when
you transitioned off the case? We want to check back in with the estate attorneys, but want to check where we left things
before reaching out. In trying to figure out where things stand, I was looking through our past subpoenas, but couldn't
find the subpoena to the estate covering images/videos. Do you know where I can find that?
Thanks,
EFTA00019312


c1: EFTA00018878
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018878.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Court Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Amazon.com, Inc.
Corporation Service Company
Legal Department - Subpoena
MC-CSC1, 300 Deschutes Way SW, Suite 208
Tumwater, WA 98501
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:
Subscriber records, order history, billing/shipping information, and means and source of payment from
January 1, 1994 until January 1, 2005, for the following identifiers:
gmax1@mindspring.com, gmax@mindspring.com, gmax1@ellmax.com and
gmax@ellmax.com
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
September 27, 2021
/s
AUDREY STRAUSS
United States Attorney for the
DEPARTMENT UNITED COURT
Southern District of New York
FOR
THE
Assistant United States Attorney
RICT
YORK
One St. Andrew's Plaza
New York, New York 10007
Rev. 02.01.12
EFTA00018878


c1: EFTA00020181
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020181.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "Moyne, Parvin"
To:
Cc: "Moyer, Thomas"
Subject: 2019.8.15 - SDNY Production Index.xlsx
Date: Thu, 15 Aug 2019 13:47:58 +0000
Attachments: 2019.8.15_-_SDNY_Production_Index.xlsx
&
Please find attached an index to our productions to date. This is a work in progress - we will update it as we gather and
produce additional documents.
Would you like to touch base later today about scheduling a proffer? We are free after 4 p.m.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
EFTA00020181


c1: EFTA00018969
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018969.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Redlined statement
Date: Sat, 10 Aug 2019 17:07:39 +0000
Attachments: Jeffrey_Epstein_Statement.docx
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I
Mobile:
I
Press Office:
EFTA00018969


c1: EFTA00020090
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020090.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
PANISH
SHEA &
BOYLE
LLP
June 8, 2020
VIA E-MAIL AND FEDEX
The Honorable Geoffrey S. Berman
United States Attorney for the
Southern District of New York
c/o
Assistant United States Attorney
E-mail:
Re:
Request for Tangible and Documentary Evidence (Touhy Request)
Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF
Dear Mr.
:
Please be advised that we represent the plaintiff in the above-referenced litigation who is
hereby submitting this written request for documentary and tangible evidence relating to the U.S.
Government's investigation concerning Jeffrey E. Epstein's repeated acts of sexual abuse against
our client, Jane Doe. I See United States ex rel. Touhy V. Ragen, 340 U.S. 462 (1951). We
believe that such evidence is currently in the possession, custody and control of the Department
of Justice ("DOJ") and are highly relevant to Doe's above-referenced civil matter.
This written request is submitted pursuant to 28 C.F.R. $ 16.21 et seq., known
colloquially as the "Touhy" regulations. Because this request is directed to DOJ employees,
compliance is subject to the Touhy process, and for that reason we have not affected formal
service of process and hope that it will be unnecessary.
Summary of Information Sought and its Relevance to the Proceeding
Doe's civil case arises out of years of sexual abuse and exploitation by notorious
pedophile and convicted sex offender Jeffrey E. Epstein. It all started in 1994 when 13-year-old
Doe met Epstein at a summer camp in Michigan. Doe was Epstein's first known victim and was
1
To protect her anonymity, our client has elected to file her action as a Jane Doe and will be
referred to simply as "Doe" in this letter. The prosecutors handling the Epstein case and any and
all related ongoing investigations in your office, however, are aware of our client's true identity.
11111 Santa Monica Boulevard, Suite 700
Los Angeles, California 90025
310.477.1700 phone
310.477.1699 fax
www.psblaw.com
EFTA00020090

=== Page 2 ===
PANISH
SHEA &
The Honorable Geoffrey S. Berman
BOYLE
United States Attorney for the
LLP
Southern District of New York
c/o
Assistant United States Attorney
June 8, 2020
Page 2
subsequently abused by Epstein for years as a young girl, suffering unimaginable physical and
psychological trauma and distress.
The United States ultimately investigated and brought charges against Jeffrey E. Epstein
for sexual abuse of minors and violations of federal law. We believe the government's
investigation spanned several years and collected copious amounts of information and
documents regarding Jeffrey E. Epstein and his victims, including Doe.
As summarized below, we request the production of documentary and tangible evidence
relating to Doe which was obtained during the government's investigation of Epstein and that is
currently in the government's possession. This evidence is highly relevant to Doe's civil case as
it will likely provide information regarding Epstein's liability and Doe's significant damages.
Specifically, we seek copies of the following documents currently in the possession of the
government:
1.
All photographs of Doe
2.
All flight logs stating Doe's name
3.
All videos of Doe
4.
All correspondences between Epstein and his agents, employees and/or attorneys
and Doe
5.
All records of purchases of airline tickets on behalf of Doe
6.
Jeffrey E. Epstein's Trust Agreement of The 1953 Trust dated August 8, 2019
7.
Jeffrey E. Epstein's Epstein's 1953 Trust
8.
Any and all other documentary materials relating in any way to Doe
Disclosure is Warranted Under 28 C.F.R. § 16.26
Pursuant to the DOJ's Touhy regulations, the Deputy or Associate Attorney General
assesses the following considerations in determining whether disclosure is warranted:
EFTA00020091

=== Page 3 ===
PANISH
SHEA &
The Honorable Geoffrey S. Berman
BOYLE
United States Attorney for the
LLP
Southern District of New York
c/o
Assistant United States Attorney
June 8, 2020
Page 3
(a)(1) Whether such disclosure is appropriate under the rules of procedure governing the
case or mater in which the demand arose;
(a)(2) Whether disclosure is appropriate under the relevant substantive law of privilege.
This request satisfies both of these considerations. As explained previously, the requested
non-privileged documentary evidence directly concerns the allegations in Doe's civil case.
Additionally, DOJ's Touhy regulations prohibit disclosure, subject to certain exceptions,
if any of the following factors exist:
(b)(1) Disclosure would violate a statute, such as the income tax laws, 26 U.S.C.A. 6103
and 7213, or a rule of procedure, such as the grand jury secrecy rule, F.R.Cr.P., Rule 6(e),
(b)(2) Disclosure would violate a specific regulation;
(b)(3) Disclosure would reveal classified information, unless appropriately declassified
by the originating agency,
(b)(4) Disclosure would reveal a confidential source or informant, unless the investigative
agency and the source or informant have no objection,
(b)(5) Disclosure would reveal investigatory records compiled for law enforcement
purposes, and would interfere with enforcement proceedings or disclose investigative techniques
and procedures the effectiveness of which would thereby be impaired,
(b)(6) Disclosure would improperly reveal trade secrets without the owner's consent.
This request does not implicate any of the above considerations. The requested
information is within the scope of ordinary subpoena practice and does not seek disclosure of
information prohibited by statute or regulation, nor information that is classified or that would
reveal the source of an informant.
To the extent any of Doe's requests seek the investigatory records compiled for law
enforcement purposes, Doe does not request investigatory records that would interfere with
ongoing enforcement proceedings.
Expedited Response
EFTA00020092

=== Page 4 ===
PANISH
SHEA &
The Honorable Geoffrey S. Berman
BOYLE
United States Attorney for the
LLP
Southern District of New York
c/o
Assistant United States Attorney
June 8, 2020
Page 4
Doe's civil case is actively being litigated and the parties have already requested and
exchanged initial discovery. Moreover, a victim compensation fund has been recently
established that Doe may elect to participate in. Accordingly, Doe respectfully requests that the
DOJ expedite the production of these requested documents to assist her obtain long-awaited
justice for the atrocities committed against her.
Very truly yours,
PANISH SHEA & BOYLE
R.Olas
Robert S. Glassman
Attorney for Jane Doe
cc:
)
EFTA00020093


c1: EFTA00019907
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019907.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Hi Ok you can check now
Date: Wed, 18 Dec 2019 23:40:11 +0000
From: etravelservices@cwtsatotravel.com <etravelservices@cwtsatotravel.com>
Sent: Wednesday, December 18, 2019 6:38 PM
To:
is
(USANYS)
(USANYS)
is
(USANYS)
Subject: Final Voucher 10893150(1) prepared by a travel arranger is pending your review
Dear
Final voucher 10893150(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 10893150
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13257 - U.S. V. Epstein - Witness Interviews
Destination: Santa Monica, CA, United States
Dates: 2019-12-15 - 2019-12-17
Current status: Pending Voucher Approval
Voucher total expenses: 1360.82
Estimated trip cost: 1907.95
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0012
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00019907


c1: EFTA00019575
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019575.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Jeffrey Pop
To:
)"
Cc: Magaly Jimenez
Subject: RE: SDNY investigation,
Date: Tue, 24 Dec 2019 16:44:18 +0000
Inline-Images: image001.jpg
I received the e-mail. I will run it by an associate for a second opinion. If I then have questions I will circle back.
Otherwise I will let you know about the timing of the attorney proffer regarding the issues you have outlined.
Jeff
Jeffrey S. Pop, Esq.
JEFFREY S. POP & ASSOCIATES
Beverly Hills, California 90212-3429
fax
www.poplawyer.com
www.vaccineinjuryteam.com
JEFFREY S. POP & ASSOCIATES
A LAW CORPORATION
Since 1980
CONFIDENTIALITY
This e-mail is for the personal and exclusive use of the recipient(s) named above. It contains confidential information from Jeffrey S. Pop & Associates. 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.
From:
) [mailto:
Sent: Monday, December 23, 2019 9:34 PM
To: Jeffrey Pop
Cc:
)
Subject: RE: SDNY investigation,
Jeff,
Following up on our phone conversation today, I wanted to memorialize that, as discussed, we do not currently have
reason to believe Ms.
has criminal exposure based on what we are aware of in connection with her interactions
with Jeffrey Epstein, and your brief attorney proffer regarding the circumstances of those interactions are consistent with
that view. In your further discussions with Ms.
in advance of a further attorney proffer to address the general
nature of her relationship with Mr. Epstein, as well as his employees or relevant close associates, if you have any concerns
about additional possible exposure you should please feel free to be in touch with us again. As we also discussed, I
believe any non-federal offenses would be well outside the relevant statute(s) of limitation, but of course if you wish to
further research that issue, or consult with criminal counsel, we defer to you entirely.
EFTA00019575

=== Page 2 ===
Please let us know if any other information would be useful at this stage, and hopefully we can be in touch in the coming
weeks about productive next steps.
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00019576


c1: EFTA00020119
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020119.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: "Martin G. Weinberg"
"Miller, Michael"
"Weingarten, Reid"
Cc:
)"
Subject: RE: U.S. V. Epstein call
Date: Thu, 22 Aug 2019 16:09:19 +0000
Marty,
I got your voicemail from this morning regarding follow-up on civil forfeiture- we have a meeting at 12:30 that I expect
will go approximately 15 minutes and will plan to give you (or Mike, to conference you in) a call after that, so
approximately around 12:45 - 1:00.
Separately, based on the expected nolle order, and in connection with the protective order in this case, in advance of the
hearing on Tuesday can you please either return to the Government all discovery you received in this case and certify that
any copies have been security destroyed or deleted, or, alternatively, simply certify that all discovery received has been
security destroyed or deleted? (As to the second option, that is to say that you do not need to make additional copies of
electronic materials to formally "return" them to us if it is more efficient to simply delete and destroy the existing
electronic copies you have.) We want to be able to advise the Court on Tuesday that there are no outstanding discovery
obligations on either side based in connection with the protective order.
Thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00020119


c1: EFTA00019662
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019662.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(OIG)"
To:
(USANYS)"
Subject: Re: Question from HQ
Date: Sat, 17 Aug 2019 00:21:09 +0000
I will ask. That was all I got
Sent from mobile device, please excuse typos.
Special Agent
Office of the Inspector General
On Aug 16, 2019, at 8:10 PM,
(USANYS)
wrote:
What do you mean by "memorialize phone calls"?
On Aug 16, 2019, at 7:17 PM,
(OIG)
wrote:
and
My HQ has the following question on the underlying case, can you please forward this to the prosecutors on the
underlying case? Thank you.
In addition to BOP policies, did SDNY have requirements to memorialize Epstein's phone calls related to
the underlying case? If so, were they followed?
U.S. Department of Justice
Office of the Inspector General
New York Field Office
EFTA00019662


c1: EFTA00018022
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018022.pdf
c6: pdf
c7: images
c0:
=== 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:
Birth certificate for the following individual:
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
July 28, 2021
/s
AUDREY STRAUSS
United States Attorney for the
UNITED STATES DISTRICT COURT
Southern District of New York
STATE
FOR
THE
Assistant United States Attorney
RICT
YORK
One St. Andrew's Plaza
New York, New York 10007
Email:
Telephone:
Rev. 02.01.12
EFTA00018022


c1: EFTA00017943
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017943.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Cc:
Subject: FW: 20-3061 United States of America V. Maxwell "Summary Order FILED"
Date: Mon, 19 Oct 2020 18:50:52 +0000
Attachments: Maxwell_SO.pdf
Good news - Maxwell's appeal relating to the protective order modification was dismissed on jurisdictional grounds.
Great job by the team and by
at oral argument.
From:
Sent: Monday, October 19, 2020 2:44 PM
To:
is
Cc:
is
Subject: Fwd: 20-3061 United States of America V. Maxwell "Summary Order FILED"
Maxwell's appeal has been dismissed.
Begin forwarded message:
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
Date: October 19, 2020 at 2:35:00 PM EDT
To:
Subject: 20-3061 United States of America V. Maxwell "Summary Order FILED"
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 10/19/2020
Case Name:
United States of America V. Maxwell
Case Number: 20-3061
Document(s): Document(s)
Docket Text:
SUMMARY ORDER AND JUDGMENT, dismissing the appeal, by JAC, RSP, RR, FILED.[2955206] [20-
3061]
EFTA00017943

=== Page 2 ===
Notice will be electronically mailed to:
The following document(s) are associated with this transaction:
Document Description: Summary Order FILED
Original Filename: 20-3061_so.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=10/19/2020] [FileNumber=2955206-0]
[c9287df390bbf83b60e39be41f91c2f0fdc321b401f2206499affb40c712331d20b0ed4d402ef2a304563e9ec9e47
7368fd7dfbee4e7c9fe40f9134601e97d0f]]
Document Description: Bill_of_Cost_Itemized_Notice_1
Original Filename:
/opt/ACECF/live/forms/YenniLiu_203061_2955206_Bill_of_Cost_Itemized_Notice_1_292.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=10/19/2020][FileNumber=2955206-1]
[4edda701c0a976b1a5449cc3707d8496b0a95c561bbec5d14c4f25cdc52d63b9a285c3c9ef4bf7dbc646c562a4b6
878edc16d9039d6719252fd2f737fc6b3da5]]
Recipients:
Document Description: :Bill_of_Cost_Itemized_Notice_2
Original Filename:
/opt/ACECF/live/forms/YenniLiu_203061_2955206_Bill_of_Cost_Itemized_Notice_2_291pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=10/19/2020][FileNumber=2955206-2]
[3a81f26fadf203008714022cc8285c1022e72e400c60e780d312ce3feec69400ced785abfe17d4c197c5c77b6504
bd9244b52ef24c2f0155f059bc5df2ffdbec]]
Recipients:
EFTA00017944

=== Page 3 ===
EFTA00017945


c1: EFTA00019203
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019203.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "McGorty, Glen"
To:
)"
)"
Cc: "Zelenko, Daniel"
"Giffuni, Danielle"
(USANYS)"
Subject: RE: Wednesday's WebEx
Date: Tue, 10 Nov 2020 18:16:21 +0000
just wanted to circle back with you in advance of Thursday's meeting. We want
to be fully prepared, so
if there is any more granularity on this topic (or any additional topic or topics), please let us know.
Thanks,
Glen
Glen G. McGorty Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Monday, October 26, 2020 6:19 PM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
>;
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Thanks very much, Glen. Let's plan for 1pm on Thursday, 11/12. I will circulate a WebEx invitation shortly.
We expect to ask Mr.
about his interactions with
the U.S. Customs and Border Protection
employee who worked in Saint Thomas and who had Mr.
listed as a contact in his phone. I expect we will ask for
an approximate timeline of when Mr.
met and interacted with
the nature of those interactions, and any
interactions
may have had with Epstein (to the best of Mr.
knowledge).
Best,
Assistant United States Attorney
Southern District of New York
EFTA00019203

=== Page 2 ===
From:
Sent: Monday, October 26, 2020 11:58 AM
To:
)
>;
Cc: Zelenko, Daniel
>; Giffuni, Danielle
>;
(USANYS)
Subject: RE: Wednesday's WebEx
Sorry for the delay. Looks like we can do between 11 a.m. and 2 p.m. on Tuesday, 11/10, or any time on Thursday, 11/12.
Let us know if anything in that range will work.
So as to make sure Mr.
is prepared, can you give us an overview of what you expect to cover?
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
)
Sent: Thursday, October 22, 2020 10:33 AM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
>;
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Glen,
As I believe we mentioned when we last spoke, we would like to schedule time for a second interview with Mr.
via
WebEx. Are there any days the week of November 9th when your team and Mr.
would be available? We would
expect this proffer to be much shorter than our first, and certainly no more than two hours at most.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00019204

=== Page 3 ===
From:
Sent: Friday, October 9, 2020 4:42 PM
To:
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
is
Subject: RE: Wednesday's WebEx
Hi Glen,
Thanks very much. I'm attaching the fully executed copy.
Thanks,
From:
Sent: Thursday, October 8, 2020 9:31 AM
To:
Cc: Zelenko, Daniel
>; Giffuni, Danielle
(USANYS)
is
Subject: RE: Wednesday's WebEx
Hi all.
Attached please find the signed proffer agreement. It was nice seeing everyone yesterday.
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com Web Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Monday, October 5, 2020 4:14 PM
To:
Cc: Zelenko, Daniel
>; Giffuni, Danielle
(USANYS)
is
Subject: RE: Wednesday's WebEx
EFTA00019205

=== Page 4 ===
External Email
Hi Glen,
Not a problem at all -- I've added everyone to the calendar invitation. Please let us know if any other tech issues crop up,
and we'd be happy to work through them.
Thanks,
From:
Sent: Monday, October 5, 2020 12:48 PM
To:
is
is
(USANYS)
Cc: Zelenko, Daniel
is
>; Giffuni, Danielle
Morrissey, Josh
Subject: Wednesday's WebEx
Thanks for sending the WebEx invitation for Wednesday's meeting to me. For whatever reason, the system is not
permitting me to forward the invite, so I would ask that you separately invite those copied on this e-mail: Dan, Danielle
and Mr.
but also Josh Morrissey who is in our IT group and will make sure we are good to go for our meeting.
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
EFTA00019206


c1: EFTA00017867
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017867.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Notes from last week
Date: Thu, 09 Sep 2021 23:54:26 +0000
Attachments: 1995-11-07_Oxford_ltr.pdf; Epstein_Blackbook_OCR.pdf
Thanks very much. See attached. As to the second attachment (the blackbook), we only showed her page 19 of the
attached PDF. When you send this 302, please be sure to include whatever attachments you include to the 302. Thanks
again!
From:
Sent: Thursday, September 9, 2021 12:40 PM
To:
Cc:
Subject: Re: Notes from last week
No problem. I'm not in the office today but will be back tomorrow and I can send all of my notes along. Can you please
send me the documents we discussed that we're shown during the
interview that was just me and you present for?
Once I have those I can finalize the 302 and send that to you tomorrow as well once it gets approved.
On Sep 9, 2021, at 11:58,
wrote:
CAUTION! EXTERNAL SENDER
STOP WHEN UNSURE. Never click on links or open attachments if sender is unknown, and never provide
user ID or password. Suspicious? Please report to this email address: reportphishing@nypd.org
Hi
I know you guys are still working on the 302s from out meetings last week, but can you please send us the notes from
the meetings last week?
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:
EFTA00017867


c1: EFTA00019480
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019480.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: The OPR investigation - 8 years too late
Date: Fri, 08 Mar 2019 16:23:59 +0000
Attachments:
Letter_to_OPR_Feb_2019_PDF.pdf
Hey
and
Here is correspondence (with attachments) about the OPR investigating. On December 10, 2010, I asked U.S. Attorney
Ferrer (S.D. Fla.) to investigate the "most suspicious criminal case I have ever encountered." That letter was forwarded to
OPR and, on May 6, 2011, OPR declined to investigate on grounds of ongoing litigation.
Note: We have seen a privilege log from S.D. Fla. that makes it appear that there was some correspondence between OPR
at Main Justice and S.D. Florida in connection with my letter. That correspondence was deemed "privileged" in some way,
so we've never seen it. But you should be able to get it.
Of course, as you know, in about January 2019, OPR did open an investigation into the case prompting my February 7,
2019 letter (attached) requesting that the victims be kept informed. I've received a response and we're going to set up a
conference call soon.
for Jane Doe 1 and Jane Doe 2
CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the
addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this
message in error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the
Utah State Bar, but not the bars of other states. Any views he expresses in this email are his own.
EFTA00019480


c1: EFTA00019327
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019327.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Epstein MCC
Date: Mon, 12 Aug 2019 12:57:34 +0000
- Just tried to reach you. Please let us know if you have a second to chat. We should also both be in by
about 930 if that's easier.
Sent from my iPhone
EFTA00019327


c1: EFTA00019451
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019451.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
Subject: witness travel
Date: Sat, 20 Nov 2021 23:43:00 +0000
Attachments: Fact_Witness_Travel_Request_(trial).docx
Hi
Attached is a travel request form for a witness in the Maxwell case. This is one of the witnesses we've discussed who will
be testifying under a pseudonym. Could you please reach out to him when you can?
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019451


c1: EFTA00019823
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019823.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "postmaster@usdoj.gov" <postmaster@usdoj.gov>
To:
Subject: Notice of Message Failure; Encryption Required
Date: Fri, 16 Aug 2019 20:13:57 +0000
In accordance with the Department Memorandum "Safeguarding Personally Identifiable Information", dated
April 16, 2015, the preceding message has been identified as containing possible sensitive Personally
Identifiable Information (PII) and cannot be delivered unless properly encrypted.
When electronically sending PII to external users outside of Department email systems, the communication
should be encrypted and transmitted to recipients only for a legally authorized purpose. In addition, PII should
not be sent to or from personal email addresses at any time (e.g., Gmail, Hotmail, Comcast, Yahoo).
To compose a secure message open Microsoft Outlook email application and compose the message as normal.
When ready to send - select the "Send Securely" button. Alternately, if you are using another email client (OWA,
iOS, Blackberry etc.) enter the word [encrypt] into the Subject field of the message. Include the square brackets
followed by any other pertinent Subject information, and send the message as you normally would. The
Proofpoint email encryption service will detect and encrypt the message prior to delivery. The external recipient
will be notified via email, how to retrieve the encrypted message.
If you did not intend to send PII within the message, please check the message contents and resend the message
without the PII.
Message Details:
From:
To:
Date : 2019-08-16 20:13:57 GMT
Subject: RE: Subpoenas Re Ghislaine Maxwell
For any questions, please contact your local IT Helpdesk.
EFTA00019823


c1: EFTA00019509
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019509.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
(USANYS)"
Cc:
)"
)"
Subject: Re: Epstein
Date: Mon, 10 Dec 2018 19:03:53 +0000
Attachments: DAS_search.pdf; Event Detail - Parking_Summons.pdf; Event Detail - SOMU.pdf
More Epstein reports
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
From:
Sent: Monday, December 10, 2018 1:54:43 PM
To:
,
(USANYS)
Cc:
);
);
Subject: Re: Epstein
See attached SOMU records.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
From:
(USANYS)
Sent: Monday, December 10, 2018 12:47:40 PM
To:
Cc:
);
);
Subject: Re: Epstein
Can we chat after 2? Otherwise go ahead without me and
will catch me up.
you are going to have to change your
name!
Sent from my iPhone
On Dec 10, 2018, at 12:46 PM,
<mailto:
wrote:
,
We are available now if you would like to call but I am on the road so you will have to conference us in separately.
On Dec 10, 2018, at 12:12,
)
<mailto:
wrote:
and
EFTA00019509

=== Page 2 ===
Any chance you're free for a brief call this afternoon? We wanted to touch base about a few items. I'm sure you're both
very busy in preparation for Wednesday, so we promise to keep it short.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
EFTA00019510


c1: EFTA00019168
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019168.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Press Inquiry Re Jeffrey Epstein
Date: Sat, 12 Jan 2019 22:02:52 +0000
Importance: Normal
All,
Just wanted to let you I know got a call on my personal cell from a writer with The New Yorker
Magazine on the Epstein case. She has interviewed
The reporter asked me to verify that I was an agent and that Jason and myself traveled to Australia and
interviewed
and that she disclosed that she had sex with Epstein and Allan/Allen Dershowitz. I told her I
was an agent and all inquiries about the case would have to through
and
I gave her both your email
addresses. She said she had emailed
previously.
Have a feeling these calls may become more frequent.
, can't get
email to pop up. Don't know if you want to forward so she's in the loop.
Thanks,
EFTA00019168


c1: EFTA00020165
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020165.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
,
(USANYS)"
Subject: RE: Epstein Autopsy
Date: Sun, 11 Aug 2019 19:33:03 +0000
Thanks for sending
From:
(USANYS)
Sent: Sunday, August 11, 2019 15:31
To:
is
is
;
Cc:
(USANYS)
Subject: FW: Epstein Autopsy
FYI
From:
(USANYS)
Sent: Sunday, August 11, 2019 3:30 PM
To: Geoffrey S. .Berman
(
is
(
is
(USANYS)
is
(
Cc:
(USANYS)
i
(USANYS)
i
(USANYS)
Subject: Epstein Autopsy
All,
OCME just completed the autopsy and the findings are consistent with strangulation/hanging. Epstein had a broken hiatal
bone and injuries to the left shoulder that are consistent with hanging. Per OCME, there is no reason to suspect that
Epstein did not hang himself. OCME will wait to finalize the report until after the toxicology reports come back, and
OCME has had an opportunity to review any reports of interviews of the first guards on the scene who discovered Epstein.
We will continue to keep you posted. Please let us know if you have any questions. Thanks.
EFTA00020165


c1: EFTA00018398
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018398.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: CNN; Attorney General Bill Barr will not recuse himself from Jeffrey Epstein child sex
prosecution
Date: Tue, 09 Jul 2019 15:55:02 +0000
Importance: High
https://www.cnbc.com/2019/07/09/bill-barr-will-not-recuse-himself-in-jeffrey-epstein-prosecution.html
Attorney General Bill Barr
will not recuse himself from
Jeffrey Epstein child sex
prosecution
PUBLISHED 10 MIN AGO
Attorney General William Barr will not recuse himself from involvement in the new federal criminal
prosecution of accused child sex trafficker Jeffrey Epstein, an official said Tuesday.
But Barr will recuse himself from an internal Justice Department probe of current Labor Secretary's
Alex Acosta involvement in approving a controversial no-prosecution deal with the wealthy
financier a decade ago, an official said.
Barr's decision to have oversight over the Epstein prosecution came on the heels of reports that he
had recused himself from the case, which is being prosecuted by the U.S. Attorney's Office for the
Southern District of New York.
And it came as a bevy of Democratic members of Congress and presidential candidates demanded
that Acosta resign because of his role as then-U.S. Attorney in Miami in signing off on a deal to not
prosecute Epstein in the mid-2000s.
Epstein, 66, is accused of sexually abusing dozens of underage girls from 2002 to 2005 after they
were brought to his luxurious residences on the Upper East Side of Manhattan, and in Palm Beach,
Fla.
EFTA00018398

=== Page 2 ===
Epstein was being eyed for the same alleged conduct in Florida that federal prosecutors have now
charged him with in Manhattan.
A Justice Department official on Tuesday said that Barr consulted with career ethics officials at the
department, and concluded he did not have to recuse himself from the current prosecution in
Manhattan.
However, Barr was quoted Monday as saying he was recusing himself from the Epstein case.
"I'm recused from that matter because one of the law firms that represented Epstein long ago was a
firm I subsequently joined for a period of time," Barr told reporters on Monday.
Barr joined that law firm, Kirkland & Ellis, in 2009.
Kirkland & Ellis had represented Epstein in 2008, when he was being investigated in Florida.
Barr's comment Monday seems to have referred - or does so now - to his continued recusal from
the Justice Department's internal probe into the non-prosecution of Epstein as signed off by Acosta.
"Due to his prior association with Kirkland and Ellis, the Attorney General has and will remain
recused from any retrospective review of the resolution of the earlier [Southern District of Florida]
matter," the Justice Department official told CNBC on Tuesday.
Public Affairs
United States Department of Justice
U.S. Attorney's Office Southern District of New York
EFTA00018399


c1: EFTA00018101
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018101.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: NOTES - 2020.01.17 Call with
Date: Fri, 17 Jan 2020 16:01:39 +0000
NOTES - 2020.01.17 Call with
-
IG Empowerment Act of 2016
Gives DOJ-IG access to all GJ materials
sent it to us (with highlights); we will pass along to
and discuss
-
Looking into whether there was a policy violation or administrative failure in not providing Epstein with a
cellmate
-
Discussion of
and other witnesses' statements re Epstein having a cell mate
-
does not yet have handwritten notes
-
Timing
IG wants report done ASAP
will express to IG our desire that anything they write comes out after the trial; our Office can also
make a formal request to IG about timing, if necessary
-
Witness names
In Oversight Review Division, long reports with all names
In Investigations Division (where
is helping out on this report), different approach; using titles, not
names
Does not believe that he will be citing any inmate testimony
In any public version, do not believe that most MCC employees will be named, but we should confirm
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00018101


c1: EFTA00019320
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019320.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: sec
Date: Fri, 16 Aug 2019 21:13:23 +0000
I connected with
Original Message
From: Cowley,
(USANYS)
Sent: Friday, August 16, 2019 9:26 AM
To:
(USANYS)
Cc:
(USANYS)
(USANYS) 6
Subject: Re: sec
Dude, I started my email by apologizing for the ping!
The SEC's failure to register as an IA case most continue!
Thx
Sent from my iPhone
> On Aug 16, 2019, at 9:23 AM,
(USANYS)
wrote:
>
> This fell down the priority list after, you know, he strangled himself the morning after our call. But
may
have spoken to the team about it? If not we'll try to today.
>
> Sent from my iPhone
V
On Aug 16, 2019, at 9:19 AM, Cowley,
(USANYS)
wrote:
Guys,
>> Sorry for the ping on this, but Sec called me about Epstein stuff. I think where we left off is you were going
to confirm that you hadn't seen anything in the records consistent with him investing other people's money.
>>
Sent from my iPhone
EFTA00019320


c1: EFTA00019487
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019487.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Subject: Tentative: Call with PAE re Epstein
Date: Thu, 25 Mar 2021 20:09:35 +0000
Importance: Normal
Attachments: unnamed
EFTA00019487


c1: EFTA00018560
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018560.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc:
Christian Everdell
,
Subject: Re: [EXTERNAL] Ghislaine Maxwell 02879-506
Date: Thu, 21 Oct 2021 12:41:20 +0000
Thank you.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
On Oct 21, 2021, at 8:27 AM,
wrote:
Good morning Bobbi,
The staff was made aware yesterday afternoon, and we are all set.
Best,
BOBBI C STERNHEIM
10/20/2021 3:18 PM
Good afternoon-
A telephonic court conference will be held tomorrow at noon.
Please confirm that arrangements are in place for Ms. Maxwell's
participation.
Please contact me with any questions.
Thank you-
Bobbi
Please note my new office address and preferred email address:
EFTA00018560

=== Page 2 ===
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
This message and any attached documents contain information from the
Law Offices of Bobbi C. Sternheim that may be confidential and/or
privileged.
If you are not the intended recipient, you may not read, copy,
distribute, or use this information.
If you have received this transmission in error, please notify the
sender immediately by reply e-mail and then delete this message. Thank
you.
EFTA00018561


c1: EFTA00019824
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019824.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
,
)"
Subject: notes
Date: Thu, 14 Nov 2019 19:42:57 +0000
Attachments: 2019.11.12
Interview_Prep.docx
In case this is helpful, here are my scattered notes in prep for today.
EFTA00019824


c1: EFTA00019456
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019456.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: "Stoddart, Allison"
@wilmerhale.com>
Subject: Tentative: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Date: Sat, 20 Nov 2021 22:06:38 +0000
Importance: Normal
Attachments: unnamed
EFTA00019456


c1: EFTA00019790
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019790.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
MCC NEW YORK
Friday August 09, 2019
NEW YORK, NY
Page 1
Daily Assignment Roster
6 07:00 15:00
9 12:00- 20:00
Split Shift 2 00:00 - 08:00
3 06:00- 14:00
8 08:00 16:00
10 14:00- 22:00
12 16:00 - 00:00
Post
CAPTAIN
CAPTAIN SEC
OPS LT
ACT LT
SHU LT
SIS LT
SIS LT #2
SIA
SIS TECH #1
PHONE MONITOR
SEC OFFICER #1
SEC OFFICER #2
TOOL ROOM
SEARCH OFFICER
2 SALLY OFF
3 SALLY OFF
LOBBY
CONTROL #1
CONTROL #2
INTERNAL
INTERNAL #2
ATTY CONF
UNIT 2
UNIT 3
5 NORTH
5 SOUTH
7 NORTH
7 SOUTH
9 NORTH
SHU #1
12 Noel, T
SHU #2
**2 Thomas, M
oT (NC)
SHU #3
SHU #4
10 SOUTH #1
10 SOUTH #2
REC OFFICER #1
3/10/2019 7:18:56 PM
EFTA00019790

=== Page 2 ===
Friday August 09, 2019
Page 2
REC OFFICER #2
**3 <unassigned>
11 NORTH
11 SOUTH
11 SOUTH #2
REAR GATE
OSP #1
SANITATION OFF
VISIT #1
VISIT #2
VISIT #3
****Special Assignm
PHONE RM
PHONE RM 2
EPO OFFICE
LOBBY #2
ESCORT OFF #1
ESCORT OFF #2
TNWDVR
ESCORT OFF #3
TREATY LT
TREATY 1
TREATY 2
DRY CELL
****Back Page Categories****
DAY OFF
SICK LEAVE
ANNUAL LEAVE
LWOP(M)
3/10/2019 7:18:59 PM
EFTA00019791

=== Page 3 ===
Friday August 09, 2019
Page 3
AWOL
SUSPENSION
OFFICIAL TIME
COP
IF TRAINING
****Change Records****
Relieved Officer's
Relieving Officer's
Ret
Post
Splt Shft Officer
New Status
Relieving Officer
Previous Status
Shft
Changed By
3
8 PHONE RM 2(sp)
KS 7/28 13:49
LOBBY
8 PHONE RM 3(sp)
KS 7/28 13:49
(sp)PHONE RM 2
8
SHU #1
COP
KS 8/4 09:39
2
Day Off
[Sick / Annual]
KS 8/4 11:56
[Sick / Annual]
[Removed]
KS 8/4 12:00
MILITARY LEAVE
12 SHU #1
KS 8/4 12:51
SHU #1
12
Sick Leave
KS 8/4 12:52
11 SOUTH
8
COP
KS 8/4 12:54
[Inserted NCS]
[Sick/Annual]
RW 8/5 08:33
Thomas, M
SHU #2
[Sick / Annual]
RW 8/5 08:34
2
INTERNAL
8
2 UNIT 3
Y
RW 8/5 08:42
Staff
OT/CT Start End
OT
2
12 OSP #1
Y
RW 8/5 08:58
7 SOUTH
Staff
OT/CT Start End
OT
[Inserted NCS]
[Sick/Annual]
RW 8/5 09:09
INTERNAL #2
2
[Sick / Annual]
RW 8/5 09:09
2
8 SHU #1
Y
RW 8/5 09:40
11 SOUTH
Staff
OT/CT Start End
oT
[Inserted NCS]
[Sick/Annual]
RW 8/5 09:53
SHU #1
2
[Sick / Annual]
RW 8/5 09:53
[Inserted NCS]
[Sick/Annual]
RW 8/5 09:53
SHU #4
12
[Sick / Annual]
RW 8/5 09:53
SHU #4
[Time Change]
RW 8/5 09:54
12
Staff
OT/CT Start End
CT
3/10/2019 7:19:00 PM
EFTA00019792

=== Page 4 ===
Friday August 09, 2019
Page 4
Relieved Officer's
Relieving Officer's Ret
Post
Splt Shft Officer
New Status
Relieving Officer Previous Status
Shft Changed By
RW 8/5 09:59
10 SOUTH #1
2
QT/CT Start End
OT
/ RW 8/5 10:22
7 SOUTH
12
OT/CT Start End
OT
/ RW 8/5 11:02
(sp)ESCORT OFF #2
8
OT/CT Start End
OT
Y JD 8/6 06:48
10 SOUTH #1
8
OT/CT Start End
OT
[Sick / Annual]
[Removed]
JD 8/6 06:48
(sp)ESCORT OFF #2
8
[Sick / Annual]
JD 8/6 06:48
JD 8/6 06:50
(sp)ESCORT OFF #2
8
JD 8/6 07:07
3 SALLY OFF
8
RW 8/6 10:07
CONTROL #2
3
RW 8/6 11:40
SHU #3
3
ACT LT
Sick Leave
KS 8/6 14:12
3
[Sick/Annual]
KS 8/6 14:29
[Inserted]
[Sick/Annual]
KS 8/6 14:29
[Inserted]
[Inserted]
[Sick/Annual]
KS 8/6 14:29
[Sick/Annual]
KS 8/6 14:29
[Inserted]
[Sick / Annual]
IF TRAINING
KS 8/6 14:32
IF TRAINING
KS 8/6 14:32
[Sick / Annual]
IF TRAINING
KS 8/6 14:32
[Sick / Annual]
[Sick / Annual]
IF TRAINING
KS 8/6 14:33
[Inserted NCS]
[Sick/Annual]
SJ 8/6 20:12
SJ 8/6 20:12
7 SOUTH
8
SANITATION OFF
Annual Leave
RW 8/7 07:52
2
[Sick / Annual]
RW 8/7 08:27
7 SOUTH
2
[Sick / Annual]
[Removed]
RW 8/7 08:27
RW 8/7 08:27
7 SOUTH
2
Y
RW 8/7 08:27
7 NORTH
2
OT/CT Start End
oT
Y
RW 8/7 10:06
9 NORTH
8
OT/CT Start End
oT
Y
RW 8/7 10:24
LOBBY
1
OT/CT Start End
OT
1/10/2019 7:19:01 PM
EFTA00019793

=== Page 5 ===
Friday August 09, 2019
Page 5
Relieved Officer's
Relieving Officer's Ret
Post
Spit Shft Officer
New Status
Relieving Officer Previous Status Shft Changed By
Y RW 8/7 10:27
VISIT #2
9
OT/CT Start End
oT
14:00 20:00
CAPTAIN SEC
[Time Change]
RW
8/7 10:28
6
OT/CT Start End
06:00 14:00
Y
RW
8/7 10:29
(sp)TNWDVR
10
OT/CT Start End
oT
14:00
06:00
RW 8/7 10:29
(sp)EPO OFFICE
3
Y RW 8/7 11:37
11 NORTH
12
OT/CT Start End
OT
Y
JD 8/7 13:36
ACT LT
3
OT/CT Start End
OT
Y
RW 8/8 07:12
SHU #1
12
OT/CT Start End
OT
JD 8/8 08:56
11 SOUTH
8
[Sick/Annual]
JD 8/8 08:56
[Inserted NCS]
JD 8/8 08:56
UNIT 2
8
CONTROL #1
2
Sick Leave
RW 8/8 12:33
Y
RW 8/8 12:37
CONTROL #1
2
OT/CT Start End
OT
[Removed]
JD 8/8 13:36
[Sick / Annual]
SHU #4
1
[Sick / Annual]
JD 8/8 13:36
[Inserted NCS]
[Sick/Annual]
JD 8/8 13:41
JD 8/8 13:41
SHU #4
1
[Sick/Annual]
DM 8/8 15:34
[Inserted NCS]
DM 8/8 15:34
5 SOUTH
2
MC 8/8 15:50
5 SOUTH
8
Y
DM 8/8 15:54
7 SOUTH
2
OT/CT Start End
OT
Y
DM 8/8 17:59
SHU #2
8
OT/CT Start End
OT
[Removed]
MC 8/8 18:06
[Sick / Annual]
INTERNAL #2
[Sick / Annual]
MC 8/8 18:06
2
2 SALLY OFF
Sick Leave
MC 8/8 18:23
8
3/10/2019 7:19:01 PM
EFTA00019794

=== Page 6 ===
Friday August 09, 2019
Page 6
Relieved Officer's
Relieving Officer's Ret
Post
Splt Shft Officer
New Status
Relieving Officer Previous Status
Shft Changed By
DM 8/8 19:02
SHU #1
2
[Sick / Annual]
DM 8/8 19:02
[Sick / Annual]
[Removed]
DM 8/8 19:02
[Inserted NCS]
[Sick/Annual]
DM 8/8 19:02
INTERNAL #2
2
Y DM 8/8 19:04
SHU #1
2
OT/CT Start End
OT
CP 8/9 06:53
SHU #2
8
[Sick / Annual]
CP 8/9 06:53
[Sick / Annual]
[Removed]
CP 8/9 06:54
SHU #2
8
Y CP 8/9 06:55
11 NORTH
8
OT/CT Start End
OT
CP 8/9 06:55
SHU #4
8
SHU #4
8
[Time Change]
CP 8/9 06:55
QT/CT Start End
06:00 14:00
CP 8/9 07:15
5 NORTH
8
Sick Leave
(sp)ESCORT OFF #1
[Time Change]
JD 8/9 07:15
8
OT/CT Start End
06:30 14:30
8
[Time Change]
JD 8/9 07:15
(sp)ESCORT OFF #2
OT/CT Start End
06:30 14:30
JD 8/9 07:16
(sp)ESCORT OFF #3
8
JD 8/9 07:16
CONTROL #2
3
[Sick/Annual]
CP 8/9 07:46
[Inserted NCS]
CP 8/9 07:46
5 NORTH
8
SHU LT
3
Sick Leave
CP 8/9 07:50
(sp)TNWDVR
1
[Sick / Annual]
RW 8/9 08:03
RW 8/9 08:03
[Sick / Annual]
[Removed]
Y
RW 8/9 08:03
(sp)TNWDVR
1
OT/CT Start End
OT 14:00
SIS LT
6
Annual Leave
JD 8/9 08:53
Sick Leave
CP 8/9 08:58
OPS LT
1
CP 8/9 08:58
OPS LT
1
Y
CP 8/9 08:59
ACT LT
1
OT/CT Start End
oT
7 NORTH
1
Sick Leave
RW 8/9 09:05
[Sick/Annual]
RW 8/9 09:08
[Inserted NCS]
CP 8/9 09:09
ACT LT
1
[Time Change]
OT/CT Start End
OT 16:00 22:00
3/10/2019 7:19:01 PM
EFTA00019795

=== Page 7 ===
Friday August 09, 2019
Page 7
Relieved Officer's
Relieving Officer's Ret
Post
Splt Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
RW 8/9 09:09
7 NORTH
12
Y RW 8/9 09:47
(sp)TREATY LT
10
OT/CT Start End
OT
15:00
07:00 15:00
Y RW 8/9 09:47
(sp)TREATY 1
10
OT/CT Start End
OT
RW 8/9 09:48
(sp)TREATY 1
10
[Time Change]
OT/CT Start End
oT
16:00
RW 8/9 09:57
[Inserted NCS]
[Sick/Annual]
RW 8/9 09:57
(sp)TREATY 2
10
CP 8/9 10:59
SHU #1
12
[Sick / Annual]
CP 8/9 10:59
[Sick / Annual]
[Removed]
CP 8/9 11:12
[Inserted NCS]
[Sick/Annual]
CP 8/9 11:13
SHU #1
12
CP 8/9 11:32
[Inserted NCS]
[Sick/Annual]
CP 8/9 11:32
11 SOUTH
12
Sick Leave
CP 8/9 13:40
SHU #4
12
[Sick / Annual]
CP 8/9 13:40
[Sick / Annual]
[Removed]
Y
MC 8/9 14:41
(sp)DRY CELL
12
OT/CT Start End
oT 16:00 00:00
RW 8/9 22:45
(sp)TREATY LT
10
[Time Change]
OT/CT Start End
oT 15:00 22:30
RW 8/9 22:45
(sp)TREATY 1
10
[Time Change]
OT/CT Start End
OT 16:00 22:30
RW 8/9 22:45
(sp)TREATY 2
10
[Time Change]
OT/CT Start End
OT 07:30 22:30
****Recapitulation****
Morning Watch
8
AM Watch 4
Day Watch
21
PM Watch 6
Evening Watch 14
**Back Page Categories**
Day Off 23
Sick Leave 9
Annual Leave
8
LWOP(M) 2
AWOL 11
SUSPENSION 1
OFFICIAL TIME 1
COP
4
IF TRAINING 4
Total Correctional Svcs. Staff: 116
3/10/2019 7:19:01 PM
EFTA00019796

=== Page 8 ===
Friday August 09, 2019
Page 8
Non Correctional Svcs. Staff: 8
Overtime Occurrences: 28
Comptime Occurrences: 0
Ops Lt. Evening Watch Signature:
Captain's Signature:
3/10/2019 7:19:02 PM
EFTA00019797


c1: EFTA00018088
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018088.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: Epstein victim requests
Date: Tue, 03 Nov 2020 19:50:21 +0000
Sure-just gave you a call. I'm at
and should be around this afternoon. Thanks!
> On Nov 3, 2020, at 2:25 PM,
wrote:
> Hi
> Thanks!
V V V V V V V
Do you have time this afternoon for a brief call? I'm
if you have a moment.
> Sent from my iPhone
EFTA00018088


c1: EFTA00018438
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018438.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein Passport
Date: Wed, 31 Jul 2019 20:25:28 +0000
Understood and thanks
Official
UNCLASSIFIED
From:
Sent: Wednesday, July 31, 2019 3:57 PM
Subject: RE: Epstein Passport
The decision and order denying Mr. Epstein's application, which was publicly filed on the case docket, is attached. Just to
be clear, we take absolutely no position on any State Department or other extra-judicial processes relating to Mr. Epstein
-I'm sending this publicly-filed document just as a courtesy. I don't know if individuals have any due process or any other
rights in connection with their passports (and have never previously had a defendant who had his or her passport revoked
upon arrest and/or detention), and so do not have any view or position on the determinations of any other department or
agency. All that said, the order is attached, which I hope that is useful.
thank you,
From:
Sent: Wednesday, July 31, 2019 15:50
Subject: RE: Epstein Passport
Would you be able to send me a copy of the detention order? Consular Affairs will use the order to revoke his passport.
Even though he is incarcerated, the State Department would like to revoke his U.S. passport.
Thanks.
EFTA00018438

=== Page 2 ===
Assistant Special Agent in Charge
New York Field Office
U.S. Department of State
Diplomatic Security Service
Official
UNCLASSIFIED
From:
Sent: Wednesday, July 10, 2019 10:13 PM
Subject: RE: Epstein Passport
Happy to be in touch - let us know what info we can provide or how we can be of help.
thanks,
From:
Sent: Wednesday, July 10, 2019 22:12
To:
Subject: Epstein Passport
Cc'ed to this email is the prosecution team for the Epstein case.
Team,
Please meet
an ASAC at the DSS NY Field Office (and my former boss).
State Department's Consular Affairs Bureau is looking for some information regarding Epstein's passport, as they
considering revoking it. Can you guys please coordinate with
regarding this issue.
Thanks!
Special Agent
U.S. Attorney's Office
Southern District of New York
EFTA00018439

=== Page 3 ===
EFTA00018440


c1: EFTA00019889
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019889.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: Undisclosed recipients:;
Bcc:
Subject: Fwd: The Jeffrey Epstein & Jes Staley Blackmail Ring
Date: Mon, 24 Feb 2020 00:50:44 +0000
Attachments: FBI_Jes_Staley.pdf
From: "TheAbstraction ."
To: "mel stride mp"
Cc: "theo clarke mp"
,
parliament.uk, clerks@oeclaw.co.uk
Sent: Sunday, 23 February, 2020 07:58:29
Subject: Re: The Jeffrey Epstein & Jes Staley Blackmail Ring
Kalamata
Billington Lane
Derrington
Stafford
ST18 9LR
23 Feb 2020
Email:
To:
Mel Stride - Chairman of the UK Treasury Select Committee
Copies To:
Federal Bureau of Intelligence
Dame Elizabeth Gloster
The Press
EFTA00019889

=== Page 2 ===
Bailey and the TSC Suppressing Key Information to the FBI, PRA, and FCA Regarding the Jes
Staley JP Morgan Emails
Dear Mr Stride,
I believe you should have an email from me sent to yourself in particular, and copied to members of
the Treasury Select Committee on the 22nd of December 2019. I received a reply a month later from
Maciej Wenerski who handled it as a FOIA, with the obligatory one month grace before hitting the
send button.
I shall not repeat myself too much here, but the issue is raised in the public domain now, with the FBI,
FCA and the PRA all investigating Jes Staley's conduct while working at JP Morgan, which ostensibly
should disqualify him from holding a sernior position in a bank - he was never fit to be CEO of
Barclays.
Clearly according the FOIA responses I received from the TSC, the blackmail emails from Epstein
should have been enough to have had Staley dismissed in 2015, and would give substantial context to
the emails held by JP Morgan. The TSC has had the Epstein emails now for almost five years - and
no MP and no civil servant did the honourable thing and demand the FCA investigate.
Mr Stride, do you take personal responsibility for the TSC witholding key legal evidence to ongoing
inquiries? Which civil servants in the TSC are involved with the cover-up? Are they expecting a role in
Barclays after the dust has settled?
Andrew Bailey of the FCA and Lisa Osofsky of the SFO both explicity refused to investigate Staley
after I supplied them with FOIA responses. Did the TSC order the FCA and the SFO to stand down? It
is only the US press that has forced the British establishment's hand. Had Staley's role in JP Morgan
not been reported there would be no investigation.
I believe the general public would be correct to infer that Epstein not only blackmailed Parliament to
put Staley into position, but blackmailed it into accepting Bailey and Osofsky. Both would need to be
corrupted in order for Staley to keep his job. Why is Bailey being considered for top job at the Bank of
England when the FCA that he runs has a 98% disapproval rating from the general public.
Bailey and the FCA are answerable to the Treasury which is answerable to Parliament.
It is noted that Andrew Bailey and Mark Carney are being investigated for the LC&F scandal.
EFTA00019890

=== Page 3 ===
To remind you, my friend
may well have been murdered for exposing the Epstein and
Staley story back in 2017. The timing of her death and the contents of her exposé were given as
evidence to Judge Worster of the Birmingham Court. The Court now refuses to accept my emails and
he stonewalls me. Worster served two restraining orders against me. The effect of these orders is
patent - they blocked the truth about Staley being publicly validated in a legal document and signed
off by a High Court judge. They also allowed Deutsche Bank to get away with never having to file
incriminating evidenec against themselves.
Did Worster take a bribe or was he ordered by the TSC to gag me? I presume if Staley was going to
bribe a judge to cover up his role in the Epstein paedophile circle, he would have to make sure the
Lord Chief Justice lan Burnett was in the loop. Lord Etherton seems to have implied Burnett was
himself a paedphile. You may have heard about this. I wonder if Burnett was Epstein's pick? Certainly
someone who works with both Lord Adrian PIE Fulford and Paul Kernaghan has to be highly suspect. I
guess the truth must be in your email system somewhere.
Did you bother asking the FCA to investigate Roger Jenkins, who also appears to have also gone to
Epstein's child-rape parties?
Yours sincerely
Mark Anthony Taylor
On Sun, 22 Dec 2019 at 14:07, TheAbstraction
wrote:
To the TSC and my constituency MP Theo Clarke
Please find attached a letter to the TSC regarding Epstein's blackmail of Parliament and the
Judiciary.
Regards
Mark Anthony Taylor
Mark Anthony Taylor
EFTA00019891


c1: EFTA00020351
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020351.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
:
,
Cc:
,
)"
)"
'Arraignment NYSD' <Arraignment@nysd.uscourts.gov>,
Subject: unsealing and wheel-out request -- United States V. Ghislaine Maxwell, 20 Cr. 330
Date: Thu, 02 Jul 2020 13:06:17 +0000
Attachments: 020-07-02,_GM,_government_unsealing_request_and_proposed_order.docx;2020-07-
02,_GM,_government_unsealing_request_and_proposed_order.pdf
To the Chambers of Judge Parker:
The Government respectfully submits the attached application and proposed order for unsealing and assignment of
United States V. Ghislaine Maxwell, 20 Cr. 330, attached in Word and PDF formats. We would be very grateful to have the
case unsealed as soon as practicable.
In connection with this case, we also write to advise the Court that we expect the defendant will be presented today in
the District of New Hampshire.
Should there be any questions or issues, I am available anytime via phone at
Respectfully,
Assistant U.S. Attorney
Southern District of New York
EFTA00020351


c1: EFTA00019858
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019858.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
) [Contractor]"
Cc:
)"
)"
Subject: RE: quick disc burn for agents
Date: Tue, 06 Aug 2019 14:50:22 +0000
Password, I mean, not address.
I need to get some sleep (after my trial).
From:
Sent: Tuesday, August 06, 2019 10:48
To:
(USANYS) [Contractor]
-
[Contractor]
Cc:
is
Subject: RE: quick disc burn for agents
That's correct, thanks - l'll let them know it's there and tell them the address
From:
(USANYS) [Contractor]
Sent: Tuesday, August 06, 2019 10:25
To:
)
)
[Contractor]
Cc:
is
Subject: RE: quick disc burn for agents
Okay! About to put it downstairs. It is just one envelope addressed to both of them - is that correct?
Also the password is USAO_sdny2018!
From:
)
Sent: Monday, August 5, 2019 11:50 PM
To:
) [Contractor]
(USANYS) [Contractor]
Cc:
is
)
Subject: quick disc burn for agents
Hey, tomorrow (Tuesday) morning could one of you please burn a disc for the agents on Epstein with the materials in the
Fourth Production and Fifth Production folders here:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNYinvestigation\Subpoena
Returns\Deutsche Bank
And put it in an envelope downstairs for:
FBI Special Agent
Detective
EFTA00019858

=== Page 2 ===
and let us know when it's all set and we'll tell them they can pick up? Thank you!
Assistant U.S. Attorney
Southern District of New York
EFTA00019859


c1: EFTA00019900
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019900.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To: Aida Leisenring
Cc:
)"
Bruce Barket
"BRUCE KOFFSKY'
(
)"
Subject: Re: Preservation request
Date: Tue, 17 Dec 2019 21:58:29 +0000
We'll follow up again.
Co-Chief, Narcotics Unit
On Dec 17, 2019, at 16:41, Aida Leisenring
wrote:
Dear
and
I am surprised that the video was not retained, as I specifically requested its preservation, and
had
confirmed with me that he had made the preservation request. See below. Thank you.
Aida Ferrer Leisenring, Esq.
Barket, Epstein, Kearon, Aldea & LoTurco LLP
Garden City, NY 11530
T
F
Please note that my emailed has changed to:
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: Aida Leisenring
Sent: Tuesday, December 17, 2019 4:30 PM
To: Bruce Barket
Subject: FW: Preservation request
Aida Ferrer Leisenring, Esq.
Barket, Epstein, Kearon, Aldea & LoTurco LLP
EFTA00019900

=== Page 2 ===
Please note that my emailed has changed to:
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
Sent: Thursday, July 25, 2019 1:59 PM
To: Tony Ricco
); Aida Leisenring; Bruce Barket; Stephanie Scannell; 'BRUCE KOFFSKY'
Subject: Re: Preservation request
Hello Aida,
It was great seeing you as well.
I have asked the appropriate staff to preserve the requested video footage. Please be advised MCC staff do not have
body cameras.
Thank you,
>>> Aida Leisenring
7/25/2019 11:54 AM >>>
Hello
It was good to see you yesterday. Thank you for accommodating my visit with Tartaglione and giving him extra time to
review his discovery. We very much appreciate that.
I am writing to request the preservation of all video surveillance that captures the hallway outside of Tartaglione's cell
on the date and time of the Epstein incident that is currently being investigated. I believe that the date and time is July
23 during the early morning hours. Accordingly, I would ask that all video surveillance from July 22 at 11 pm to July 23
at 4 am is preserved. If it is your understanding that the incident occurred at a different time, please let me know and
preserve the relevant footage, including an hour before the incident and an hour afterwards. If the responding officers
were wearing body cameras that captured the inside of the cell in the aftermath of the incident, I am requesting that
such footage also be preserved.
We will be officially requesting this material through the appropriate means, but please consider this email a formal
preservation request.
Thank you.
Aida Ferrer Leisenring, Esq.
Barket, Epstein, Kearon, Aldea & LoTurco LLP
EFTA00019901

=== Page 3 ===
Please note that my emailed has changed to:
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.
EFTA00019902


c1: EFTA00017995
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017995.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Haddon, Morgan and Foreman, P.C
Laura A. Menninger
HADDON
Denver, Colorado 80203
MORGAN
FOREMAN
www.hmflaw.com
March 8, 2021
VIA EMAIL
United States Attorney's Office
Southern District of New York
New York, NY 10007
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Discovery request pertaining to FOIA productions
Dear Counsel:
I write to request certain discovery pursuant to Fed. R. Cr. P. 16.
Under Rule 16(a)(1)(E), I ask that you provide to us the documents produced by the FBI to
news media, as described in Radar Online V. FBI, 17 Civ. 3956 (PGG). The FBI in New York
released to Radar Online some 1,232 pages "relating to the FBI's investigation and
prosecution of Jeffrey Edward Epstein." Id. at Dkt. 25, p. 1. According to a letter signed by
your office, 181 pages were released in full and 1,051 were released with partial redactions.
Id. at 2. Your office made these representations and therefore presumably is aware of the
documents' existence and constructively aware that their contents relate to the FBI
investigation and prosecution of Jeffrey Edward Epstein and relate to the investigation and
prosecution of Ghislaine Maxwell. We perceive no legal basis for you to refuse to produce
the records; the records have previously been released to a news media outlet, "relate to" the
investigation and prosecution of Ms. Maxwell's alleged co-conspirator, and are in the
government's "possession, custody, or control."
We also request that your office detail when each batch of documents, by Bates number or
some other identifier, were released to Radar Online. The public availability of, for example,
witness statements and other investigative materials is relevant to this case because we believe
there have been efforts by certain witnesses to conform their testimony to the public
statements and police reports made by other witnesses. It is relevant and material to Ms.
Maxwell's defense to know when the FBI made any such witness statements (even if
redacted) or other materials available to a tabloid news organization.
EFTA00017995

=== Page 2 ===
March 8, 2021
Page 2
Further, we request that you make inquiry of your "Prosecution Team," to include the USAO-
SDNY, FBI-New York Office, and FBI Florida Office, regarding any other FOIA requests
that have produced documents pertaining to any investigation of Jeffrey Epstein or Ghislaine
Maxwell and produce to us the documents made public through the FOIA requests, the dates
the documents were produced and the identity of the recipient of the documents.
Finally, in your letter to Judge Nathan of October 7, 2020, you represented that your
"Prosecution Team had no involvement in the Florida Investigation." (Dkt. 63 at 4.) You
defined your "Prosecution Team" to include not only of the USAO-SDNY but also the FBI-
New York Office. We believe that the FBI-New York Office participated in the USAO-SDFL
investigation by, inter alia, arranging for interviews and testimony of certain New York
witnesses between 2005 and 2010. We urge you to look again at your files to ascertain
whether your statement to Judge Nathan was accurate and to produce any materials that reflect
the involvement of the FBI-New York Office in the USAO-SDFL investigation.
Given that we are rapidly approaching trial, I ask that you please provide these materials by
the end of the week, March 15, 2021.
Respectfully submitted,
Jan Laura A. Menninger a. ing
CC: Counsel of Record via Email
EFTA00017996


c1: EFTA00018836
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018836.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: PCU Monthly Update
Date: Fri, 05 Mar 2021 17:40:21 +0000
Attachments:PC_Unit__Short_Form_Update.3.5.21.rd.docx
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
Desk
Cell
EFTA00018836


c1: EFTA00019489
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019489.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
)"
(USANYS)"
Subject: RE: US V. Epstein
Date: Thu, 25 Mar 2021 19:29:11 +0000
Great, dial-in below:
Dial-in:
Code:
From:
(USANYS) [Contractor]
Sent: Thursday, March 25, 2021 3:28 PM
To:
)
is
)
is
(USANYS)
Subject: RE: US V. Epstein
I am sorry I meant 4:30 today.
From:
Sent: Thursday, March 25, 2021 3:27 PM
To:
(USANYS) [Contractor]
is
)
is
(USANYS)
Subject: RE: US V. Epstein
I meant today at 4:30. Does that work?
From:
(USANYS) [Contractor]
Sent: Thursday, March 25, 2021 3:25 PM
To:
is
>;
(USANYS)
Subject: RE: US V. Epstein
We can be available tomorrow at 4:30. Please let me know if you would like for me and the vendor to call you or do you
want circulate a conference call for 4:30?
From:
Sent: Thursday, March 25, 2021 3:22 PM
To:
(USANYS) [Contractor]
in
)
is
(USANYS)
Subject: RE: US V. Epstein
Hi
Would a call at 4:30pm work?
Thanks,
EFTA00019489

=== Page 2 ===
From:
(USANYS) [Contractor]
Sent: Thursday, March 25, 2021 2:19 PM
To:
is
is
(USANYS)
Subject: US V. Epstein
Hello
Me and the vendor (PAE) need to talk to you about the scanning data to be loaded to Relativity. Please let me know when
you have time to talk today.
Thank you.
EFTA00019490


c1: EFTA00019458
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019458.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Protective order for Rule 17(c) materials
Date: Wed, 24 Nov 2021 06:02:48 +0000
Attachments: 021-11-23,_GM,_government_proposed_Rule_17_protective_order.docx
Counsel,
We owe the Court a proposed protective order by noon for the materials responsive to your Rule 17 subpoena. Attached
is a draft of a short order which just applies the provisions of our existing protective order to these materials.
Please either send us a redline so we can discuss or let us know if you agree.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00019458


c1: EFTA00018721
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018721.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: GM - Draft Third Bail Opposition
Date: Tue, 09 Mar 2021 12:40:22 +0000
Embedded: RE:_Ghislaine_Maxwell_renewed_bail_application.msg
Chiefs - FYI, OIA got back to us this morning confirming the accuracy of the highlighted language and attaching a letter
from MOJ. See attached. I requested that the letter be translated on an expedited basis. I think we may be able to
strengthen the second highlighted sentence and cite to the last paragraph of MOJ's letter, but I'm awaiting the translation.
From:
Sent: Monday, March 08, 2021 8:09 PM
To:
is
Cc:
is
Subject: RE: GM - Draft Third Bail Opposition
Thanks very much. Will send to
now.
From:
Sent: Monday, March 08, 2021 7:20 PM
To:
is
Cc:
>;
Subject: RE: GM - Draft Third Bail Opposition
Thanks
we had a couple of additional comments but this looks good. We'd like you guys to send to
tonight, so
I think it's fine to keep the caveat about OIA/highlighted language in there while she reviews. Thanks again.
From:
Sent: Monday, March 8, 2021 6:39 PM
To:
is
Cc:
is
Subject: RE: GM - Draft Third Bail Opposition
Chiefs,
Attached is an updated draft of the opposition for your review. Our OIA contact in the UK had no edits on the language in
the attached. As indicated in the attached, the OIA contact in France is still waiting on feedback from MOJ; if we don't get
confirmation, we will remove the highlighted language.
Thanks,
From:
Sent: Sunday, March 07, 2021 10:04 PM
To:
i
EFTA00018721

=== Page 2 ===
Cc:
is
Subject: RE: GM - Draft Third Bail Opposition
Some combined comments and questions in track. I would like to see again at some point, and I think
will want to
see as well. But hopefully this should permit you to get the relevant section to OIA in the morning.
From:
>
Sent: Sunday, March 7, 2021 8:16 PM
To:
is
Cc:
is
Subject: GM - Draft Third Bail Opposition
Chiefs,
Hope you both had a nice weekend. Attached for your review is a draft of our opposition to the third bail application, also
attached for your convenience. As noted in the draft, we are still waiting on feedback from OIA re France so that section
is subject to change. We also plan to send the section on citizenship renunciation to OIA to make sure they review for
accuracy (as we did with our last opposition). Given the time difference and our filing deadline of Tuesday, we are hoping
to send this to them sometime tomorrow morning, but of course, happy to discuss.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
Tel:
EFTA00018722


c1: EFTA00019161
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019161.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
=
(USANYS)"
Subject: Emails from MM JE investigation
Date: Wed, 04 Nov 2020 16:57:25 +0000
Attachments: Items_of_Possible_Interest_JE_GM_case
zip
Attached is the folder containing the emails that we discussed this morning.
Please let me know if you need anything else.
Thanks and have a good day,
EFTA00019161


c1: EFTA00018844
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018844.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:20-cr-00330-AJN Document 337 Filed 10/05/21 Page 1 of 1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
United States of America,
DATE FILED: 10/5/21
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
The Court is currently in the process of planning logistics for trial in this matter and
requires the parties' best and current estimate of length of trial. The Court plans to have the jury
sit 5 days a week from 9am until 5pm. Given that jury selection will be complete by November
19 and opening statements will occur on November 29, the Court requests that the parties
provide their best estimate as to when the jury is likely to begin deliberations. This will allow
the Court to assess the likelihood that trial may continue after the Christmas holiday and
therefore whether the jury may be required to sit some days during the week between Christmas
and New Year's Day. Accordingly, on or before October 12, 2021, the parties are ORDERED to
confer and submit a joint letter with their best and current estimate as to when the jury is likely to
begin deliberations.
so ORDERED.
Dated: October 5, 2021
Alim D.Netto
New York, New York
ALISON J. NATHAN
United States District Judge
1
EFTA00018844


c1: EFTA00018391
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018391.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE:
Date: Wed, 24 Jul 2019 20:49:32 +0000
Hey I'm sorry, I'm running behind this afternoon. I could do 5:30, but I think that's after the hard stop for Sheb -- could we
do tomorrow morning or early afternoon? I can do literally anytime between 10:30 and 1:00 if any of that works. Sorry
for the moving target.
From:
Sent: Wednesday, July 24, 2019 16:37
To:
Cc:
Subject: RE:
I was going to volunteer my open-concept office, but everyone hates it so let's do conference room on 1.
From:
Sent: Wednesday, July 24, 2019 4:22 PM
To:
a
(
)
>; Swett, Sebastian
(
Cc:
Subject: RE:
Yeah, I can come down at 5:00 - let me know whose office
From
Sent: Wednesday, July 24, 2019 16:17
To: Swett, Sebastian
(
is
Subject: RE:
You guys around at all to chat?
From:
Sent: Wednesday, July 24, 2019 1:28 PM
To:
is
Cc:
)
Subject: RE:
I'm around until 5:30.
From
Sent: Wednesday, July 24, 2019 11:52 AM
To:
)
EFTA00018391

=== Page 2 ===
Cc:
Subject: RE:
Hey, we are getting subpoena results from
for Epstein materials, but we don't consider them a subject or target in
connection with their work with him, and so far they've been very responsive. When is a good time for you guys to chat
today? We're pretty over-scheduled these days but could potentially do this afternoon.
From:
Sent: Wednesday, July 24, 2019 09:25
To:
Cc:
Subject:
Hi guys,
We hear you may be talking to
about its relationship with Epstein. We've got an investigation into the
that overlaps with the Epstein stuff. Is there time today when we can chat?
Thanks!
Assistant United States Attorney
U.S. Attorney's Office for the Southern District of New York
1 St. Andrew's Plaza, New York, NY 10007
EFTA00018392


c1: EFTA00017812
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017812.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: Discovery Review Update
Date: Fri, 02 Oct 2020 16:23:45 +0000
Embedded: Discovery_Review_Update.msg
Sender:
Subject: Discovery Review Update
Message-Id:
<CY1P110MB0342D589DA379FFF8B32ADE492310@CY1P110MB0342.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
Cc:
EFTA00017812


c1: EFTA00019424
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019424.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Cc:
)"
(USANYS)"
JSANYS) [Contractor]"
Subject: RE: GM response
Date: Fri, 18 Dec 2020 15:03:44 +0000
Has Judge Nathan scheduled a day to rule on Maxwell's renewed bail motion? If/when, should we update the
VW site?
https://www.justice.gov/usao-sdny/united-states-v-ghislaine-maxw.l
Original Message
From:
)
Sent: Wednesday, December 16, 2020 9:14 PM
To:
Cc:
(USANYS)
Subject: Re: GM response
Sure thing, I'll forward it to you.
> On Dec 16, 2020, at 9:11 PM, Biase, Nicholas (USANYS)
wrote:
>
>
Awesome, thanks,
Would it be possible to get a copy just for me and
Obviously no rush,
tomorrow would be fine.
>
>
Sent from my iPad
V
On Dec 16, 2020, at 9:08 PM,
)
wrote:
>>
We filed our response today, but Judge Nathan required us to file it under seal with proposed redactions in the
first instance. Defense counsel has 24 hours to object to our redactions. So our response likely won't be on the
docket for at least a couple days.
On Dec 16, 2020, at 8:46 PM,
(USANYS)
wrote:
Pardon the interruption, I couldn't seem to find it on PACER, but when is our response to their renewed bail
package due? Thanks.
Sent from my iPad
EFTA00019424


c1: EFTA00018264
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018264.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Questionnaires are ready
Date: Sat, 13 Nov 2021 16:14:30 +0000
Attachments:
Copy_of_US_v_Maxwell_Juror_Questionnaire_Review_-
_MASTER_CHART_copy.xlsx
Hi
My spreadsheet is attached, thanks!
From:
Sent: Friday, November 12, 2021 1:53 PM
To:
is
is
is
Cc:
Subject: RE: Questionnaires are ready
Questionnaires from this morning saved here:
Assignments are in the attached spreadsheet. The questionnaires are uploaded to USAfx and are ready to be shared with
defense counsel once you email them to let them know.
Original Message
From:
Sent: Friday, November 12, 2021 12:07 PM
To:
is
is
is
Cc:
Subject: RE: Questionnaires are ready
Thanks! Team, as a reminder for planning purposes: your comments/objections to your batch of jurors will be due to
by 11 a.m. tomorrow morning. I'll work with
today to get this out to the defense and the court and get the
juror numbers assigned out to the team to review.
Original Message
From:
Sent: Friday, November 12, 2021 12:03 PM
To:
is
is
is
Cc:
Subject: Questionnaires are ready
Well let you know when they're scanned and ready for you.
Sent from my iPhone
EFTA00018264


c1: EFTA00019045
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019045.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: photo project
Date: Thu, 30 Sep 2021 20:41:53 +0000
Importance: Normal
Attachments: :Photos_for_Trial_Prep_with_Location_Info.xlsx
Let's discuss.
From:
Sent: Thursday, September 30, 2021 4:31 PM
To:
Cc:
Subject: RE: photo project
Hi
The photo sourcing project is completed and attached.
I added 3 columns: Evidence Item #, Name of CD and Location of Item.
Thanks,
From:
Sent: Monday, September 27, 2021 6:26 PM
To:
Cc:
Subject: [EXTERNAL EMAIL] - photo project
Hi
Just checking in on the photo sourcing project. Do you think you'll be able to send us that spreadsheet in the next few
days?
Thanks so much for helping with this.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019045


c1: EFTA00018838
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018838.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
STATE
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 4, 2021
VIA CERTIFIED MAIL
Ghislaine Maxwell (Reg. No. 02879-509)
MDC Brooklyn
Metropolitan Detention Center
P.O. Box 329002
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Enclosed is discovery pertinent to the following inmate:
Ghislaine Maxwell: 02879-509
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
s/
Assistant United States Attorneys
Enclosure
EFTA00018838


c1: EFTA00018174
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018174.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Gail Collins on Acosta and Epstein (the best part I highlighted in yellow)
Date: Thu, 11 Jul 2019 17:29:10 +0000
Importance: Normal
Inline-Images: image001.png; image002.jpg
https://www.nytimes.com/2019/07/10/opinion/acosta-epstein.html?action=click&module=Opinion&pgtype=Homepage
Trump Doesn't Know About Labor
Thank God we've got so many inept cabinet members.
By Gail Collins
Opinion Columnist
July 10, 2019
Image
EFTA00018174

=== Page 2 ===
Labor Secretary Alexander Acosta on Wednesday publicly defended his role in overseeing the prosecution of
Jeffrey Epstein. CreditCreditAnna Moneymaker/The New York Times
So, did you enjoy the parade for the U.S. women's soccer team? People sure did seem happy. I believe this is
partly because the players are terrific and partly because many Americans are desperate to think about something
other than Donald Trump.
And, good Lord, his crack team of cabinet members. On Wednesday, Secretary of Labor Alex Acosta tried to
hold back the outrage that's been building since people learned that, as a federal prosecutor in South Florida, he
had brokered a very lenient punishment for Jeffrey Epstein, a rich guy who liked to have sex with underage girls.
Explanation: It was a good deal. You know how this administration feels about good deals.
"The Palm Beach state attorney's office was ready to let Epstein walk free," Acosta said in his calm, sort of
toneless voice. "Our prosecutors presented the ultimatum." Which was that Epstein, who had molested a
parade of teenagers, some only 14, had to serve at least a little jail time. The punishment Acosta wrangled with
his alleged best possible efforts involved 13 months in prison, during which Epstein was free to spend most days
at his office as long as he slept overnight in the clink.
The victims had no idea that might be the end of the story. The case is now in the hands of federal prosecutors in
New York who are going after Epstein on other sex-trafficking charges. (You may have noticed that over the last
few years virtually everything that happens in this country winds up in the hands of New York prosecutors.)
Do you think Acosta ever asked himself whether he could have fought harder? Nah. The problem was the
victims, who were too "scared and traumatized" to be good witnesses. Asked by reporters if he had any regrets,
he just said that was "a very hard question."
Have you heard anybody in the Trump administration apologize for anything? Well, there was the occasion the
secretary of health and human services said he was sorry he spent $400,000 of our tax dollars to fly around in
specially chartered planes. But that was a long time and a whole lot of bad behavior ago.
About Jeffrey Epstein. He sounds like one of the worst people imaginable, so we are, of course, stunned to hear
he used to be tight with our current chief executive. "Terrific guy," Trump said in an interview with New York
magazine in 2002. "He's a lot of fun to be with. It is even said that he likes beautiful women as much as I do, and
many of them are on the younger side."
The palship no longer exists. "I had a falling-out with him. I haven't spoken to him in 15 years. I was not a fan of
his, that I can tell you," said the president, who appears to have erased the lot-of-fun-to-be-with period.
Are you shocked by any of this? Hey, early in our acquaintanceship we learned Trump is a guy who bragged
about being so important he could get away with grabbing women by their private parts. Who was put into office
thanks to Russian manipulation of our election. Some days you just want to sigh and talk a lot about women's
soccer.
Ever since the Epstein scandal arose, Trump has been defending Acosta, stressing what an "excellent" job he's
doing. After all, the president told reporters, "our economy is so good, our unemployment numbers are at record
lows." You might have thought he was under the impression the secretary of labor had something to do with
boosting the economy. As opposed to things like workplace safety and collecting job statistics.
And oh, yeah, human trafficking. Very embarrassing that Acosta is one of the people who's supposed to protect
underage women from being sold as sex slaves.
Hmm. Before this week, what do you think Donald Trump thought the Department of Labor did?
A) Something about delivering babies.
B) Something about getting good people to, you know, mow the lawn and stuff.
C) Something.
The president is oblivious, but otherwise almost nobody likes the job Acosta's been doing. People who care
about workers are naturally outraged that he's been trying to water down everything from mine safety regulations
to the rules that prohibit restaurant managers from grabbing a piece of the waiters' tips.
Trump insiders, of course, feel undermining workers' rights is supposed to be Acosta's mission. And they
complain he's been sort of inept at it. Mick Mulvaney, the Trump Acting Chief of Staff For Life, has been trying
to take control. Recently, Acosta's chief of staff was pushed out for a lack of, um, leadership. Or, as one former
administration official told Politico, "There are times when he goes completely loony."
You've got to be appalled by Acosta's failure to stand up for vulnerable children being lured into serving as sex
playthings for a man who truly does epitomize the concept of filthy rich.
But are you upset that Trump is too much of an ethical beanbag to get rid of him? The sad truth is that we're
really probably better off with cabinet members too inept to accomplish anything at all.
EFTA00018175

=== Page 3 ===
Cheer up. There's always soccer.
EFTA00018176


c1: EFTA00019880
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019880.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
) [Contractor]"
Cc:
)"
)"
Subject: RE:
notes
Date: Thu, 19 Dec 2019 22:19:25 +0000
Thanks!
From:
)
[Contractor]
Sent: Thursday, December 19, 2019 5:16 PM
To:
)
Cc:
>;
)
Subject: RE:
notes
Saved here:
From:
)
Sent: Thursday, December 19, 2019 5:14 PM
To:
)
[Contractor]
Cc:
)
>;
)
Subject: FW:
notes
For the Epstein share, thanks!
From:
Sent: Thursday, December 19, 2019 3:42 PM
To:
)
is
N. (NY) (FBI)
Subject: Re:
notes
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
From:
Sent: Wednesday, December 18, 2019 10:51 PM
To:
N. (NY) (FBI)
is
Subject:
notes
Hi guys, would one of you please send me the notes from the
interview when you have the chance?
Assistant United States Attorney
Southern District of New York
EFTA00019880

=== Page 2 ===
1 St. Andrew's Plaza
New York, NY 10007
EFTA00019881


c1: EFTA00018515
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018515.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 1 of 26
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
20 Cr. 330 (AJN)
V.
:
:
GHISLAINE MAXWELL,
:
:
Defendant.
:
:
X
MEMORANDUM OF GHISLAINE MAXWELL
IN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Jeffrey S. Pagliuca
(pro hac vice admission pending)
Laura A. Menninger
HADDON, MORGAN & FORMAN P.C.
150 East 10th Avenue
Denver, Colorado 80203
Phone: 303-831-7364
Attorneys for Ghislaine Maxwell
EFTA00018515

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 2 of 26
TABLE OF CONTENTS
Page
PRELIMINARY STATEMENT
1
ARGUMENT
5
I.
The Conditions Created by the COVID-19 Pandemic Mandate the Release of
Ms. Maxwell.
5
II.
The Government Has Not Carried Its Burden Under 18 U.S.C. $ 3142.
9
A.
Applicable Law
9
B.
Ms. Maxwell Has Rebutted the Presumption That She Poses a Flight
Risk, and the Government Has Not Carried Its Burden That No
Combination of Conditions Can Be Imposed To Reasonably Assure Her
Presence In Court
11
1.
Ms. Maxwell's Personal History and Characteristics
Demonstrate That She Is Not a Flight Risk
12
2.
The Nature and Circumstances of the Charges and the Weight of
the Evidence Militate in Favor of Bail
17
3.
The Proposed Bail Package Is More Than Adequate to Secure
Ms. Maxwell's Presence
20
CONCLUSION
22
i
EFTA00018516

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 3 of 26
TABLE OF AUTHORITIES
Page(s)
Cases
Hung V. United States,
439 U.S. 1326 (1978)
16
United States V. Abdellatif El Mokadem,
No. 19-CR-646 (AJN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020)
17
United States V. Alindato-Perez,
627 F. Supp. 2d 58 (D.P.R. 2009)
18
United States V. Bodmer,
No. 03-cr-947(SAS), 2004 WL 169790 (S.D.N.Y. Jan. 28. 2004)
16
United States V. Boustani,
932 F.3d 79 (2d Cir. 2019)
20
United States V. Carrillo-Villa,
20-MJ-3073 (SLC)
8
United States V. Chandler, 19-CR-867 (PAC),
2020 WL 1528120 (S.D.N.Y. Mar. 31, 2020)
8, 9
United States V. Conway,
No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3, 2011)
10, 18
United States V. Crowell,
No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006)
11
United States V. Deutsch,
No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020)
11, 18
United States V. DiGiacomo,
746 F. Supp. 1176 (D. Mass. 1990)
14
United States V. Dominguez,
783 F.2d 702 (7th Cir. 1986)
10
United States V. Dreier,
596 F. Supp. 2d 831 (S.D.N.Y. 2009)
21
United States V. English,
629 F.3d 311 (2d Cir. 2011)
10, 11
ii
EFTA00018517

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 4 of 26
United States V. Epstein,
425 F. Supp. 3d 306 (S.D.N.Y. 2019)
17
United States V. Esposito,
309 F. Supp. 3d 24 (S.D.N.Y. 2018)
21
United States V. Friedman,
837 F.2d 48 (2d Cir. 1988)
13, 18
United States V. Hansen,
108 F. App'x 331 (6th Cir. 2004)
16
United States V. Hanson,
613 F. Supp. 2d 85 (D.D.C. 2009)
16
United States V. Karni,
298 F. Supp. 2d 129 (D.D.C. 2004)
16
United States V. Kashoggi,
717 F. Supp. 1048 (S.D.N.Y. 1989)
16
United States V. Mattis,
No. 20-1713, 2020 WL 3536277 (2d Cir. June 30, 2020)
10
United States V. Moscaritolo,
No. 10 Cr. 4 (JL), 2010 WL 309679 (D.N.H. Jan. 26, 2010)
18
United States V. Sabhnani,
493 F.3d 63 (2d Cir. 2007)
9, 10, 16, 18
United States V. Salerno,
481 U.S. 739 (1987)
9
United States V. Stephens, 15-CR-95 (AJN),
2020 WL 1295155 (S.D.N.Y. Mar. 19, 2020)
5,6,7, 8
United States V. Veres,
No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Mar. 4, 2020)
18
United States V. Williams-Bethea,
No. 18-CR-78 (AJN), 2020 WL 2848098 (S.D.N.Y. June 2, 2020)
6
Statutes
18 U.S.C. $ 3142
passim
iii
EFTA00018518

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 5 of 26
PRELIMINARY STATEMENT
Ghislaine Maxwell respectfully submits this Memorandum in Opposition to the
government's July 2, 2020 Memorandum in Support of Detention ("Gov. Mem.").
It is difficult to recall a recent case that has garnered more public attention than the
government's prosecution of Jeffrey Epstein ("Epstein"). In July 2019, Epstein was indicted for
offenses relating to sexual misconduct, amid overwhelming media attention focused on the
nature of the charges and Epstein's wealth and lifestyle. On August 10, 2019, Epstein died in
federal custody, and the media focus quickly shifted to our client-wrongly trying to substitute
her for Epstein-even though she'd had no contact with Epstein for more than a decade, had
never been charged with a crime or been found liable in any civil litigation, and has always
denied any allegations of claimed misconduct. Many of these stories and online posts were
threatening and harassing to our client and those close to her.
But sometimes the simplest point is the most critical one: Ghislaine Maxwell is not
Jeffrey Epstein. She was not named in the government's indictment of Epstein in 2019, despite
the fact that the government has been investigating this case for years. Instead, the current
indictment is based on allegations of conduct that allegedly occurred roughly twenty-five years
ago. Ms. Maxwell vigorously denies the charges, intends to fight them, and is entitled to the
presumption of innocence. Far from "hiding," she has lived in the United States since 1991, has
litigated civil cases arising from her supposed ties to Epstein, and has not left the country even
once since Epstein's arrest a year ago, even though she was aware of the pending, and highly
publicized, criminal investigation. She should be treated like any other defendant who comes
before this Court, including as to bail. Under the Bail Reform Act, case law in this Circuit and
other circuits, as well as decisions of this Court, Ms. Maxwell should be released on bail, subject
to the strict conditions proposed below.
EFTA00018519

=== Page 6 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 6 of 26
Background. Ms. Maxwell, 58, is a naturalized U.S. citizen who has resided in the
United States since 1991. She is also a citizen of France, where she was born, and of the United
Kingdom, where she was educated and spent her childhood and formative years. Ms. Maxwell
graduated from Oxford University. She moved to the United States in 1991, and has lived in this
country ever since that time. Ms. Maxwell has maintained extremely close relationships with her
six siblings and her nephews and nieces. They all stood by her in the aftermath of the July 2019
indictment of Epstein and continue to stand by her now. She is especially close to two of her
sisters and their children, all of whom reside in the United States. Ms. Maxwell also has
numerous friends in the United States who themselves have children, and she is a godmother to
many of them. Ms. Maxwell's family and friends have remained committed to her because they
do not believe the allegations against her, which do not match the person they have known for
decades.
The Government's Position. The government has the burden of persuasion in showing
that detention is warranted, and that there are no conditions or combination of conditions that
will secure a defendant's appearance in court. In seeking to carry this burden, the government
relies on the presumption of detention in 18 U.S.C. $ 3142(e)(3)(E), and argues that Ms.
Maxwell poses a flight risk because she supposedly lacks ties to the United States; is a citizen of
the United Kingdom and France, as well as a citizen of the United States, and has passports for
each country; has traveled internationally in the past; and has financial means. And echoing
recent media stories, the government speculates that Ms. Maxwell was "hiding" from law
enforcement during the pendency of the investigation, even though she has been in regular
contact with the government, through counsel, since Epstein's arrest. Finally, the government
argues that the nature and circumstances of the offense and the weight of the evidence warrant
2
EFTA00018520

=== Page 7 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 7 of 26
detention. Importantly, in contrast with the bail position it took with Epstein, the government
does not and cannot assert that Ms. Maxwell presents a danger to the community under Section
3142(g)(4).
Ms. Maxwell's Response. The Court should exercise its discretion to grant bail to Ms.
Maxwell, on the strict conditions proposed below (or as modified by the Court), for two
compelling reasons.
First, the COVID-19 crisis and its impact on detained defendants warrants release. As
this Court has noted, the COVID-19 pandemic represents an unprecedented health risk to
incarcerated individuals, and COVID-19-related restrictions on attorney communications with
pretrial detainees significantly impair a defendant's ability to prepare her defense. Simply put,
under these circumstances, if Ms. Maxwell continues to be detained, her health will be at serious
risk and she will not be able to receive a fair trial. (See infra Section I, pages 5 to 9).
Second, the Court should grant bail because the government has not met its burden under
the Bail Reform Act and controlling case law. The presumption relied on by the government
may be rebutted, and is so here. Ms. Maxwell has strong ties to the community: she is a U.S.
citizen and has lived in this country for almost 30 years; she ran a non-profit company based in
the United States until the recent media frenzy about this case forced her to wind it down to
protect her professional colleagues and their organizations; and she has very close ties with
family members and friends in New York and the rest of the country. Nor does her conduct
indicate that she is a flight risk: she has no prior criminal record; has spent years contesting civil
litigation arising from her supposed ties to Epstein; and has remained in the United States from
the time of Epstein's arrest until the present, with her counsel in regular contact with the
government. She did not flee, but rather left the public eye, for the entirely understandable
3
EFTA00018521

=== Page 8 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 8 of 26
purpose of protecting herself and those close to her from the crush of media and online attention
and its very real harms-those close to her have suffered the loss of jobs, work opportunities,
and reputational damage simply for knowing her. The government's remaining arguments-
about Ms. Maxwell's passports, citizenship, travel and financial means- also fail because they
would require that every defendant with multiple citizenship and financial means be denied bail,
which is simply not the law. Finally, as discussed below, the government's position regarding
the nature and circumstances of the offense and weight of its evidence, which relates to alleged
conduct that is roughly twenty-five years old, is not persuasive and does not alter the bail
analysis. (See infra Section II, pages 9 to 21).
Proposed Bail Conditions. In light of the above, we propose the following bail
conditions, which are consistent with those that courts in this Circuit have imposed in analogous
situations: (i) a $5 million personal recognizance bond, co-signed by six financially responsible
people, all of whom have strong ties to Ms. Maxwell, and secured by real property in the United
Kingdom worth over $3.75 million; (ii) travel restricted to the Southern and Eastern Districts of
New York; (iii) surrender of all travel documents with no new applications; (iv) strict
supervision by Pretrial Services; (v) home confinement at a residence in the Southern District of
New York with electronic GPS monitoring; (vi) visitors limited to Ms. Maxwell's immediate
family, close friends and counsel; (vii) travel limited to Court appearances and to counsel's
office, except upon application to Pretrial Services and the government; and (viii) such other
terms as the Court may deem appropriate under Section 3142.
The Bail Reform Act does not discard the presumption of innocence; Ms. Maxwell is
entitled to that presumption here, as she is in all aspects of this case. See 18 U.S.C. $ 3142(j)
("Nothing in this section [3142] shall be construed as modifying or limiting the presumption of
4
EFTA00018522

=== Page 9 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 9 of 26
innocence."). The government has failed to meet its burden of establishing that Ms. Maxwell
presents an "actual risk of flight" and must be detained under Section 3142. The strict bail
conditions outlined above are appropriate under the circumstances and are the "least restrictive"
set of conditions that will "reasonably assure" Ms. Maxwell's appearance in Court, without the
health and access to counsel risks inherent in the government's request that Ms. Maxwell be
detained pending trial. See 18 U.S.C. $ 3142 (c)(1)(B). Under the controlling legal standards,
Ms. Maxwell should be released on bail.
ARGUMENT
There are two compelling reasons why the Court should order Ms. Maxwell's release
on bail pursuant to the strict conditions she has proposed:
First, Ms. Maxwell will be at significant risk of contracting COVID-19 if she is detained,
and she will not be able to meaningfully participate in the preparation of her defense due to the
restrictions that have been placed on attorney visits and phone calls in light of the pandemic.
Second, the government has failed to carry its burden under 18 U.S.C. $ 3142 that no
combination of conditions can be imposed that will reasonably assure Ms. Maxwell's presence in
court.
I.
The Conditions Created by the COVID-19 Pandemic Mandate the Release of
Ms. Maxwell.
Impact of COVID-19 on the Prison Population. We submit that the conditions created by
the COVID-19 pandemic compel Ms. Maxwell's release pursuant to appropriate bail conditions.
Four months ago, this Court held in United States V. Stephens, 15-CR-95 (AJN), 2020 WL
1295155 (S.D.N.Y. Mar. 19, 2020), that COVID-19 is an "unprecedented and extraordinarily
dangerous" threat that justifies release on bail. Id. at *2. In that case, the defendant, who had no
underlying medical conditions, filed an emergency motion for reconsideration of the Court's
5
EFTA00018523

=== Page 10 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 10 of 26
prior detention order based in part on the risks brought on by COVID-19. At the time, COVID-
19 had only begun to take its devastating toll on New York, and there was no known outbreak in
the prison population. Nevertheless, the Court noted that "inmates may be at a heightened risk of
contracting COVID-19 should an outbreak develop," and, based in part on this changed
circumstance, ordered the defendant released. Id.
Since the Court issued its opinion in Stephens, the COVID-19 risks to inmates have
increased dramatically, as there have been significant outbreaks of COVID-19 in correctional
facilities. In the last month alone, the number of prison inmates known to have COVID-19 has
doubled to 68,000, and prison deaths tied to COVID-19 have increased by 73 percent. 1 Indeed,
as of July 2, 2020, nine of the ten largest known clusters of the coronavirus in the United States
are in federal prisons and county jails.² As this Court noted last month, "the "inability [of]
individuals to socially distance, shared communal spaces, and limited access to hygiene
products' [in correctional facilities] make community spread all but unavoidable." United States
V. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020)
(citation and internal quotation marks omitted). The risks are further enhanced by the possibility
of a second wave of coronavirus cases. 3
In particular, COVID-19 has begun to spread through the Metropolitan Detention Center
(MDC), where Ms. Maxwell has been housed since the Bureau of Prisons (BOP) transferred her
there on July 6, 2020. According to the MDC's statistics, as of April 3, 2020, two inmates and
I Timothy Williams, et al., Coronavirus Cases Rise Sharply in Prisons Even as They Plateau Nationwide, N.Y.
Times, available at https://www.nytimes.com/2020/06/16/us/coronavirus-inmates-prisons-jails.html (last updated
June 30, 2020).
2 Coronavirus in the U.S: Latest Map and Case Count, N.Y. Times, available at
https://www.nytimes.com/interactive/2020/us/coronavirus-us-cases.html/cluster (last updated July 2, 2020).
3 See, e.g., Audrey Cher, WHO's Chief Scientist Says There's a "Very Real Risk" of a Second Wave of Coronavirus
As Economies Reopen, CNBC, June 9, 2020, available at https://www.cnbc.com/2020/06/10/who-says-theres-real-
risk-of-second-coronavirus-wave-as-economies-reopen.html
6
EFTA00018524

=== Page 11 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 11 of 26
five staff had tested positive; by June 30, 2020, those numbers had risen to 14 and 41,
respectively.4 The increased spread among prisons means that the COVID-19 risks that were
present in the Stephens case four months ago are far more serious for Ms. Maxwell now and
mandate her release.
Impact of COVID-19 on the Ability to Prepare the Defense. The Stephens opinion
provides yet another independent basis that, we submit, requires Ms. Maxwell's release: if she is
detained, her ability to meet with her attorneys and prepare for her defense will be significantly
impaired and she will not be able to meaningfully participate in the preparation of her defense.
In Stephens, the Court found that this factor required the defendant's release under 18
U.S.C. $ 3142(i), which provides for temporary release based on a determination that such
release is "necessary for preparation of the person's defense." Stephens, 2020 WL 1295155 at
*3. The Court noted that the spread of COVID-19 had compelled the BOP to suspend all in-
person visits, including legal visits, except as allowed on a case-by-case basis. Id. at *3. That
suspension persists to this day. 5 In a case such as this, which will require assessing evidence
relating to events that occurred approximately twenty-five years ago, including documents and
personal recollections, numerous in-person meetings between counsel and Ms. Maxwell will be
critical to the preparation of the defense. The recent resurgence of the pandemic calls into
question whether these meetings will ever be able to happen in advance of her trial. As in
4 See April 3, 2020 Report from the BOP regarding the Metropolitan Detention Center and Metropolitan
Correctional Center ("MDC and MCC Report"), available at
https://img.nyed.uscourts.gov/files/reports/bop/20200403_BOP Report.pdf; and June 30, 2020 MDC and MCC
Report, available at https://www.nyed.uscourts.gov/pub/bop/MDC MCC
5 See BOP COVID-19 Modified Operations Plan, available at https://www.bop.gov/coronavirus/covid19_status.jsp.
7
EFTA00018525

=== Page 12 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 12 of 26
Stephens, Ms. Maxwell's inability to meet with her attorneys while this policy is in effect
constitutes a "compelling reason" requiring her release. Stephens, 2020 WL 1295155 at *3.6
Even speaking by phone with Ms. Maxwell presents daunting challenges due to COVID-
19-related protocols requiring at least 72 hours' notice to schedule a call, unless it is urgent, in
which case counsel can email a request to the MDC. As counsel learned this past week,
however, even an urgent call request does not mean the call will take place in the time required.
At approximately 5:30 p.m. on July 6, 2020, the Court ordered us to confer with Ms. Maxwell
about waiving her physical presence at the arraignment, initial appearance, and bail hearing, and
ordered counsel for both sides to jointly report back by 9:00 p.m. that night with a proposed date
and time for these proceedings. We promptly emailed the MDC to request an urgent call,
making specific reference to the Court's Order, but were not connected with Ms. Maxwell until
9:00 p.m. There will no doubt be other orders of the Court with no guarantees we will be able to
reach our client in time if she is detained. In addition, during this past week, Ms. Maxwell has
not been able to physically review documents and has had limited access to writing materials.
The prohibition on in-person visits means we must read to her any documents requiring her
review, and she has virtually no ability to take notes. The age of the allegations in this case
compound these problems. Under the current circumstances, Ms. Maxwell cannot review
6 Since the Court issued its opinion in Stephens, numerous other courts in this District have ordered defendants
released on bail, over the government's objection, due to the pandemic and its impact on the defendant's ability to
prepare for trial. See, e.g., United States V. Carrillo-Villa, 20-MJ-3073 (SLC) (S.D.N.Y. Apr. 6, 2020) (releasing
undocumented defendant in drug conspiracy case because of inability to meaningfully communicate with lawyer and
risk of COVID-19); United States V. Hudson, 19-CR-496 (CM) (S.D.N.Y. Mar. 19, 2020) (releasing defendant in
drug conspiracy, loansharking, and extortion case, whose two prior, pre-COVID-19 bail applications were denied,
because of inability to prepare for upcoming trial and risk of COVID-19); United States V. Chandler, 19-CR-867
(PAC), 2020 WL 1528120, at *1 (S.D.N.Y. Mar. 31, 2020) (releasing defendant on felon in possession case, with
prior manslaughter conviction, due to inability to prepare for trial due to COVID-19 restrictions).
7 The government has recently worked with the BOP to set up a standing call between counsel and Ms. Maxwell
each morning until the initial appearance to facilitate attorney-client communications. While we greatly appreciate
these efforts, they are a short-term patch to a persistent problem that shows no signs of abating. Nor would it be
appropriate, on an ongoing basis, for the prosecutors to be involved in and dictate the date and time of our
communications with our client in connection with the preparation of our defense.
8
EFTA00018526

=== Page 13 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 13 of 26
documents and other evidence from approximately twenty-five years ago and meaningfully assist
in the preparation of her defense. These restrictions are additional "compelling reasons"
justifying her release. See id.⁸
II.
The Government Has Not Carried Its Burden Under 18 U.S.C. § 3142.
The grave concerns raised by the current COVID-19 crisis notwithstanding, Ms. Maxwell
must be released because she has met her limited burden of production showing that she does not
pose a flight risk, and the government has entirely failed to demonstrate that no release condition
or combination of conditions exist that will reasonably assure Ms. Maxwell's presence in court.
A.
Applicable Law
As the Supreme Court has recognized, "[i]n our society liberty is the norm, and detention
prior to trial or without trial is the carefully limited exception." United States V. Salerno, 481
U.S. 739, 755 (1987). Pretrial detention is appropriate only where "no condition or combination
of conditions will reasonably assure the appearance of the [defendant]." United States V.
Sabhnani, 493 F.3d 63, 75 (2d Cir. 2007) (quoting 18 U.S.C. $ 3142(e)). The Bail Reform Act
provides that a court "shall order the pretrial release" of the defendant (18 U.S.C. $ 3142(b))
(emphasis added), but may impose bail conditions if "such release will not reasonably assure the
appearance" of the defendant in court. 18 U.S.C. § 3142(c). Where conditions are necessary,
such release shall be "subject to the least restrictive
set of conditions that [the court]
determines will reasonably assure the appearance of the person as required." 18 U.S.C. $
3142(c)(1)(B) (emphasis added). Consequently, "[u]nder this statutory scheme, 'it is only a
limited group of offenders who should be denied bail pending trial." Sabhnani, 493 F.3d at 75
(citation and internal quotation marks omitted).
8
See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. V.
Federal Bureau of Prisons, et al., No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence of in-person
visitation, highly limited VTC and telephone call capacity, and issues pertaining to legal mail and legal documents).
9
EFTA00018527

=== Page 14 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 14 of 26
The government bears a dual burden in seeking pre-trial detention. First, the government
must show "by a preponderance of the evidence that the defendant
presents an actual risk of
flight." Sabhnani, 493 F.3d at 75 (emphasis added). If the government is able to satisfy this
burden, it must then "demonstrate by a preponderance of the evidence that no condition or
combination of conditions could be imposed on the defendant that would reasonably assure his
presence in court." Id.
In determining whether there are conditions of release that will reasonably assure the
appearance of the defendant, the court must consider (1) the nature and circumstances of the
offense charged; (2) the weight of the evidence against the person; (3) the history and
characteristics of the person; and (4) the nature and seriousness of the danger to any person or
the community that would be posed by the person's release. 18 U.S.C. $ 3142(g).
In this case, unlike in the Epstein case, the government does not contend that Ms.
Maxwell poses any danger to the community, and therefore the fourth factor does not apply.
The Bail Reform Act contains a rebuttable presumption, applicable based on certain of
the crimes charged here, that no conditions will reasonably assure against flight. See 18 U.S.C. $
3142(e)(3)(E). In cases where this presumption applies, the "defendant bears a limited burden of
production-not a burden of persuasion-to rebut that presumption by coming forward with
evidence that [she] does not pose
a risk of flight." See United States V. English, 629 F.3d
311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily
satisfied, United States V. Conway, No. 4-11-70756 MAG (DMR), 2011 WL 3421321, at *2
(N.D. Cal. Aug. 3, 2011), and "[a]ny evidence favorable to a defendant that comes within a
category listed in $ 3142(g) can affect the operation" of the presumption. United States V.
Dominguez, 783 F.2d 702, 707 (7th Cir. 1986); see also United States V. Mattis, No. 20-1713,
10
EFTA00018528

=== Page 15 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 15 of 26
2020 WL 3536277, at *4-5 (2d Cir. June 30, 2020). Although the presumption "remains a factor
to be considered" even after the defendant has met her burden of production, "[a]t all times
the government retains the ultimate burden of persuasion by
a preponderance of
the
evidence" that the defendant poses a flight risk that cannot be addressed by any bail conditions.
English, 629 F.3d at 319 (citation and internal quotation marks omitted); see also United States
V. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398, at *5 (E.D.N.Y. July 1, 2020). And
regardless of the presence of the presumption or the nature of the charges alleged, "[n]othing in
this section [3142] shall be construed as modifying or limiting the presumption of innocence."
18 U.S.C. $ 3142(j); see also United States V. Crowell, No. 06-CR-291E(F), 2006 WL 3541736,
at *3 (W.D.N.Y. Dec. 7, 2006) (those charged with crimes involving minors "continue to enjoy
the presumption of innocence in setting conditions of release.").
B.
Ms. Maxwell Has Rebutted the Presumption That She Poses a Flight
Risk, and the Government Has Not Carried Its Burden That No
Combination of Conditions Can Be Imposed To Reasonably Assure Her
Presence In Court
The government has not carried its burden of establishing that no set of conditions
will reasonably assure Ms. Maxwell's appearance in court. As set forth below, Ms.
Maxwell's personal history, her family and other ties to this country, and her conduct prior
to her arrest easily rebut the presumption that she presents a risk of flight. For these same
reasons, the government cannot establish that the strict bail conditions she proposes, which
are consistent with a number of cases in this Circuit in which courts have ordered release,
will not "reasonably assure" her presence in court. Accordingly, the Court should order Ms.
Maxwell released pursuant to her proposed conditions.
11
EFTA00018529

=== Page 16 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 16 of 26
1.
Ms. Maxwell's Personal History and Characteristics
Demonstrate That She Is Not a Flight Risk
a.
Ms. Maxwell Has No Prior Criminal Record, and Has
Significant Ties to the United States and the New York Region
Ms. Maxwell's history and characteristics do not "strongly support detention," as the
government contends (Gov. Mem. at 6), but instead demonstrate that she is firmly rooted in
this country and that her appearance can be reasonably assured with appropriate bail
conditions. Ms. Maxwell has no criminal record, which includes the approximately twenty-
five-year period from the time the conduct alleged in the indictment took place to the
present. Ms. Maxwell also has significant ties to the United States. She has lived in this
country for almost 30 years and became a naturalized U.S. citizen in 2002. Ms. Maxwell
also has strong family ties to this country. Two of her sisters, who have agreed to co-sign
her bond, live in the United States, and they have several children who are U.S.-born
citizens. Ms. Maxwell is very close with her sisters and maintains regular contact with
them, as well as with her nieces and nephews. Ms. Maxwell also has numerous close
friends and professional colleagues who reside in this country. In sum, the United States has
been Ms. Maxwell's home for decades.
b.
Ms. Maxwell Has Actively Litigated Civil Cases in this District
and Has Not Left the United States Since Epstein's 2019 Arrest
Ms. Maxwell has never once attempted to "hide" from the government or her
accusers, and has never shown any intent to leave the country. To the contrary, Ms.
Maxwell has always vehemently denied that she was involved in illegal or improper conduct
related to Epstein, and her conduct has been entirely consistent with someone who fully
intends to remain in this country and fight any allegations brought against her. For example,
since 2015, and continuing through today, Ms. Maxwell has actively litigated several civil
12
EFTA00018530

=== Page 17 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 17 of 26
cases related to Epstein in the Southern District of New York and has sat for depositions in
those cases. Similarly, throughout the course of the criminal investigation of this case,
which has been publicly reported on for nearly a year, Ms. Maxwell has remained in the
United States. Indeed, on July 7, 2019, the day after Epstein's arrest, Ms. Maxwell reached
out to the prosecutors in the Southern District of New York, through counsel, and
maintained regular contact with them right up to the point of her arrest.
The government's broad assertion that Ms. Maxwell has engaged in "frequent
international travel" in the last three years (Gov. Mem. at 6) obscures the critical point: she
has not left the country even once since Epstein's arrest. Ms. Maxwell's decision to remain
in the United States after Epstein's arrest and subsequent death in August 2019 is
particularly significant because any incentive she may have had to flee would have been
even more acute at that time. Within days of Epstein's death, a steady stream of press
articles began turning the public's attention to Ms. Maxwell-wrongly substituting her for
Epstein-and speculating that she had become the prime target of the government's
investigation. 9 Adding even more fuel to this fire, several of the women claiming to be
victims of Epstein's abuse began publicly calling for her immediate arrest and prosecution.
Despite the increasing risk of being criminally charged, and the media firestorm that was
redirected toward her after Epstein's death, and despite having ample opportunity to leave
the country, Ms. Maxwell stayed in the United States for almost an entire year until she was
arrested. These actions weigh heavily in favor of release. See United States V. Friedman,
9 See, e.g., Spotlight turns on Jeffrey Epstein's British socialite 'fixer' Ghislaine Maxwell after his suicide - but will
she be prosecuted?, Daily Mail (Aug. 10, 2019), https://www.dailymail.co.uk/news/article-7344765/Spotlight-turns-
Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html; Ghislaine Maxwell: the woman accused of helping Jeffrey
Epstein groom girls, The Guardian (Aug. 12, 2019), https://www.theguardian.com/us-news/2019/aug/12/ghislaine-
maxwell-woman-accused-jeffrey-epstein-groom-girls: British socialite Ghislaine Maxwell in spotlight after
Epstein's apparent suicide, NBC News (Aug. 12, 2019), https://www.nbcnews.com/news/us-news/british-socialite-
ghislaine-maxwell-spotlight-after-epstein-s-apparent-suicide-n104111.
13
EFTA00018531

=== Page 18 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 18 of 26
837 F.2d 48, 49-50 (2d Cir. 1988) (overturning district court's decision that defendant posed
a flight risk based in part on the ground that the defendant took "no steps" to flee
jurisdiction in three-week period between execution of search warrant at home and arrest);
United States V. DiGiacomo, 746 F. Supp. 1176, 1179-80 (D. Mass. 1990) (concluding
defendants did not present a flight risk because each of them "for three years knew there
was substantial evidence of the likely charges against them and did not attempt to flee
before indictment").
Indeed, the absence of any allegation by the government that Ms. Maxwell was
taking steps to leave the country at the time of her arrest is conspicuous. The government
has offered no proof that she was making plans to leave the country. In fact, had the
government alerted her counsel that she was about to be arrested, we would have arranged
for Ms. Maxwell's prompt, voluntary surrender. Instead, the government arrested Ms.
Maxwell without warning on the day before the July 4th holiday, thus ensuring that she
would be in federal custody on the one-year anniversary of Epstein's arrest.
c.
Ms. Maxwell's Actions to Protect Herself From Intrusive Media
Coverage and Death Threats Do Not Demonstrate an Intent to
Flee
Furthermore, the steps Ms. Maxwell took to leave the public eye after Epstein's
arrest are not indicative of a risk of flight. The government notes that Ms. Maxwell dropped
out of public view after Epstein's arrest, which the government seeks to portray as "hiding"
from the law. The government further argues that she has taken several steps to avoid
detection, including moving residences and switching her phone and email address. (Gov.
Mem. at 8). But Ms. Maxwell did not take these steps to hide from law enforcement or
evade prosecution. Instead, they were necessary measures that Ms. Maxwell was forced to
14
EFTA00018532

=== Page 19 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 19 of 26
take to protect herself, her family members, her friends and colleagues, and their children,
from unrelenting and intrusive media coverage, threats, and irreparable reputational harm.
Ever since Epstein's arrest, Ms. Maxwell has been at the center of a crushing
onslaught of press articles, television specials, and social media posts painting her in the
most damning light possible and prejudging her guilt. The sheer volume of media reporting
mentioning Ms. Maxwell is staggering. Since Epstein's arrest, she has been mentioned in
literally thousands of media publications, news reports, and other online content. The media
attention also spawned a carnival-like atmosphere of speculation about her whereabouts. In
November 2019, the British tabloid, The Sun, even offered a £10,000 bounty for information
about Ms. Maxwell's location. A headline reminiscent of a Wild West wanted poster read:
"WANTED: The Sun is offering a £10,000 reward for information on Jeffrey Epstein pal
Ghislaine Maxwell.'
And in the days leading up to her arrest, there was a deluge of media
reports (all untrue) claiming that Ms. Maxwell was hiding out in an apartment in Paris to avoid
questioning by the FBI. 11 She has seen helicopters flying over her home and reporters hiding in
the bushes. Indeed, since Ms. Maxwell's arrest on July 2, 2020, her counsel has been flooded
with hundreds of media inquiries and solicitations from members of the public.
The "open season" declared on Ms. Maxwell after Epstein's death has come with an
even darker cost - she has been the target of alarming physical threats, even death threats, and
has had to hire security guards to ensure her safety. The media feeding frenzy, which has only
intensified in recent months, has also deeply affected her family and friends. Some of Ms.
Maxwell's closest friends who had nothing whatsoever to do with Epstein have lost their jobs or
10 Se https://www.the-sun.com/news/74018/the-sun-is-ofering-a-10000-reward-for-information-on-jeffrey-epstein-
pal-ghislaine-maxwell/.
11 See, e.g., https://www.dailymail.co.uk/news/article-8444137/Jeffrey-Epsteins-fugitive-madam-Ghislaine-
Maxwell-hiding-luxury-Paris.html.
15
EFTA00018533

=== Page 20 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 20 of 26
suffered severe professional and reputational damage simply by being associated with her. Ms.
Maxwell therefore did what any responsible person would do - she separated herself from
everyone she cares about and removed herself from the public eye in order to keep herself and
her friends out of harm's way. 12
Lacking any evidence required under the governing standard that Ms. Maxwell
presents an "actual risk of flight," Sabhnani, 493 F.3d at 75, the government's flight risk
argument is reduced to the following: Ms. Maxwell is a woman of means who has foreign
citizenship and has traveled internationally in the past, and who now faces serious charges.
But if that were sufficient, then virtually every defendant with a foreign passport and any
meaningful amount of funds would need to be detained as a flight risk. See Hung V. United
States 439 U.S. 1326, 1329 (1978) (to detain based on risk of flight, government must show
more than "opportunities for flight," and instead must establish an "inclination on the part of
[the defendant] to flee"). That is not what the Bail Reform Act requires. Indeed, courts in
this Circuit and elsewhere commonly find that bail conditions can adequately address risk of
flight, even where individuals have foreign citizenship and passports or otherwise substantial
foreign connections, and financial means. See, e.g., Sabhnani, 493 F.3d at 66; United States V.
Hansen, 108 F. App'x 331 (6th Cir. 2004); United States V. Hanson, 613 F. Supp. 2d 85 (D.D.C.
2009); United States V. Bodmer, No. 03-cr-947(SAS), 2004 WL 169790, at *2-3 (S.D.N.Y.
Jan. 28. 2004); United States V. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004); United States V.
Kashoggi, 717 F. Supp. 1048, 1050-52 (S.D.N.Y. 1989).
Finally, the ongoing travel restrictions caused by the COVID-19 pandemic would
pose a significant hurdle to Ms. Maxwell's ability to flee the United States, particularly to
12 The media spotlight has also drawn out people who claim to speak for Ms. Maxwell, and even purport to have had
direct communications with her, but who, in fact, have no ties to Ms. Maxwell whatsoever. One such person has
even given numerous television interviews on news shows in the United Kingdom.
16
EFTA00018534

=== Page 21 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 21 of 26
France and the United Kingdom. 13 Notably, two weeks ago, this Court recognized in United
States V. Abdellatif El Mokadem, No. 19-CR-646 (AJN), 2020 WL 3440515 (S.D.N.Y. June
23, 2020) that "concerns regarding risk of flight are mitigated by the ongoing [COVID-19]
pandemic, which has understandably curtailed travel across the country, and, indeed, around
the world." Id. at *1. In that case, despite finding detention to be warranted on two prior
occasions, the Court concluded that the government could no longer establish flight risk and
ordered the defendant released pending sentencing. Id. ("Taking account of the COVID-19
pandemic, which had not yet reached this country when the Court last considered
Defendant's custody status, the balance now clearly and convincingly tips in Defendant's
favor
"). Consideration of this factor weighs heavily in favor of release on the proposed
bail conditions here.
2.
The Nature and Circumstances of the Charges and the
Weight of the Evidence Militate in Favor of Bail
The Defense Has Rebutted the Presumption Relating to Certain of the Charges. The
government relies on the statutory presumption of detention applicable to offenses involving
minor victims. (Gov. Mem. at 4-5.) But unlike the position it took with Epstein, the
government does not contend that Ms. Maxwell poses any danger to the community, or that
she suffers from compulsive or addictive sexual proclivities. See United States V. Epstein,
425 F. Supp. 3d 306, 314-15 (S.D.N.Y. 2019). Even according to the indictment, Ms.
Maxwell's alleged participation in offenses involving minors ended in 1997. Here, the only
13 See, e.g., E.U. Formalizes Reopening, Barring Travelers From U.S., N.Y. Times, (June 30, 2020), available at
https://www.nytimes.com/2020/06/30/world/europe/eu-reopening-blocks-us-travelers.html (confirming that the
European Union will not open its borders to travelers from the United States, and "[t]ravelers' country of residence,
not their nationality, will be the determining factor for their ability to travel to countries in the European Union");
England Drops Its Quarantine for Most Visitors, but Not Those From the U.S., N.Y. Times (July 3, 2020), available
athttps://www.nytimes.com/2020/07/03/world/europe/britain-quarantine-us-coronavirus.html (confirming that
England will leave mandatory 14-day quarantine restrictions in place for travelers coming from the United States).
17
EFTA00018535

=== Page 22 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 22 of 26
applicable presumption relates to risk of flight, and, as noted, Ms. Maxwell has rebutted that
presumption based on her ties to the United States, her decision to remain in this country
after Epstein's arrest, and all of the other reasons discussed above. This Court should follow
other courts in this Circuit and elsewhere that have found that defendants rebutted the
presumption and imposed appropriately strict bail conditions in cases involving alleged
offenses against minors. See Deutsch, 2020 WL 3577398, at *5-6; United States V. Veres,
No. 3:20-CR-18-J-32JBT, 2020 WL 1042051, at *3-4 (M.D. Fla. Mar. 4, 2020); Conway,
2011 WL 3421321, at *4-5.
The Impact of the Potential Penalties Is Overstated. The government asserts that
detention is warranted because of the potential for a long sentence in this case. (Gov. Mem.
at 4-5.) This oversimplifies the governing standard. Although the severity of potential
punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of
the commission of a serious crime and the fact of a potentially long sentence to support a
finding of risk of flight." Friedman, 837 F.2d at 49-50 (district court's finding that
defendant posed a risk of flight was clearly erroneous, despite potential for "long sentence
of incarceration"); see also Sabhnani, 493 F.3d at 65, 76-77 (reversing detention order
where defendants agreed to significant physical and financial restrictions, despite the fact
that they faced a "lengthy term of incarceration"). Accordingly, the asserted potential for a
14
long sentence does not meet the government's burden of persuasion.
14 The government relies on United States V. Alindato-Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009), cited
approvingly by United States V. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679, at *2 (D.N.H. Jan. 26, 2010) for
the proposition that "[t]he steeper the potential sentence, the more probable the flight risk is, especially considering
the strong case of the government (Gov. Mem. at 5.) But Alindato-Perez is easily distinguished on its facts
from Ms. Maxwell's case. Alindato-Perez was a narcotics case that did not involve 20-year old conduct as here, but
instead involved a conspiracy that "continu[ed] until the date of the indictment." 627 F. Supp. 2d at 60-61. The
evidence included eleven "clearly incriminating video tapes" and testimony from various cooperating witnesses, and
the defendant faced a 10-year mandatory minimum sentence. Id. at 61-64. These factors are not present in this case.
18
EFTA00018536

=== Page 23 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 23 of 26
Moreover, the government overstates the potential for Ms. Maxwell to spend
"decades in prison" if she is convicted. (Gov. Mem. at 5.) In fact, her likely total exposure
even if she were convicted on all counts is 10 years, assuming the Court were to follow the
traditional practice in this District and impose concurrent sentences. Although a 10-year
sentence would be significant, it is a far cry from the government's forecast, further
demonstrating that the government has not met its burden of showing Ms. Maxwell is an
actual risk of flight.
The Government's Case Is Subject to Significant Challenges. In evaluating the
strength of the government's case, we note that Ms. Maxwell intends to mount several legal
challenges to the indictment, including that: (i) this prosecution is barred by Epstein's
September 24, 2007 non-prosecution agreement with the Department of Justice, which
covers "any potential co-conspirators of Epstein"; (ii) the conspiracy, enticement of minors,
and transporting of minors charges are time-barred and otherwise legally flawed; and (iii)
the two perjury charges are subject to dismissal on several legal grounds. 15 In addition, as
we understand from the face of the indictment, the government's case is based primarily on
the testimony of three individuals about events that allegedly occurred roughly 25 years ago
between 1994 and 1997. It is inherently more difficult to prosecute cases relating to
decades-old conduct. These issues further call into question the strength of the government's
case, and provide an independent basis justifying release on bail.
15 The defense is also considering whether the government's comments in connection with this case conform to
Local Criminal Rule 23.1, and whether to seek appropriate relief from the Court.
19
EFTA00018537

=== Page 24 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 24 of 26
3.
The Proposed Bail Package Is More Than
Adequate to Secure Ms. Maxwell's Presence
For the reasons stated above, the Court should release Ms. Maxwell because the
circumstances created by the COVID-19 pandemic will greatly increase her personal risk
and prevent her from meaningfully participating in her defense, and because the government
has not carried its burden under 18 U.S.C. $ 3142. We respectfully submit that the proposed
bail package represents the "least restrictive" set of conditions that will reasonably ensure Ms.
Maxwell's presence in court. 18 U.S.C. $ 3142 (c)(1)(B).
The package includes six co-signers-Ms. Maxwell's siblings, relatives and
friends-many of whom reside in the United States, and all of whom continue to support her
despite the unrelenting media attacks that Ms. Maxwell and they, themselves, have suffered
as a result of this case. Each of them has voluntarily agreed to assume responsibility for an
extremely large bond amount of $5 million, in order to secure her appearance. The bond is
also to be secured by real property in the United Kingdom worth roughly $3.75 million.
The package also includes stringent travel and physical restrictions, including surrendering
all passports and no new travel applications, travel restricted to the Southern and Eastern
Districts of New York, and home detention with electronic GPS monitoring. Ms. Maxwell,
for personal reasons, will continue to need security guards to protect her upon release.
Under the circumstances, if the Court requires it, the security guards could report to Pretrial
Services. 16
16 In United States V. Boustani, 932 F.3d 79 (2d Cir. 2019), the Second Circuit curtailed the circumstances under
which a court can grant pretrial release to a defendant on the condition that the defendant pays for private armed
security guards. Boustani, nevertheless, held that a defendant may be released on such a condition if the defendant
"is deemed to be a flight risk primarily because of his wealth. In other words, a defendant may be released on such a
condition only where, but for his wealth, he would not have been detained." Id. (emphasis in original). We submit
that a similarly situated defendant who, like Ms. Maxwell, had no prior criminal record, significant ties to the United
States, and a demonstrated lack of intent to flee the country, as well as numerous, supportive co-signers, but who did
20
EFTA00018538

=== Page 25 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 25 of 26
Ms. Maxwell has a number of other family members and friends who, under normal
circumstances, would also co-sign and secure her bond. She is not relying on them in
connection with this bail application in an effort to safeguard their privacy and protect them
and their families from harm.
The proposed bail conditions are consistent with those approved by courts in this
Circuit in other high-profile cases, and should be approved here. See, e.g., United States V.
Esposito, 309 F. Supp. 3d 24, 32 (S.D.N.Y. 2018) (alleged leader of Genovese crime family
who was charged with racketeering and extortion granted release subject to conditions),
aff'd, 749 F. App'x 20 (2d Cir. 2018); United States V. Dreier, 596 F. Supp. 2d 831, 832
(S.D.N.Y. 2009) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high
flight risk," granted release subject to conditions); United States V. Madoff, 586 F. Supp. 2d
240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever" and
alleged to be a "serious risk of flight," granted release subject to conditions).
not have Ms. Maxwell's means, would be released on bail conditions. Accordingly, if the Court deems it necessary,
it may impose private security guards as a condition of release.
21
EFTA00018539

=== Page 26 ===
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 26 of 26
CONCLUSION
For the foregoing reasons, Ms. Maxwell respectfully requests that the Court order her
release on bail pursuant to the conditions she has proposed.
Dated: July 10, 2020
Respectfully submitted,
/s/ Mark S. Cohen
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Jeffrey S. Pagliuca
(pro hac vice admission pending)
Laura A. Menninger
HADDON, MORGAN & FORMAN P.C.
150 East 10th Avenue
Denver, Colorado 80203
Phone: 303-831-7364
Attorneys for Ghislaine Maxwell
22
EFTA00018540


c1: EFTA00018263
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018263.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Reply to GM letter
Date: Thu, 29 Oct 2020 20:17:19 +0000
Attachments: 2020.10.23,_GM_defense_response_to_Government_letter_re_other_agency_files.pdf;
2020-10-
07_GM_letter_to_Judge_Nathan_re_discovery_from_other_agencies_(FINAL).pdf;2020-
10-29_GM_reply_letter_re_discovery_v1.docx
Chiefs,
Attached is a draft reply to Maxwell's letter from last Friday. For reference, I'm attaching both their Friday letter and our
October 7th letter.
Thanks,
EFTA00018263


c1: EFTA00019851
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019851.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
(USANYS) [Contractor]"
(USANYS)"
)"
Subject: RE: Epstein/Maxwell Upload
Date: Fri, 25 Sep 2020 15:17:43 +0000
Thanks for flagging. Let's produce in their original format to both for now. If Maxwell has trouble opening them at MDC,
we'll deal with that after she tells us she can't open them. She has not identified every single excel and txt file from past
productions as problematic, so she will hopefully be able to open these.
From:
(USANYS) [Contractor]
Sent: Friday, September 25, 2020 10:47 AM
To:
Cc:
(USANYS) [Contractor] ;
(USANYS)
;
)
Subject: RE: Epstein/Maxwell Upload
How are we handling producing to Maxwell vs. Counsel? With these files there are tons of text and excel files that need to
be converted in order to be sent to MDC. Are we also producing the converted versions to defense or rather the original
natives?
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 2:34 PM
To:
(USANYS) [Contractor]
i
Cc:
(USANYS) [Contractor]
is
(USANYS)
is
Subject: RE: Epstein/Maxwell Upload
The zip files have been copied to the below location. Please let me know if there are any issues with the data in the zip
files.
Thank you.
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:42 AM
To:
(USANYS) [Contractor]
is
Cc:
(USANYS) [Contractor]
is
(USANYS)
;
Subject: RE: Epstein/Maxwell Upload
That's what I figured. Thanks! Now that they are all good to go would you please export both Deutsche Bank and
JPMorgan productions to the shared here: \\Usa.doj.gov\cloud\
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:39 AM
To:
(USANYS) [Contractor]
i
Cc:
(USANYS) [Contractor]
>;
(USANYS)
>;
Subject: RE: Epstein/Maxwell Upload
No way to put a confidential stamp on a excel file. There should be an image placeholder that says document produced in
native format which has the confidential stamp.
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:36 AM
To:
(USANYS) [Contractor]
is
EFTA00019851

=== Page 2 ===
Cc:
(USANYS) [Contractor]
is
(USANYS)
;
Subject: RE: Epstein/Maxwell Upload
Thanks
These look great. One quick question, on documents in native format (excel files) is there a confidential
stamp? I've checked and it seems the answer is no but I just want to be sure that I'm not missing anything.
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:20 AM
To:
>;
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS)
>;
Subject: RE: Epstein/Maxwell Upload
The documents should now be available for review. Please let me know if there are any questions.
Thank you.
From:
Sent: Thursday, September 24, 2020 9:11 AM
To:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
(USANYS)
>;
Subject: RE: Epstein/Maxwell Upload
These documents are not supposed to be privileged reviewed. The only documents that need to be privilege reviewed are
the electronic search warrant returns.
Thanks,
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 9:05 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
V.
(USANYS)
>;
)
Subject: RE: Epstein/Maxwell Upload
The data is probably secured for privilege review. Please let me know if these documents are not supposed to be
privileged reviewed.
Thank you.
From:
(USANYS) [Contractor]
Sent: Wednesday, September 23, 2020 5:39 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
V.
(USANYS)
>;
)
Subject: RE: Epstein/Maxwell Upload
Hey
When I click on each of those links I'm brought to a Relativity page with no data. Am I doing something wrong?
Thanks,
From:
(USANYS) [Contractor]
Sent: Wednesday, September 23, 2020 11:32 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
)
>;
(USANYS)
is
)
Subject: RE: Epstein/Maxwell Upload
The production of the documents has been completed. The below are links to the production for you to review:
EFTA00019852

=== Page 3 ===
Deutsche Bank -
JP Morgan - https://d1pe.nss.pae.com/Relativity/go?id-
Please review the documents and let me know if anything needs to be adjusted with the production.
Thank you.
From:
(USANYS) [Contractor]
Sent: Friday, September 18, 2020 10:26 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
>;
(USANYS)
is
Subject: RE: Epstein/Maxwell Upload
1. Yes, we want to mark all of them confidential
2. We are working on that.
3. I suppose database load files? We want to retain the files as they are currently formatted as best we can.
4. That won't be an issue. I don't think we will be searching through them; the purpose is just to be able to stamp
them.
Thanks!
From:
(USANYS) [Contractor]
Sent: Friday, September 18, 2020 10:10 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
V.
(USANYS)
is
)
Subject: RE: Epstein/Maxwell Upload
I know you want to produce these documents can you please tell me the following:
1. Will you placing a Confidential stamp on these documents?
2. What bates number do you wish to use on the documents?
3. How do you want to produce the documents (single page tiff images, database load files or PDF production).
4. Also please note that once the documents have been loaded to Relativity there is no way to run any searches for
these images since they are mostly images and video.
Please let me know if there are any questions.
Thank you.
From:
(USANYS) [Contractor]
Sent: Thursday, September 17, 2020 4:54 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
is
(USANYS)
is
Subject: Epstein/Maxwell Upload
Hey
We have some materials that we need uploaded to Relativity to the Epstein database for the purpose of stamping them.
The files in question number about 40,000 and are about 300GB in size. They are currently copying onto a drive to be sent
to Relativity and should be ready by tomorrow. Do you want to see them first or can they go directly to PAE?
Folder/Subfolder in Relativity: US V. Epstein
FBI Case File
Images Seized During Search
Thanks,
Paralegal Specialist
U.S. Attorney's Office SDNY
1 St. Andrew's Plaza
New York, NY 10007
Office:
Cell:
EFTA00019853


c1: EFTA00020358
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020358.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: SDNY indictment
Date: Thu, 02 Jul 2020 13:06:44 +0000
Attachments: Maxwell_Indictment,_20_Cr._330.pdf; ATT00001.htm; Maxwell_Arrest_Warrant.pdf;
ATT00002.htm
Chris, Mark, and Jeff,
We are writing to let you know that the FBI arrested your client this morning in Bradford, New Hampshire. I have
attached the indictment and arrest warrant, which we are providing to you as a courtesy while we seek the formal
unsealing of the indictment at SDNY this morning. We will let you know when a district judge is assigned at SDNY. The
defendant is currently being transported for arrest processing by the FBI, and our current expectation is that she will be
presented this afternoon in the District of New Hampshire, via remote proceedings. We will update you as we learn more.
and
and I are available for a call later this morning, if that would be useful. Please let us know what time
would be convenient for you.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00020358


c1: EFTA00019042
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019042.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: depo
Date: Fri, 26 Mar 2021 00:06:28 +0000
Attachments: 2009-12-04,
Deposition_Vol _I.pdf; 2009-12-
04,
Deposition_Vol._II.pdf
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00019042


c1: EFTA00018108
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018108.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
)"
Subject: Epstein Sharing Order Part II
Date: Wed, 29 Jan 2020 15:39:54 +0000
Attachments: 2019.12.19_Epstein_6(e)_App_Order.ebd.,docx.docx
- I've updated the sharing order application to be one to share the additional trust and will documents we have now
received. Would you take a look when you can?
- I've tried to describe the various materials we have gotten from the estate attorneys over the last two weeks.
Would you mind taking a look (or asking a paralegal to take a look) to make sure I've accurately described/characterized
the new stuff we're looking to share?
Thanks,
EFTA00018108


c1: EFTA00019329
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019329.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Epstein
Date: Tue, 23 Jul 2019 21:19:40 +0000
Importance: High
WaPo is hearing that he was found unresponsive is his cell last night, possibly a suicide attempt. I'm here if you want to
stop in.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
Mobile:
I
Press Office:
EFTA00019329


c1: EFTA00017869
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017869.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
y (USANYS)"
To:
(USANYS)"
Subject:
Date: Wed, 13 Nov 2019 15:33:06 +0000
NYT:
said she recalled Mr. Epstein as kind and casual, wearing
sweatpants, pouring champagne and talking about her college plans. During the
trip, they all went to see a movie. As the film progressed, Mr. Epstein began
rubbing
hand, and then her lower leg, she said."
EFTA00017869


c1: EFTA00018892
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018892.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
STATE
STATE
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
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
EFTA00018892


c1: EFTA00019507
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019507.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Epstein case, supervisor info
Date: Fri, 07 Dec 2018 02:34:36 +0000
Importance: Normal
ASAC
GS
Assistant U.S. Attorney
Southern District of New York
EFTA00019507


c1: EFTA00018726
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018726.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Automatic reply: Epstein victim call
Date: Wed, 10 Mar 2021 21:16:53 +0000
I am out of the office with limited access to email until Monday, March 14. If you need immediate assistance, contact the other agent on the case
or SSA
Thank you
EFTA00018726


c1: EFTA00018396
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018396.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Epstein's attorney?
Date: Mon, 08 Jul 2019 17:13:28 +0000
Importance: Normal
Do you have his attorney info?
Public Affairs
U.S. Attorney's Office for the Southern District of New York
Website: www.justice.gov/usao-sdny.
Facebook: https://www.facebook.com/usaosdny
Follow us on Twitter: @SDNYnews
EFTA00018396


c1: EFTA00018272
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018272.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Fwd: Epstein
Date: Sat, 13 Jul 2019 14:43:20 +0000
Importance: Normal
I didn't realize his son worked for
We should consider whether we should do a protect-the-record
Curcio given that his son works for
Sent from my iPhone
Begin forwarded message:
From: "Berman, Geoffrey (USANYS)"
Date: July 12, 2019 at 9:10:52 PM EDT
To:
Subject: Epstein
I just ran into Reid Weingarten at Odeon, who told me that he had just met with his client and he may reach out
to the team early next week to have an "interesting conversation". He added that he spoke to his son, who is an
in
who told him that the sex trafficking statute is quite broad. (That he could have figured out for
himself). Geoff
EFTA00018272


c1: EFTA00019432
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019432.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 11061409-1(1) approved by
,
now awaiting further
approval
Date: Tue, 24 Mar 2020 14:28:04 +0000
Importance: Normal
Dear
Final voucher 11061409-1(1) has been approved by
, now awaiting further approval.
Trip ID: 11061409-1
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13400 - Epstein Investigation Witness interviews
Destination: Beverly Hills, CA, United States
Dates: 2020-02-26 - 2020-02-29
Current status: Pending Voucher Approval
Voucher total expenses: 1196.11
Estimated trip cost: 1634.37
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0010
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00019432


c1: EFTA00018165
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018165.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
Subject: Fwd: House Oversight issue
Date: Tue, 09 Jul 2019 14:21:02 +0000
Importance: Normal
See below. I have not yet responded.
Also late yesterday, call from
I did not yet connect with him.
Let's discuss.
Sent from my iPhone
Begin forwarded message:
From:
Date: July 9, 2019 at 8:52:45 AM EDT
To:
)"
Subject: House Oversight issue
good morning. Hope that you are well. I received a call from the House Oversight Committee yesterday
related to the Jeffrey Epstein indictment. Would you be the right point of contact to discuss their request? If not, could
you put me in touch with the team handling this matter?
Thanks,
Deputy Assistant Attorney General
Office of Legislative Affairs
U.S. Department of Justice
EFTA00018165


c1: EFTA00019082
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019082.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
March 29, 2021
BY ELECTRONIC MAIL
New York, NY 10022
Denver, CO 80203
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
In light of the return of superseding indictment S2 20 Cr. 330 (AJN) (the "S2 Indictment"),
the Government writes to provide you with information regarding the individual identified as
Minor Victim-4 in the S2 Indictment. Please note that both this letter is 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. Minor Victim-4 was born in
To assist you in identifying portions of the discovery materials that are relevant to the new
allegations contained in the S2 Indictment, below please find a list of certain Bates ranges that
relate to Minor Victim-4, which were already produced to you. Please note that this list, which is
being provided to you as a courtesy, is not exhaustive and does not include every portion of
discovery that is relevant Minor Victim-4.
EFTA00019082

=== Page 2 ===
Page 2
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
Assistant United States Attorneys
EFTA00019083


c1: EFTA00019725
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019725.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: Misc Correspondence re Jeffrey Epstein
Date: Sat, 19 Oct 2019 01:56:19 +0000
Attachments: 4319870-Email Message-RE_Ettinger.pdf; Arlan_Ettinger.pdf; 4319870-ES_Control_Sheet-
Ettinger.pdf; 2019.10.15_Letter_to_Guernsey's.docx
FYI
From:
Sent: Tuesday, October 15, 2019 12:09
To:
Subject: Misc Correspondence re Jeffrey Epstein
Please file this, which includes my response, in some appropriate place. Thanks.
From:
Sent: Wednesday, October 9, 2019 2:06 PM
To:
Subject: FW: Arlan Ettinger
What is the right way to handle this? It seems to be an offer by Guernsey's Auctioneers & Brokers to be retained to handle
the disposition of Epstein's property. I was assigned to respond to this. Please advise.
Thanks
From:
Sent: Wednesday, October 9, 2019 1:57 PM
To:
Subject: Arlan Ettinger
Good afternoon!
I have been advised to forward you the attached correspondence from Arlan Ettinger, President of Guernsey's Auctioneers
& Brokers. The letter is regarding the property of the late Jeffrey Epstein. As advised by Nathaniel Gamble Il from ODAG
(see email attached), this has been assigned to USAO-SDNY for handling. Please let me know if you have any questions or
concerns.
Thank you very much in advance.
Best,
EFTA00019725

=== Page 2 ===
U.S. Department of Justice
Executive Office for U.S. Attorneys
0:
Pronouns: she/ her/ hers
EFTA00019726


c1: EFTA00019344
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019344.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Chron
Date: Wed, 14 Aug 2019 16:32:18 +0000
Attachments: MCC_Timeline.xlsx
This is a chron that we put together, in case you want to take a look.
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00019344


c1: EFTA00018976
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018976.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(OIG)"
To:
(NY) (FBI)"
(NY) (OGA)
(FBI)"
(USANYS)"
(USANYS)"
Subject: FW: Requested Documents
Date: Sun, 11 Aug 2019 14:57:11 +0000
Attachments: E-Mails_from_Psychology.pdf
Please see the attached emails regarding Suicide Watch and Psychological Observation. Suicide Watch and Psychological
Observation occur in cells on the second floor. The only difference is that while on Suicide Watch inmates are not
permitted to have clothes in their cell.
Some questions I just asked Lt. Doctor this morning:
1) Are there logs slips for the head counts done at 3:00 a.m. and 5:00 a.m.? If so, can we get copies?
She is getting us those forms.
2) Who was Epstein's last cellmate?
). He had court on 8/9/19 and was released from 500 Pearl St. According to
the BOP webpage he was released from custody and his location now is unknown.
was a regular SHU
inmate, not special trainings according to his file.
3) Was Epstein supposed to have a cellmate?
According to Lt. Doctor, there was not a requirement for him to have a cellmate.
4) Who assignments cellmates?
Any officer can assign cellmates, as long as there are no "conflicts." The only person Epstein was not permitted to
be cellmates with was "Tartaglione", who was his cellmate during his first suicide attempt.
U.S. Department of Justice
Office of the Inspector General
New York Field Office
New York, NY 10004
(Office)
(Cell Phone)
From:
[mailto:
Sent: Sunday, August 11, 2019 10:33 AM
To:
(OIG)
Subject: Requested Documents
EFTA00018976


c1: EFTA00018504
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018504.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Second Circuit oral arguments next week (October 12-16, 2020)
Date: Thu, 08 Oct 2020 21:21:33 +0000
The Office has three oral arguments in criminal cases scheduled before the Second Circuit next week. They will be argued
by phone/zoom, and you can listen to the livestream at this link. Also, you can click on the hyperlinks below to access our
briefs.
Tuesday, October 13, 2020
(Winter, Walker, Menashi)
Farhane V. United States
-
arguing
- Motion for certificate of appealability: denial of Section 2255 motion raising ineffective of assistance of counsel
claim based on failure to advise about possibility of denaturalization
- First on A calendar; scheduled to start at 10:00 am
(Cabranes, Pooler, Raggi)
United States V. Maxwell
-
arguing
- Pre-trial appeal: whether district court's order denying D's motion to modify protective order is subject to
interlocutory appeal; whether district court abused its discretion in denying the motion
- Second on B calendar; scheduled to start at 2:24 pm
Thursday, October 15, 2020
(Walker, Lohier, Stanceu)
United States V. Louis Mclntosh (here and here)
-
arguing
- Appeal from trial and our cross-appeal from partial grant of Rule 29 motion: sufficiency of the evidence of Hobbs Act
robbery counts (intent to commit robbery, interstate commerce, and venue); Davis challenge to Section 924(c)
conviction (attempted Hobbs Act robbery); Rehaif challenge to jury instructions; whether the Rule 32.2 deadline
for entry of a preliminary order of forfeiture is jurisdictional
- First on calendar; scheduled to start at 10:00 am
EFTA00018504


c1: EFTA00018852
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018852.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
)"
Cc:
(USANYS) [Contractor]"
Subject: RE:
Date: Wed, 06 Oct 2021 20:26:32 +0000
Attachments: manifest.xlsx
As discussed, I sorted the materials into either
3500 folder or
3500 folder. I've attached the manifest
that
also included in the zip file, for your reference. Would you like that saved anywhere on the shared?
From:
(USANYS) [Contractor]
Sent: Wednesday, October 6, 2021 4:00 PM
To:
(USANYS)
>;
)
Cc:
(USANYS) [Contractor]
Subject: RE:
Hey
- would you like me to save this on the shared somewhere? Thanks!
From:
Sent: Wednesday, October 6, 2021 3:53 PM
To:
(USANYS)
is
Cc:
;
(USANYS) [Contractor]
Subject: RE:
Can you see if this will open for you? If not, can you send me a link to upload to USAfx?
Thanks,
From:
(USANYS)
Sent: Wednesday, October 6, 2021 3:41 PM
To:
(NY) (FBI)
is
)
Cc:
(NYPD)
is
(USANYS) [Contractor]
Subject: [EXTERNAL EMAIL] - RE:
Thanks,
Unfortunately the zip seems to be empty? I'm copying
Can you try resending to her? Or she can
set you up with USAfx? Thanks!
From:
Sent: Wednesday, October 6, 2021 2:50 PM
To:
(USANYS)
is
)
Cc:
Subject:
1As you requested are attached.
EFTA00018852

=== Page 2 ===
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
EFTA00018853


c1: EFTA00018883
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018883.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
April 23, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Pursuant to Rule 16(a)(1)(G) of the Federal Rules of Criminal Procedure, the Government
hereby provides notice that it may call as an expert witness at trial Dr. Lisa Rocchio, a clinical
instructor of psychiatry and human behavior at the Alpert Medical School of Brown University.
The Government reserves the right to call additional expert witnesses and will promptly provide
notice if the Government elects to do so.
I.
Disclosure by the Government
Dr. Lisa Rocchio is the President-Elect of the Division of Trauma Psychology of the
American Psychological Association ("APA"). Dr. Rocchio has practiced psychology since
earning her Ph.D. in 1995, and she is currently a clinical instructor at the Alpert Medical School
of Brown University, where she trains psychiatric residents in treating trauma survivors. Since
she entered private practice in 1998, Dr. Rocchio has specialized in treating patients with trauma,
including sexual trauma in childhood and adolescence. In the last twenty-three years, Dr. Rocchio
has treated hundreds of victims of trauma, many of whom were minor victims of sexual abuse.
Dr. Rocchio has also received specialized training in traumatic stress, sexual abuse, and clinical
EFTA00018883

=== Page 2 ===
Page 2
and forensic psychology. She has written, presented, and taught about the assessment and
treatment of trauma, among other topics. Since 2014, Dr. Rocchio has been on the editorial review
board of the APA journal Trauma Psychology: Theory, Research, Practice and Policy, and she is
a member of the APA Ethics Committee. A copy of Dr. Rocchio's curriculum vitae is being
produced to you today bearing Bates number 3502-006.
Dr. Rocchio is expected to testify, based on her relevant education, training, experience,
and research to the following: Individuals with particular vulnerabilities are often targeted by
perpetrators of sexual abuse. Sexual abuse of minors frequently occurs through the use of
manipulation or coercion in the context of an established relationship that is developed over time,
rather than through the use of forcible rape. Minor victims are often subject to a strategic pattern
of behaviors, often called grooming, that can take a variety of forms and function to render the
victims vulnerable to abuse, to obscure the nature of the abuse, and to build trust and attachment
with their abuser. The relationship of trust and attachment can prevent victims from being aware
that what they are experiencing is abuse and can prevent disclosure. Minor victims therefore may
not identify themselves as victims of abuse while it is ongoing, and may not recognize the
consequences of that abuse until adulthood. Repeated exploitation and abuse can increase the
likelihood of victimization later in life and can result in long-term traumatic and psychological
consequences, especially when it occurs in the context of complex trauma. The presence of other
individuals can facilitate the sexual abuse of minors. Dr. Rocchio is also expected to testify that
nondisclosure, incremental disclosure, and secrecy are common among victims of sexual abuse for
a variety of reasons, and that memory and disclosure of traumatic or abusive events is impacted
by a number of factors, including the circumstances surrounding the trauma. Dr. Rocchio has not
evaluated any specific victim in this case, and the Government does not presently intend to offer
Dr. Rocchio's testimony regarding any specific victim.
Dr. Rocchio's expected testimony relies on her education and training on psychological
trauma, traumatic stress, interpersonal violence, and sexual abuse. It also relies on Dr. Rocchio's
extensive clinical experience treating individuals who suffered sexual abuse and trauma in
childhood and adolescence, as well as Dr. Rocchio's experience conducting forensic psychological
evaluations of people who have experienced sexual abuse and trauma. The Government is
producing notes from the Government's interviews with Dr. Rocchio today as well.
II.
Request for Reciprocal Discovery and Expert Notice
In light of your request for the foregoing notice, the Government hereby requests reciprocal
notice under Rule 16(b)(1)(C) of the Federal Rules of Criminal Procedure regarding any expert
witness that the defendant intends to rely upon, including a written summary of any testimony that
the defendant intends to use under Rules 702, 703, or 705 of the Federal Rules of Evidence, as
well as the witness's qualifications.
1 Dr. Rocchio has previously testified in state court and has been deposed in the course of federal
and state litigation. As a courtesy, a list of that testimony is also being produced to you today
bearing Bates number 3502-002.
EFTA00018884

=== Page 3 ===
Page 3
Additionally, the Government reiterates its August 5, 2020 request for reciprocal discovery
under Fed. R. Crim. P. 16(b). Specifically, we request that you allow inspection and copying of:
(1) any books, papers, documents, data, photographs, tangible objects, buildings or places, or
copies or portions thereof, which are in the defendant's possession, custody or control, and which
the defendant intends to introduce as evidence or otherwise rely on at trial; and (2) any results or
reports of physical or mental examinations and of scientific tests or experiments made in
connection with this case, or copies thereof, which are in the defendant's possession or control,
and which the defendant intends to introduce as evidence or otherwise rely on at trial or which
were prepared by a witness whom the defendant intends to call at trial.
The Government also reiterates its August 5, 2020 request that the defendant disclose prior
statements of witnesses she will call to testify, including expert witnesses. See Fed. R. Crim. P.
26.2; United States V. Nobles, 422 U.S. 225 (1975). The Government requests that such material
be provided on the same basis upon which the Government agrees to supply the defendant with
3500 material relating to Government witnesses.
Very truly yours,
United States Attorney
by: /s/
Assistant United States Attorneys
EFTA00018885


c1: EFTA00019516
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019516.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: Epstein Oral Argument-- Second Circuit
Date: Wed, 09 Jan 2019 19:17:13 +0000
Importance: Normal
Attachments: unnamed
EFTA00019516


c1: EFTA00019177
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019177.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Request for Press Comment re Epstein
Date: Fri, 23 Jul 2010 19:23:21 +0000
Importance: Normal
She called me also. I will send her an email and tell her we will not be commenting or speaking about this
matter. She is persistent, that's for sure.
From:
C. (USAFLS)
Sent: Friday, July 23, 2010 3:15 PM
To:
(USAFLS)
Subject: Request for Press Comment re Epstein
Hi
-
has called me again. She told me to read her two internet articles and then asked
me to call her to "discuss" them. Her number is
Here are the articles. I don't have any comment.
Confidential background information: The investigation stemming from the seizure of the evidence from
Epstein's former butler (who is referenced in the articles), is continuing.
Please let me know if you would like me to do anything. Thanks.
« File: Sarnoff Article.pdf >>
« File: 2nd Sarnoff Article.pdf >>
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Fax
EFTA00019177


c1: EFTA00020335
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020335.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: Maxwell superseder prosecution memo
Date: Wed, 24 Mar 2021 16:11:12 +0000
Attachments: Maxwell_S2_Indictment_v1_redline.rd.docx
My edits attached.
From:
Sent: Wednesday, March 24, 2021 11:20 AM
To:
(USANYS)
in
is
(USANYS)
is
Cc:
(USANYS)
Subject: RE: Maxwell superseder prosecution memo
Sure thing, attached.
From:
(USANYS)
Sent: Wednesday, March 24, 2021 9:22 AM
To:
)
is
is
(USANYS)
is
)
Cc:
(USANYS)
Subject: RE: Maxwell superseder prosecution memo
Thanks so much. Do you mind sending a redline from the prior version to expedite review?
From:
Sent: Tuesday, March 23, 2021 11:10 PM
To:
(USANYS)
is
is
(USANYS)
is
Cc:
(USANYS)
Subject: RE: Maxwell superseder prosecution memo
Attached is a draft superseding indictment.
Thanks,
From:
Sent: Tuesday, March 23, 2021 11:29 AM
To:
(USANYS)
is
>;
(USANYS)
is
Cc:
(USANYS)
Subject: RE: Maxwell superseder prosecution memo
Sure thing, will aim to get you a draft today, thanks.
From:
(USANYS)
Sent: Tuesday, March 23, 2021 10:32 AM
EFTA00020335

=== Page 2 ===
To:
is
is
(USANYS)
>;
Cc:
(USANYS)
Subject: FW: Maxwell superseder prosecution memo
Hi team, we have asked
what the Brass wants to do in terms of review/meeting, and will let you know. In the
meantime and mindful of the Monday GJ date, do you mind putting together a draft indictment for us to review? Thanks!
From:
(USANYS)
Sent: Friday, March 19, 2021 3:34 PM
To:
is
(USANYS)
>;
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
is
(USANYS)
>;
Subject: RE: Maxwell superseder prosecution memo
Thanks,
From:
Sent: Friday, March 19, 2021 3:24 PM
To:
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
in
is
(USANYS)
in
)
Subject: Maxwell superseder prosecution memo
All,
Attached please find a prosecution memorandum requesting authorization to seek a superseding indictment charging
Maxwell with additional criminal offenses. For reference, I have also attached the two prior prosecution memos regarding
the original indictment in this case. We have tentatively scheduled grand jury time for Monday, March 29th.
Thanks,
EFTA00020336


c1: EFTA00019788
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019788.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Truscope.Silverlight.Dashboard
Page 1 of 2
NYM: 6/11/2018 8/11/2019
A1583 $15 Contraband BA
9 SOUTH SHU
Logout
NYM
RollCal
High
Rsk
Inmate Lists
583g
SIS Contraband
BAs
UAs
Daily
Adivity
STG
Now
Inmates
8/7/2019 8/11/2019 All Log Events
Current Base Count: 74
Add Log Event
Entered Date
Event Date
Shill
Dues
Log Event
for
Summary Text
Count
08/05/2019 05:35 PM 05:30 PM Evenim
adio Check
Rado Number: 608.
SHU
08/09/2019
05:35
PM
08/09/2019
05:30
PM
Evenin
my Check
Ring Number: C-31. Count: 7.
08/09/2019 05:35 PM 08/09/2019 05:30 PM Evenin
ey Check
Ring Number: C-32, Count: 7.
08/09/2019 05:35 PM 08/09/2013 05:30 PM Evenin
#y Check
Ring Number: C-27. Count: 10.
08/09/2019 05:35 PM 08/09/2019 05:30 PM Evenin
by Check
Ring Number: C-29, Count: 6.
06/09/2019 05:35 PM 08/09/2019 05:30 PM Evenin
RY Check
Ring Number: C-28, Count: 2.
08/09/2019 05:35 PM 08/09/2019 05:30 PM Evenin
ay Check
Ring Number: B-33, Count: 4.
Housing Unit, Special
08/09/2019
05:35
PM
08/09/2019 05:30 PM
Evenin
in Alam Panel Check
Completed.
(SHU)
06/09/2019
05:35
PM
08/09/2019 05:30 PM
Evenin
inventory Sheet Verified
Completed.
08/09/2019
05:30
PM
08/09/2019 04:00 PM
Evenie
legin Shit
Completed.
08/09/2019
12:36
PM
08/09/2019
12:36
PM
Day
Search (Cells)
Cell: 107.
08/09/2019
12:36
PM
08/09/2019
12:36
PM
Day
lar Taps (Cells)
Cells: 44. BAR TAPS CONDUCTED WHOLE SHOWERS
08/09/2019
11:28
AM
08/09/2019
11:27
AM
Day
Rounds (Ueutenant)
Completed PREA.
08/09/2019
09:03
AM
08/09/2019
09:03
AM
Day
Search (Areas)
Common Area: VISITING STRIP ROOM.
08/09/2019 09:03 AM 08/09/2019 09:03 AMI Day
Search (Areas)
Common Area: STRIP ROOM.
9 SOUTH SHU
08/09/2019
09:03
AM
08/09/2019
09:03
AM
Day
Search (Areas)
Common Area: STAFF BATHROOM,
06/09/2019
09:03
AM
08/09/2019
09:03
AM
Day
Search (Areas)
Common Area: RECREATION AREA.
08/09/2019
09:03
AM
08/09/2019
09:03
AM
Day
Search (Areas)
Common Area: LAW LIBRARY.
06/09/2019
09:03
AM
08/09/2019
09:03
AM
Day
Search (Areas)
Common Area: LAUNDRY ROOM.
06/09/2019
09:03
AM
08/09/2019
09:03
AM
Day
Rounds (Officer)
Completed.
08/09/2019 09:03 AM 08/09/2013 09:03 AM Day
Fine and Security Check
Completed.
08/09/2019
09:03
AM
08/09/2019
09:02
AM
Day
X Spray Check
Completed. Serviceable.
08/09/2019
09:03
AM
08/09/2019
09:02
AM
Day
Body Alarm Check
Rado Number: 811.
08/09/2019
09:03
AM
08/09/2019
09:02
AMI
Day
Radio Check
Radio Number: 611.
08/09/2019
09:03
AM
08/09/2019
09:02
AMI
Day
Body Alarm Check
Radio Number: 810.
06/09/2019
09:03
AM
08/09/2019
09:02
AM
Day
Radio Check
Rado Number: 810.
08/09/2019
09:03
AM
08/09/2019
09:02
AM
Day
Body Alam Check
Rade Number: 809.
06/09/2019 09:03 AM 08/09/2019 09:02 AM Day
Radio Check
Radio Number: 809.
06/09/2019 09:03 AM 08/09/2019 09:02 AM Day
Key Check
Ring Number: C-32, Count: 7.
Inmate
08/09/2019
09:03
AM
08/09/2019
09:02
AM
Day
Key Check
Ring Number: C-28, Count: 2.
Search
08/09/2019 09:03 AM 08/09/2019 09:02 AM Day
Key Check
Ring Number: C-27, Count: M.
08/09/2019
09:03
AM
08/09/2019
09:02
AM
Day
Fire Alam Panel Check
Completed.
08/09/2019
09:03
AM
08/09/2019
09:02
AM
Day
Inventory Sheet Verified
Completed.
08/09/2019
09:02
AM
08/09/2019
09:02
AM
Day
Census (AM)
Unauthorized Inmates Present 0, Unauthorized Immates Ab
Institution
Shift
06/09/2019
09:01
AM
08/09/2019
08:01
AM
Day
Begin Shift
Completed.
Status
06/09/2019 05:14 AM 08/09/2019 05:13 AM Mom
Rounds (Ueuterant)
Completed PREA. Unit rounds conducted. FIV portal mall.
08/08/2019 11:32 PM 08/08/2019 11:32 PM Even
Watch Call
Completed.
1
TF14688
310 rows
Institution
PROD vl.12
Property
Close
Queue
Help
TRUSC
About
https://10.33.3.57/Dashboard.aspx
8/10/2019
EFTA00019788

=== Page 2 ===
Truscope.Silverlight.Dashboard
Page 1 of 2
NYN 6/11/2018 - 8/11/2019
All 583 All SIS Contraband AT BA
9 SOUTH SHU
Logout
NYM
RolCal
High
Risk
Innute Lists
583t
SIS
Contraband
BAs
UAs
Daily
Adivity
ES
#
New
Inmates
8/7/2019 I 8/11/2019 All Log Events
Currest Base Count: 74
Add Log Event
Extered Date
Event Date
Shalt
Leg Event
Ben
Summary Tut
Count
08/18/2019
UNIT
M
Day
A capray LINCE
- provide VICENSE.
SHU
08/10/2019
09:36
AM
08/10/2013 09:35 AM
Day
Body Alarm Check
Rado Number: 608/609.
08/10/2019
09:36
AM
06/10/2019
09:35
AM
Day
Rado Check
Rado Number: 608/509.
08/10/2019
09:36
AM
08/10/2019
09:35
AM
Day
Cey Check
Ring Number: 29, Count: 3.
08/10/2019 09:36 AMI 08/10/2019 09:35 AM Day
Cay Check
Ring Number: C29, Count: 6.
08/10/2019
09:36
AM
08/10/2019
09:35
AM
Day
Qty Check
Ring Number: C27, Count: 10.
06/10/2019
09:36
AM
08/10/2019
09:35
AN
Day
Key Check
Ring Number: C32, Counts 7.
Housing Unit, Special
08/10/2019
09:36
AM
06/10/2019 09:35 AM
Day
Key Check
Rung Number: 832 Count 4.
(SHU)
08/10/2015
09:36
AM
8/10/2019 09:35 AMI
Day
Fire Alam Panel Check
Completed.
06/10/2019
09:36
AM
08/10/2019 09:35 AM
Day
Inventory Sheet Verified
Completed.
08/10/2019
09:35
AM
08/10/2019 09:17 AM
Day
Rounds (Officer)
Completed.
06/10/2019
09:35
AM
08/10/2019
09:15
AM
Day
Begin Shift
Completed. As per Ops. assumed duties at approx 915am
06/10/2019
05:21
AMI
08/10/2019
05:21
AM
Momin
Rounds (Lieubenant)
Completed - PREA. Unit rounds conducted. PTY portal maili
08/09/2019
08:43
PM
08/09/2019 08:43 PM
Evenie
Search (Acual)
Common Area: VISITING STRIP ROOM.
08/09/2019
08:43
PM
08/09/2019 08:43 PM
Evenin
Search (Areas)
Common Area: STAFF BATHROOM,
9 SOUTH SHU
08/09/2019
08:43
PM
08/09/2019 06:43 PM
Evenin
Search (Areas)
Common Ama: RECREATION AREA.
08/09/2019 08:43 PM
08/09/2019 08:43 PM
Evenin
Search (Areas)
Common Area: LAW LIBRARY,
06/09/2019 08:43 PM
08/09/2019 06:43
Evenin
Search (Areas)
Common Area: LAUNDRY ROOM
08/09/2019 08:42 PM
08/09/2019 08:42 PM
Evenin
Bed Book Check
Completed.
08/09/2019 08:42 PM
08/09/2019 08:42 PM
Evenir
Base Count Verified
74 Base Count: 74.
08/09/2019 08:42 PM
08/09/2019 08:41 PM
Evenin
Change to Base Count In
74 Inmate: GARCIA-PENA, PEDRO.
08/09/2019 08:42 PM
08/09/2019 08:41 PM
Evenir
Visual Search
Inmates 75043054- GARCIA-PENA, PEDRO.
06/09/2019 08:41 PM
06/09/2019 08:40 PM
Evenin
Change to Base Count Out
73 Inmate: 85775054 KERRY. Taken to suicide watch
06/09/2019 08:41 PM
08/09/2019 08:40 PM
Events
Change to Base Count Out
74 Inmates 78640054 WILLIAMS, DAYVON Taken to suidde
08/09/2019
07:57
PM
08/09/2019 07:57 PM
Evenir
Change to Base Count In
75 Inmaber 08765094 - SAXON, JOSEPH. Checked back in to:
08/09/2019
07:31
PM
08/09/2019 07:31 PM
Evenir
Rounds (Lieutenant)
Completed PREA. Act Lt Silva
06/09/2019 06:28 PM
08/09/2019 06:27 PM
Evenir
Change to Base Count Out
74 Inmate: 85609054 - REID, MICHAEL.
08/29/2019 06:28 PM
08/09/2019 06:27 PM
Evenir
Change to Base Count Out
75 Innube: 08765094 SAXON, JOSEPH.
08/09/2019 06:28 PM
08/09/2019 06:27 PM
Evenir
Change to Base Count Out
76 Inmate: 14728055- HEMINGWAY, ANDRE.
Inmate
08/09/2019 05:36 PM
08/09/2019 05:36 PM
Evenir
Rounds (Officer):
Completed. All rounds will be conducted every thirty mind
Search
08/09/2019 05:36 PM
08/09/2019 04:00 PM
Event
Official Count
Clear Count: 75.
08/09/2019 05:35 PM
08/09/2019 05:35 PM
Event
Fire and Security Check
Completed. All appears safe and secure
08/09/2019 05:35 PM
08/09/2019 05:30 PM
Evenir
00 Spray Check
Completed. Serviceable.
06/09/2019 05:35 PM
08/09/2019 05:30 PM
Events
Body Alam Check
Rado Number: 610.
Institution
Shift
08/09/2019 05:35 PM
08/09/2019 05:30 PM
Evenir
Radio Check
Rade Number: 610.
Status
08/09/2019 05:35
PM
08/09/2019 05:30 PM
Evenir
Body Alarm Check
Rade Number: 609.
08/09/2019 05:35 PM
08/09/2019 05:30 PM Even
Radio Check
Radio Number: 609.
4
TF14688
310 rows
institution
PROD 12
Property
Close
Queue
Help
TROSCOPE
About
https://10.3.3.57/Dashboard.aspx
8/10/2019
EFTA00019789


c1: EFTA00018119
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018119.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Mark Steward <Mark.Steward@fca.org.uk>
To:
(USANYS)"
>, Kate Tuckley
<Kate.Tuckley@fca.org.uk>
Cc:
(USANYS)"
>, Kelly Eldred <Kelly.Eldred@fca.org.uk>, Harry Caldecott
<Harry.Caldecott@fca.org.uk>, Kelly Eldred <Kelly.Eldred@fca.org.uk>, Harry Caldecott
<Harry.Caldecott@fca.org.uk>, Kelly Eldred <Kelly.Eldred@fca.org.uk>, Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: RE: Confidential & Urgent
Date: Tue, 03 Dec 2019 18:05:55 +0000
Inline-Images: image001.png; image002.png; image003.png
We've only received the additional material today; it is voluminous which means we won't be in a position
for any meaningful conversation tomorrow. I suspect not before Friday either. Can we pencil in 3-4 pm on
Friday and will confirm on Thursday ?
Cheers
Mark Steward
Executive Director
Enforcement and Market Oversight
FCA
FINANCIAL
CONDUCT
AUTHORITY
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
in
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
From:
(USANYS) [mailto:
Sent: 03 December 2019 17:18
To: Mark Steward <Mark.Steward@fca.org.uk>; Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc: Cowley, Jason (USANYS) <Jason.Cowley@usdoj.gov>;
(USANYS)
>; Kelly
Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott <Harry.Caldecott@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>;
Harry Caldecott <Harry.Caldecott@fca.org.uk>
Subject: RE: Confidential & Urgent
Mark - Hope you had a good weekend and just wanted to circle back on this. Realizing it is starting to get a bit late in the
day in London, would tomorrow morning (New York time) work for a follow up call on this? Perhaps around 10am our
time/3pm in London? If so, we can circulate another dial in.
Thanks,
EFTA00018119

=== Page 2 ===
From: Mark Steward <Mark.Steward@fca.org.uk>
Sent: Thursday, November 28, 2019 12:59 PM
To:
(USANYS)
>; Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc:
>;
(USANYS)
>; Kelly Eldred
<Kelly.Eldred@fca.org.uk>; Harry Caldecott <Harry.Caldecott@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry
Caldecott <Harry.Caldecott@fca.org.uk>
Subject: RE: Confidential & Urgent
Thanks for taking the call today and look forward to speaking again early next week. And happy
Thanksgiving !
Kind regards
Mark Steward
Executive Director
Enforcement and Market Oversight
FCA
FINANCIAL
CONDUCT
AUTHORITY
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
in
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
From:
(USANYS) [mailto:
Sent: 28 November 2019 15:57
To: Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc: Mark Steward <Mark.Steward@fca.org.uk>; Cowley, Jason (USANYS) <Jason.Cowley@usdoj.gov>;
(USANYS)
>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
To allow a few of my colleagues to join, can we instead use a dial in:
Thanks, and talk soon.
Sent from my iPhone
On Nov 28, 2019, at 10:31 AM, Kate Tuckley <Kate.Tuckley@fca.org.uk> wrote:
EFTA00018120

=== Page 3 ===
Great much appreciated thanks
From:
(USANYS) [mailto:
Sent: 28 November 2019 15:30
To: Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc: Mark Steward <Mark.Steward@fca.org.uk>;
is
(USANYS)
>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Okay, please call my cell:
Sent from my iPhone
On Nov 28, 2019, at 10:25 AM, Kate Tuckley <Kate.Tuckley@fca.org.uk> wrote:
Hi
I have spoken to Mark's business support and he is available at 4.15pm (UK time) today (ie in just
under an hour's time). It is quite urgent so if we could speak then it would be greatly appreciated.
If that does work please let us know what number to call you on?
Many thanks
From:
(USANYS) [mailto:
Sent: 28 November 2019 14:53
To: Mark Steward <Mark.Steward@fca.org.uk>
Cc:
;
(USANYS)
>; Kate
Tuckley <Kate.Tuckley@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Hi Mark - Thanks for reaching out. We do have an active investigation and would be happy to talk. As you likely know,
today is a holiday in the US. Is this something we could discuss on Monday or is it more urgent than that? Thanks,
Sent from my iPhone
On Nov 28, 2019, at 9:28 AM, Mark Steward <Mark.Steward@fca.org.uk> wrote:
Dear
/
Can I ask whether this is still an active matter ? if so, I wonder if we could speak
when it is convenient.
Cheers
Mark Steward
Executive Director
Enforcement and Market Oversight
<image001.png>
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
EFTA00018121

=== Page 4 ===
Follow us:
<image002.png>
<image003.png>
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
From:
Sent: 28 November 2019 14:25
To: Mark Steward <Mark.Steward@fca.org.uk>;
(USANYS)
is
(USANYS)
Cc: Kate Tuckley <Kate.Tuckley@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Looping in
They run our
unit and oversee the Epstein case.
Sent from my iPhone
On Nov 28, 2019, at 8:30 AM, Mark Steward <Mark.Steward@fca.org.uk> wrote:
Hi
Can you let me know, urgently, whether anyone in your office is handling the investigation into
Jeffery Epstein, especially anything in relation to JP Morgan (he was a client of their private wealth
division) and, if so, who, as we need to have a chat. If this is not in SDNY, do you know who is
handling ongoing work into Mr E's world ?
Cheers
Mark Steward
Executive Director
Enforcement and Market Oversight
<image001.png>
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
<image002.png>
<image003.png>
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
This communication and any attachments may contain personal information. For more information about how and
why we use personal information and who to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
EFTA00018122

=== Page 5 ===
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have received
this email in error please notify postmaster@fca.org.uk immediately and delete the email from your computer.
Further information on the classification and handling of FCA information can be found on the FCA website
(http://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how and
why we use personal information and who to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have received this
email in error please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further
information on the classification and handling of FCA information can be found on the FCA website
(http://www.fca.org.uk/site-info/legal/fca-classified-information)
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
EFTA00018123

=== Page 6 ===
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how and
why we use personal information and who to contact with any queries about this, please see our privacy notices: FCA
Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-
privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish,
rely on or otherwise use it without our consent. Some of our communications may contain confidential information
which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error
please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further information on
the classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-
info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email
has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how and why
we use personal information and who to contact with any queries about this, please see our privacy notices: FCA Privacy
Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-privacy-and-
data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish,
rely on or otherwise use it without our consent. Some of our communications may contain confidential information
which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error
please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further information on the
classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-
info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email
has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
EFTA00018124

=== Page 7 ===
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623. Registered
office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how
and why we use personal information and who to contact with any queries about this, please see our privacy
notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have
received this email in error please notify postmaster@fca.org.uk immediately and delete the email from your
computer. Further information on the classification and handling of FCA information can be found on the FCA
website (http://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the
Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all
email communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how
and why we use personal information and who to contact with any queries about this, please see our privacy
notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have
received this email in error please notify postmaster@fca.org.uk immediately and delete the email from your
computer. Further information on the classification and handling of FCA information can be found on the FCA
website (http://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the
EFTA00018125

=== Page 8 ===
Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all
email communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
EFTA00018126


c1: EFTA00019759
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019759.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
OF
SPARTMENT OF JUSTICE
U.S. Department of Justice
Federal Bureau of Prisons
REAU
Metropolitan Correctional Center
New York, New York
For Immediate Release
Contact: Lee Plourde
August 10, 2019
Public Information Officer
(646) 836-6300
Inmate Death at the MCC New York
New York, NY: On Saturday, August 10, 2019, at approximately 6:30 a.m., inmate Jeffrey
Edward Epstein was found unresponsive in his cell in the Special Housing Unit from an apparent
suicide at the Metropolitan Correctional Center (MCC) in New York, New York. Life-saving
measures were initiated immediately by responding staff. Staff requested emergency medical
services (EMS) and life-saving efforts continued. Mr. Epstein was transported by EMS to a local
hospital for treatment of life-threatening injuries, and subsequently pronounced dead by hospital
staff. The FBI is investigating the incident.
Mr. Epstein was a 66-year-old male who arrived at MCC New York on July 6, 2019 under
pretrial status after being indicted for sex trafficking of minors and conspiracy.
MCC New York is an Administrative security facility that currently houses 763 male offenders
in New York, New York.
Additional information about the Federal Bureau of Prisons can be found at www.bop.gov.
###
EFTA00019759


c1: EFTA00020443
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020443.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: Call with FCA (Epstein)
Date: Wed, 04 Dec 2019 23:58:28 +0000
Importance: Normal
Attachments: unnamed
EFTA00020443


c1: EFTA00019338
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019338.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: USVI search warrant
Date: Sat, 10 Aug 2019 22:24:54 +0000
Attachments: USVI_SW.v6.docx
Attached for your review is the search warrant application for the upcoming search.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019338


c1: EFTA00018578
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018578.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:20-cr-00330-AJN Document 39 Filed 08/10/20 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
AFFIDAVIT OF CERTIFICATION
V.
PURSUANT TO LOCAL
:
:
CRIMINAL RULE 16.1
GHISLAINE MAXWELL,
:
:
Defendant.
20 Cr. 330 (AJN)
:
:
X
I, Christian R. Everdell, an attorney duly admitted to practice in New York State and
before this Court, declare the following is true and correct under penalty of perjury pursuant to
28 U.S.C. $ 1746:
1.
I am a partner at Cohen & Gresser LLP, counsel for defendant Ghislaine Maxwell
in the above-captioned case.
2.
I certify pursuant to Local Criminal Rule 16.1 that defense counsel has conferred
in good faith with Assistant U.S. Attorneys
, and
regarding the defense's request for the disclosure of the
identities of Victims 1-3 referenced in the indictment, subject to the restrictions of
the protective order entered by the Court. The government did not agree to the
request, and instead indicated that it would disclose the identities of Victims 1-3
through its production of Rule 16 discovery, or as part of its production of Jencks
Act material closer to trial.
EFTA00018578

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 39 Filed 08/10/20 Page 2 of 2
I hereby certify that the foregoing statements made by me are true. I am aware that if any of the
foregoing statements are willfully false, I am subject to punishment.
Dated: August 10, 2020
/s/ Christian R. Everdell
New York, New York
Christian R. Everdell
COHEN & GRESSER LLP
New York, New York 10022
Phone:
2
EFTA00018579


c1: EFTA00018380
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018380.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject:
Date: Thu, 04 Nov 2021 03:50:42 +0000
Attachments: 2021.11.03_Maxwell_RTC_[unredacted].docx,2021.11.03_Maxwell_verdict_sheet.docx
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00018380


c1: EFTA00018855
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018855.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS) [Contractor]"
To:
(USANYS)"
)"
Cc:
USANYS) [Contractor]"
Subject: GX from
Date: Tue, 28 Sep 2021 22:45:21 +0000
Importance: Normal
I mentioned this to
earlier, I don't think we ever specified the files we pulled for
GX following our call
with her before she went on leave. Below is a list of the exhibits we pulled and their location on the shared for your
reference.
Thanks,
Faceplates/People Photos:
Epstein (from photobook)
Maxwell (from photobook)
(from photobook)
from photobook)
(from group photo)
Included group photo as one exhibit and close up cropped image of just CA as another
PB search warrant photos, video of search, property receipts:
Photos of places (subsequently added GM London townhouse photo):
FedEx records:
Flight records:
AT&T records:
deposition and
sworn statement:
Mar-A-Lago records:
Maps:
Paralegal Specialist
U.S. Attorney's Office
SDNY
New York, NY 10007
EFTA00018855

=== Page 2 ===
Office: (
Cell:
EFTA00018856


c1: EFTA00019511
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019511.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
)"
Cc:
)"
) (FBI)"
Subject: Re: Epstein
Date: Mon, 10 Dec 2018 19:05:24 +0000
Attachments:
search.pdf
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
Sent: Monday, December 10, 2018 2:03:53 PM
To:
Cc:
);
) (FBI);
Subject: Re: Epstein
More Epstein reports
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
,
Sent: Monday, December 10, 2018 1:54:43 PM
To:
)
Cc:
);
) (FBI);
Subject: Re: Epstein
See attached SOMU records.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
^
Sent: Monday, December 10, 2018 12:47:40 PM
EFTA00019511

=== Page 2 ===
To:
Cc:
);
) (FBI);
Subject: Re: Epstein
Can we chat after 2? Otherwise go ahead without me and
will catch me up.
you are going to have to change your
name!
Sent from my iPhone
On Dec 10, 2018, at 12:46 PM,
<mailto:
,
wrote:
We are available now if you would like to call but I am on the road so you will have to conference us in separately.
On Dec 10, 2018, at 12:12,
)
<mailto:
wrote:
and
Any chance you're free for a brief call this afternoon? We wanted to touch base about a few items. I'm sure you're both
very busy in preparation for Wednesday, so we promise to keep it short.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
EFTA00019512


c1: EFTA00019449
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019449.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: US V. Maxwell, 20 Cr. 330 (AJN)
Date: Sat, 20 Nov 2021 04:35:55 +0000
Attachments: 2021.11.18_Voir_Dire_[proposed_redactions].pdf
2021.11.16_Voir_Dire_[proposed_redactions].pdf;,
2021.11.17_Voir_Dire_[proposed_redactions].pdf
Chambers,
Attached please find proposed redactions to the transcripts of voir dire.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00019449


c1: EFTA00018209
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018209.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: [EXTERNAL] US V Maxwell 20 Cr 330 11/16/21
Date: Wed, 17 Nov 2021 00:53:48 +0000
Attachments: XLBG1MAXVDF.pdf
EFTA00018209


c1: EFTA00019028
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019028.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Subject: RE: Judge Rules on Redactions to Filing in Ghislaine Maxwell Case
Date: Fri, 19 Mar 2021 02:22:47 +0000
Haha, so ridiculous! I'm assuming AJN didn't realize that those portions are in our indictment. But if she wants
them redacted, that's fine.
Original Message
From:
)
Sent: Thursday, March 18, 2021 10:21 PM
To:
Subject: RE: Judge Rules on Redactions to Filing in Ghislaine Maxwell Case
Thanks! Saw on the Google alert.
(The "sensational and impure" details are the sentences in our indictment...)
Original Message
From:
)
Sent: Thursday, March 18, 2021 10:20 PM
To:
)
Subject: FW: Judge Rules on Redactions to Filing in Ghislaine Maxwell Case
FYI
Original Message
From:
(USANYS)
Sent: Thursday, March 18, 2021 9:42 PM
To:
)
(USANYS)
Cc:
(USANYS) [Contractor]
Subject: Judge Rules on Redactions to Filing in Ghislaine Maxwell Case
https://lawandcrime.com/high-profile/judge-rules-some-ghislaine-maxwel-details-are-too-sensational-and-
impure-to-be-revealed-to-the-public/
Sent from my iPhone
EFTA00019028


c1: EFTA00020444
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020444.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Call with FCA (Epstein)
Start Date: 2019-12-10 15:00:00 +0000
End Date: 2019-12-10 15:30:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Date Created: 2019-12-05 00:09:43 +0000
Date Modified: 2019-12-05 00:09:43 +0000
Priority: 5
DTSTAMP: 2019-12-04 23:58:26 +0000
Attendee:
(USANYS)
Alarm: Display the following message 15m before start
I
Reminder
EFTA00020444


c1: EFTA00019435
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019435.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
)"
Subject: FW:
Date: Wed, 05 Dec 2018 15:35:23 +0000
Importance: Normal
FYI
From:
Sent: Friday, November 30, 2018 4:02 PM
To:
)
Subject: FW:
From:
Sent: Tuesday, March 8, 2016 12:28 PM
To:
Subject: RE:
,
If you haven't already seen it, the Post reported today on Jeffrey Epstein's continued relationships with young
women.
http://pagesix.com/2016/03/08/jeffrey-epsteins-east-side-mansion-houses-russian-playmates/
Best,
From:
Sent: Monday, February 29, 2016 10:13 PM
To:
Cc:
Subject: Re:
I am adding
to this email chain as well. As we mentioned earlier today,
is one of the lead attorneys on
the case and knows both
and the facts very well. Please include
in any follow-up that you may.
Best,
EFTA00019435

=== Page 2 ===
From:
Date: Monday, February 29, 2016 at 10:03 PM
To:
Cc:
Subject:
Thank you again for meeting with us today. We very much appreciate your time. I am attaching the following documents for
your review:
1. Complaint in the defamation case against Ghislaine Maxwell (just today, Judge Sweet denied Maxwell's motion to dismiss
today);
2. Declarations that
filed in the CVRA case;
3. The Rule 56.1 statement recently filed in the CVRA case;
4. The redacted 302
Please let us know what other information we can provide or if you have any further questions.
Best,
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1]
EFTA00019436


c1: EFTA00019847
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019847.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Tags for US V. Epstein Relativity Database
Date: Wed, 23 Sep 2020 17:12:46 +0000
Works for me
From:
Sent: Wednesday, September 23, 2020 1:12 PM
To:
is
Subject: RE: Tags for US V. Epstein Relativity Database
Yep, thanks.
From:
Sent: Wednesday, September 23, 2020 12:53 PM
To:
is
Subject: FW: Tags for US V. Epstein Relativity Database
I logged into Relativity and this looks right to me. Are you guys free at 4 to discuss reviewing batches to make sure
everyone is on the same page? Thanks.
From:
Sent: Wednesday, September 23, 2020 12:48 PM
To:
Cc:
is
is
Subject: RE: Tags for US V. Epstein Relativity Database
Good Morning,
The tags have been created in the database under issue designation field. The batches have been created and you can
check out the batches as you see fit. Please let me know if there are any questions.
Thank you.
From:
Sent: Sunday, September 20, 2020 6:04 PM
To:
Cc:
is
>;
Subject: Tags for US V. Epstein Relativity Database
Hi
We would like to use several tags as we conduct our review of documents in the "US V Epstein" database on Relativity.
For that database, would you please help us create the below tags?
EFTA00019847

=== Page 2 ===
Reviewed
Witness Statement
Produce As Is
Produce With Redactions
Produce As Confidential
Produce As Highly Confidential
Work Product (Do Not Produce)
Potential Brady
Hot Doc
For Further Review
Tech Issue
Please let me know if you have any questions or would like to discuss.
Thanks very much,
EFTA00019848


c1: EFTA00020088
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020088.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe V. Indyke
et al., SDNY Case No. 1:20-cv-00484-JGK-DCF
Date: Tue, 09 Jun 2020 03:51:05 +0000
Importance: High
Attachments: _8_20_Ltr_re_Jane_Doe_Touhy_request.pdf
Hi all,
Will you be able to gather the responsive documents for Glassman's request, as with the request from Kaplan? Except for
Item 8, this request seems fairly contained-and they have expressly cabined their request to not seek documents that
would interfere with ongoing proceedings. Please let me know if we need to discuss. Otherwise, I'll draft a letter once we
have the docs gathered (happy to do redactions again if helpful).
Thanks,
From: Robert Glassman
Sent: Monday, June 8, 2020 3:08 PM
To:
Cc:
>; Nathan Werksman
>; Keilah
Betts
Subject: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe V. Indyke et al., SDNY Case No. 1:20-
cv-00484-JGK-DCF
Importance: High
Dear Mr.
Please see the attached letter of today's date. A copy will also be sent via Fedex. Thank you.
Robert Glassman
Robert Glassman, Esq.
Panish Shea & Boyle LLP
Email:
Web: www.psblaw.com
CONFIDENTIALITY NOTICE:
This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution
or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please
contact the sender by reply e-mail or telephone, and delete all copies of this message.
If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the
full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have
signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for
your case or potential case.
EFTA00020088

=== Page 2 ===
EFTA00020089


c1: EFTA00018614
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018614.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Subject: Application for Search Warrant
Date: Tue, 27 Oct 2020 13:18:10 +0000
Good morning,
Attached for Judge Wang's consideration please find an application for the issuance of a search warrant, the four exhibits
referenced in that application, and a proposed search warrant.
The agent is available this afternoon and tomorrow morning to swear out the warrant. I can be reached by email or on
my cellphone at
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00018614


c1: EFTA00018162
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018162.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "Berman, Geoffrey (USANYS)"
To:
)"
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
)"
)"
Subject: Re: updates
Date: Sat, 06 Jul 2019 15:48:31 +0000
Importance: Normal
Thanks for the updates. 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
EFTA00018162


c1: EFTA00019343
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019343.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: MCC/Epstein Meeting
Date: Wed, 14 Aug 2019 17:13:56 +0000
Hey guys,
Geoff would like to meet 12-2pm tomorrow after the MCC visit with the brass, you two, the MCC team, and the folks
visiting from main justice/FBI/IG
(
etc.)
We'll be in the 8th floor library.
Thanks!
EFTA00019343


c1: EFTA00019896
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019896.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Christian Everdell
To:
"
Cc:
N
)"
(USANYS)"
"Mark S. Cohen"
"BOBBI C STERNHEIM"
Jeff Pagliuca
Laura Menninger
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Letter re Sealing of Renewed Bail Motion
(to be Filed Under Seal)
Date: Wed, 25 Nov 2020 19:11:59 +0000
Attachments: 2020.11.25_Letter_to_Judge_Nathan_re_Sealing_of_Renewed_Bail_Motion.PDF
Inline-Images: image005.jpg; image006.jpg
Dear Judge Nathan -
Please see the attached letter to be filed under seal and submitted to the Court and all counsel pursuant to Section 2(B) of
Your Honor's Individual Practices in Criminal Cases.
Regards,
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
GG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00019896


c1: EFTA00017803
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017803.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
(USANYS)"
Subject: FW: New document:
V. Maxwell (Doc# -, 2d Cir.
)
Date: Fri, 21 Aug 2020 03:36:28 +0000
Attachments: 2020-08-20_[-000]_BRIEF_on_behalf_of_Appellant_Ghislaine_Maxwell,_FILED.pdf
Inline-Images: image001.jpg
FYI. In this brief, Maxwell's attorneys state that if Judge Nathan denies their motion to modify the protective order, they
will appeal to the Second Circuit and seek consolidation of that appeal with the appeal from Judge Preska's order.
From: Sigrid McCawley
Sent: Thursday, August 20, 2020 8:27 PM
To:
is
is
Subject: FW: New document:
V. Maxwell (Doc# , 2d Cir. 20-02413)
Please see attached.
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
(t)
(m)
www.bsfllp.com
From: ECFdocuments@pacerpro.com [mailto:ECFdocuments@pacerpro.com]
Sent: Thursday, August 20, 2020 8:07 PM
To: Sigrid McCawley
>; ; Deborah Knowlton
Subject: New document:
V. Maxwell (Doc# , 2d Cir.
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
V. Maxwell
Docket entry number:
BRIEF, on behalf of Appellant Ghislaine Maxwell, FILED. Service date 08/20/2020
by CM/ECF, US mail.[2913550] [20-2413]
EFTA00017803

=== Page 2 ===
Date entered: 2020-08-20
VIEW CASE
https://app.pacerpro.com/cases 13420037
Sent from PacerPro, the fastest and most insightful way to access federal court records.
Questions? sales@pacerpro.com or (415) 890-4958
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
EFTA00017804


c1: EFTA00020173
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020173.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Western Union Financial Services, Inc.
Attn: Custodian of Records
12500 E. Belford Ave, M21A2
Englewood, CO 80112
Phone Number: 866-628-5067
Delivered via: Email
The following are the items that are required to be provided by the attached Subpoena:
For the period of inception thru today, any and all available information regarding money transfers, the
purchase of money orders, including but not limited to, sender's name and address, location of purchase
including name and address of selling agent, form of payment used to purchase money orders, amount
of money orders purchased, date and time of purchase, the payee's name and address, the amount and
currency distributed.
Please utilize the following identifiers:
NAMES/ENTITIES
DOB
SSN
ADDRESS
PHONE
EMAIL
If you have any questions or comments, please contact
Forensic Accountant, at
EFTA00020173


c1: EFTA00018099
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018099.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
> On Jan 16, 2020, at 9:48 PM,
wrote:
>
> Hi
- I assume, given the news coverage, that your team and the executives have seen the lawsuit filed by
the Virgin Islands government against Epstein's estate, the 1953 Trust, and various entities (which seeks, among
other relief, to void the fraudulent transfer of assets to the trust)? If not, let me know and I can circulate the
complaint and more detail to the broader group.
V V V V
EFTA00018099


c1: EFTA00019835
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019835.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Accepted: Jason Mojica Proffer (Ordered) (re Epstein)
Date: Wed, 04 Sep 2019 16:06:18 +0000
Importance: Normal
Attachments: unnamed
EFTA00019835


c1: EFTA00018110
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018110.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Mark Steward <Mark.Steward@fca.org.uk>
To:
(USANYS)"
(USANYS)"
Cc: Kate Tuckley <Kate.Tuckley@fca.org.uk>, Kelly Eldred <Kelly.Eldred@fca.org.uk>, Harry
Caldecott <Harry.Caldecott@fca.org.uk>, Kelly Eldred <Kelly.Eldred@fca.org.uk>, Harry
Caldecott <Harry.Caldecott@fca.org.uk>
Subject: RE: Confidential & Urgent
Date: Thu, 28 Nov 2019 14:28:20 +0000
Inline-Images: image001.png; image002.png; image003.png
,
Can I ask whether this is still an active matter ? if so, I wonder if we could speak
when it is convenient.
Cheers
Mark Steward
Executive Director
Enforcement and Market Oversight
FCA
FINANCIAL
CONDUCT
AUTHORITY
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
in
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
From:
Sent: 28 November 2019 14:25
To: Mark Steward <Mark.Steward@fca.org.uk>;
(USANYS)
is
(USANYS)
Cc: Kate Tuckley <Kate.Tuckley@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Looping in
They run our
unit and oversee the Epstein case.
Sent from my iPhone
On Nov 28, 2019, at 8:30 AM, Mark Steward <Mark.Steward@fca.org.uk> wrote:
Hi
EFTA00018110

=== Page 2 ===
Can you let me know, urgently, whether anyone in your office is handling the investigation into Jeffery
Epstein, especially anything in relation to JP Morgan (he was a client of their private wealth division) and,
if so, who, as we need to have a chat. If this is not in SDNY, do you know who is handling ongoing work
into Mr E's world ?
Cheers
Mark Steward
Executive Director
Enforcement and Market Oversight
<image001.png>
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
in
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
This communication and any attachments may contain personal information. For more information about how and why
we use personal information and who to contact with any queries about this, please see our privacy notices: FCA Privacy
Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-privacy-and-
data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish,
rely on or otherwise use it without our consent. Some of our communications may contain confidential information
which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error
please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further information on the
classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-
info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email
has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623. Registered
office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how
EFTA00018111

=== Page 3 ===
and why we use personal information and who to contact with any queries about this, please see our privacy
notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have
received this email in error please notify postmaster@fca.org.uk immediately and delete the email from your
computer. Further information on the classification and handling of FCA information can be found on the FCA
website (http://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the
Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all
email communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
EFTA00018112


c1: EFTA00019750
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019750.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 15, 2019
Bank of America N.A.
Legal Order Processing
Christiana IV
800 Samoset Drive
Newark, DE 19713
Mail code DE5-024-02-08
Re:
Grand Jury Subpoena
Please be advised that the accompanying grand jury subpoena has been issued in
connection with an official criminal investigation of a suspected felony being conducted by a
federal grand jury. The Government hereby requests that you voluntarily refrain from disclosing
the existence of the subpoena to any third party. While you are under no obligation to comply
with our request, we are requesting you not to make any disclosure in order to preserve the
confidentiality of the investigation and because disclosure of the existence of this investigation
might interfere with and impede the investigation.
Thank you for your cooperation in this matter.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
EFTA00019750

=== Page 2 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Bank of America N.A.
Legal Order Processing
Christiana IV
800 Samoset Drive
Newark, DE 19713
Mail code DE5-024-02-08
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:
October 29, 2019
Appearance Time: 10 a.m.
to testify and give evidence in regard to alleged violations of federal criminal law, including:
18 U.S.C. §§ 1591, 1594(c), 2422(b), 371
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:
SEE ATTACHED RIDER. Personal appearance is not required if the requested records are (1)
produced by on or before the return date to Special Agent
Federal Bureau of
Investigation, 26 Federal Plaza, New York, NY 10278, telephone
and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. Please
contact
with any questions.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
October 15, 2019
Gilby
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
DEPARTMENT UNITED COURT
RICT FOR THE YORK
EFTA00019751

=== Page 3 ===
RIDER
(Grand Jury Subpoena to Bank of America, dated October 15, 2019) I
Please provide from account inception to the present any and all records pertaining to the following
accounts(s)/organization(s)/individuals(s), whether held jointly or severally or as trustee or
fiduciary as well as custodian, executor, or guardian. Please provide all images of documents in
Adobe PDF files on CDs.
A. Please use the following identifiers:
NAMES/ENTITIES
AKA:
DOB
SSN
ADDRESS
PHONE
EMAIL
ACCOUNT NUMBER
B. Records to be produced should include but are not limited to the items listed below:
1. Documents (checks, debit memos, cash in tickets, wires in, wires out, etc.) reflecting
additions and/or subtractions to the account and how the account balances are being satisfied
on a monthly basis;
2. Signature cards;
3. Proof of identification (including but not limited to copies of identification used to open the
account);
4. Location of withdrawals
3
EFTA00019752

=== Page 4 ===
5. Opening account(s) documents with attachments, including any and all applications, internal
documents generated to open account(s), and identification information or other
documentation provided by Customer;
6. "Know your customer" documentation;
7. Wire transfer records (incoming and outgoing, and any and all applications and instructions);
8. Safe deposit records, including applications, signature cards, and sign-in records;
9. Trust accounts;
10. Monthly statements;
11. Credit card statements;
12. Bank, travelers, or cashier checks drawn on account or purchased with an account check;
13. Prepaid debit cards, certified checks, cashiers' checks, money orders, and traveler's checks;
14. Loan, lease, and/or mortgage application files (whether granted or denied) including credit
reports, applications, and payments made on loans;
15. Any and all corporate resolutions, certifications of incorporation, business certificates and/or
partnership agreements;
16. Online banking information- All information regarding the electronic use of banking systems
to include the following: username, registration IP address, online account creation date,
online account status and IP logs/history, MAC addresses and online session times and
duration; and
17. Any and all correspondence, electronic or otherwise, including memoranda, emails and text
messages, that reference or concern items (1) through (16), above, and/or any financial
interests involving the individuals and/or entities identified in Section A.
N.B.: Personal appearance is not required if the requested records are (1) produced by on or
before the return date to Special Agent
, Federal Bureau of Investigation, 26
Federal Plaza, New York, NY 10278, telephone
and (2)
accompanied by an executed copy of the attached Declaration of Custodian of Records.
PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE.
Please contact Forensic Accountant
with any questions.
IMPORTANT: REQUEST FOR NON-DISCLOSURE
Due to the ongoing nature of the investigation, it is requested that you do not
disclose any information relating to this Grand Jury subpoena request to any third party.
4
EFTA00019753

=== Page 5 ===
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 October 15, 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.
EFTA00019754


c1: EFTA00019331
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019331.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
"
ANYS)"
(USANYS)"
"
(USANYS)"
Subject: Meeting re MCC/Epstein
Date: Tue, 13 Aug 2019 12:05:14 +0000
Importance: Normal
Attachments: unnamed
EFTA00019331


c1: EFTA00018571
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018571.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: GM Recent Letters
Date: Tue, 11 Aug 2020 15:31:31 +0000
Attachments:2020-08-10_GM,_defense_motion_for_victim_identities_and_prison_privileges:pdf;2020-
08-10,_GM,_defense_affidavit_re_victim_identities_and_prison_privileges,pdf,2020-08-
10_[01100-000]_LETTER_addressed_to_Judge_Loretta_A._Preska_from_..pd
letter_to_USA_re_protective_order_(002)_002)final.pdf
Per your request, attached are the recent letters we received. Judge Nathan gave us until Thursday to respond (and any
reply Monday). We are meeting with the team later today to discuss.
EFTA00018571


c1: EFTA00018903
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018903.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
(USANYS)"
Subject: Fwd: Epstein Probate
Date: Sun, 08 Dec 2019 15:37:13 +0000
Attachments: 11.14.2019.001_Expedited_Motion_for_the_Establishment_of_Voluntary_Claims.pdf;
ATT00001.htm
See below. Did you guys connect with her after this on the sharing order? If not, let's set up a call tomorrow.
Sent from my iPhone
Begin forwarded message:
From:
(USANYS)"
Date: December 2, 2019 at 3:17:15 PM EST
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Epstein Probate
Hi
The U.S. Virgin Islands court has recently posted on its website the petition that was filed in the Epstein probate
proceedings seeking establishment of a victim claims fund. The petition seeks "expedited approval" from the court to
establish the fund, though no timeline is specified. (It is attached, if of interest.) If approved, estate assets would be
used to pay for administering the fund, and deadlines would be set for victims to file their claims if they wish to
participate.
There was over a week's delay between when the petition was filed with the court and when the court posted the
petition on its public page for "cases of interest." That page is not an official case docket, though it has at least select
filings from the probate case (though I cannot tell if all filings are being posted). It would obviously be preferable if we
had contemporaneous access to a complete docket, but we haven't been able to find a way to access an online
complete docket. We're inclined to call the Virgin Islands court to ask whether there's a way to access a full electronic
docket, but we wanted to check whether you have concerns before we do so (we doubt we would need to identify
ourselves). Let us know your thoughts.
Relatedly, what's the status of the 6(e) order?
Thanks,
Assistant United States Attorney
86 Chambers Street, 3rd Floor
New York, NY 10007
Tel.:
Fax:
EFTA00018903

=== Page 2 ===
EFTA00018904


c1: EFTA00017871
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017871.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
(USANYS)"
(USANYS) [Contractor]"
Subject: ttps://www.nytimes.com/2019/11/19/nyregion/epstein-prison-guards-arrested.html?smid=nytcore-
ios-share
Date: Tue, 19 Nov 2019 14:05:06 +0000
Times reporting both in custody.
Sent from my iPhone
EFTA00017871


c1: EFTA00019215
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019215.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: United States V. Ghislaine Maxwell
Date: Sun, 28 Nov 2021 16:00:58 +0000
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
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019215


c1: EFTA00017955
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017955.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
BUT
STATES
U.S. Department of Justice
United States Attorney
Southern District of New York
United States Courthouse
300 Quarropas Street
White Plains, New York 10601
December 19, 2019
BY ECF
The Honorable Kenneth M. Karas
United States District Judge
Southern District of New York
300 Quarropas Street
White Plains, NY 10601
Re:
United States V. Nicholas Tartaglione, S4 16 Cr. 832 (KMK)
Dear Judge Karas:
The Government respectfully submits this letter to update the Court regarding the defense's
request for certain video footage from inside the Metropolitan Correctional Center ("MCC") on
July 22 - July 23, 2019 (the "Video"). Earlier today, the Government confirmed with MCC staff
that the Video was preserved by MCC staff upon defense counsel's request in July 2019, and the
Government is in the process of obtaining a copy of the Video from the MCC. Once the
Government obtains a copy of the Video, the Government intends to make it available for defense
counsel's review at the United States Attorney's Office.
Respectfully submitted,
GEOFFREY S. BERMAN
United States Attorney
By:
/s/
Assistant United States Attorneys
Cc:
Counsel of record (by ECF)
EFTA00017955


c1: EFTA00019911
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019911.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: FW:
Emails
Date: Sun, 15 Dec 2019 19:32:10 +0000
Attachments: 2008-09-03_Convo_with_Epstein.pdf; 2008-09-
03 hear had a of bother.pdf; 2009-07-
22_Email_from_Jeffrey_Epstein.pdf; 2010-06-29 Meeting Jeffrey Epstein.pdf; 2010-06-
29_where_are_u.pdf,2010-9-
; 2010-10-
23_Email_from_Jeffrey_Epstein.pdf 2011-05-09_Email_to_JE_NYC.pdf; 2012-10-
3_Call_Jeffrey_Epstein.pdf
Inline-Images: image001.png
could you please create a folder for "Emails" in the
folder in the Epstein share drive and save
the attached emails there? Thanks very much.
From:
Sent: Saturday, December 14, 2019 18:13
To:
Cc
Subject:
Emails
I have attached the emails provided by
Hope everyone is doing well,
ГД
EDWARDS
POTTINGER LLC
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
EFTA00019911


c1: EFTA00019849
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019849.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Nicole Simmons
To: "newcases@ca2.uscourts.gov" <newcases@ca2.uscourts.gov>
Cc:
Subject:
V. Maxwell Case No. . 20-2413 and US V. Maxwell Case No. 20-3061, [Unredacted
Document]
Date: Wed, 23 Sep 2020 18:54:59 +0000
Attachments: 2020.09.23_Reponse_to_Govt_Opp_to_Mot_to_Consolidate_(Unredacted).pdf
Inline-Images: image001.jpg
To Whom It May Concern:
At the request of
please see attached the Unredacted version of the document filed today in the above
referenced matters. Please let me know if you have any questions or concerns.
Regards,
Nicole
Denver, Colorado
80203
www.hmflaw.com
EFTA00019849


c1: EFTA00020340
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020340.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
"
)"
Subject: FW: Anonymous Civilian Crime Report Related to Human Trafficking
Date: Wed, 19 Aug 2020 20:44:46 +0000
Attachments:08_19_2020_About_People_Involved_in_Child_trafficking.pdf
From:
Sent: Wednesday, August 19, 2020 4:04 PM
To:
Cc:
Subject: Anonymous Civilian Crime Report Related to Human Trafficking
Attached is a Civilian Crime Report for you to review. Because it is anonymous, we do
nothing more. If interested, feel free to forward to an Agency.
EFTA00020340


c1: EFTA00017768
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017768.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
,
:
ov>
Cc: Christian Everdell
"Mark S. Cohen"
)"
)"
Subject: Pretrial Interview - Ghislaine Maxwell
Date: Mon, 06 Jul 2020 17:32:08 +0000
Good afternoon,
Copied on this email are Chris Everdell and Mark Cohen, two attorneys representing defendant Ghislaine Maxwell in case
number 20 Cr. 330 (AJN). Please let them know how they can arrange for a pretrial interview with their client in advance
of her bail hearing this week.
If you need any additional information, please do not hesitate to contact me.
Thank you,
Maurene
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00017768


c1: EFTA00019898
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019898.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
[Contractor]"
Cc:
)"
(USANYS)"
[Contractor]"
Subject: Copy of production from PAE
Date: Tue, 17 Nov 2020 18:41:38 +0000
Hi
Following up on our phone call just now, I'm writing to confirm that PAE will make a new copy of the 1.2 million document
production that they already copied onto the 2 defense drives last week. I understand that you will coordinate to get PAE
a drive on which to load this copy. Would you please ask PAE to send the drive to
again?
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00019898


c1: EFTA00018033
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018033.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Joe Nascimento
To:
)"
Cc:
(USANYS)"
)"
Subject: Re:
)
- Epstein
Date: Tue, 03 Aug 2021 17:44:28 +0000
3:30 works for me. My cell would be best:
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: Tuesday, August 3, 2021 at 12:28 PM
To: Joe Nascimento
Cc:
(USANYS)"
i
)"
Subject: RE:
)
- Epstein
Thanks very much, would 3:30 p.m. work for you? I can plan to call your office line, but please let me know if a different
number is better today. Thanks.
From: Joe Nascimento
Sent: Tuesday, August 3, 2021 10:03 AM
To:
Cc:
(USANYS)
is
)
Subject: Re:
)
- Epstein
Of course, what time works best for you?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
EFTA00018033

=== Page 2 ===
e.
www.crimlawfirm.com
On Aug 3, 2021, at 10:02 AM,
)
wrote:
Hi Joe,
Hope you're doing well. Are you available for a brief call this afternoon?
Thanks,
From: Joe Nascimento
Sent: Monday, April 26, 2021 9:53 AM
To:
Cc:
(USANYS)
y.
)
Subject: Re:
)
- Epstein
Perfect, I received the invite with the link. Unfortunately (or fortunately sometimes) WebEx has been a part a
daily part of my life the past year, so we should be OK. See you all then, let me know if you need anything
further from us in the meantime.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Apr 26, 2021, at 9:31 AM,
)
wrote:
Hi Joe,
Thanks very much. Let's plan for May 14th at 12 p.m., if that works for you. I'll send a WebEx link for the
videoconference shortly. Please let us know if you have any tech issues/questions about WebEx.
Thanks,
EFTA00018034

=== Page 3 ===
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
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)
i
)
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
,
EFTA00018035

=== Page 4 ===
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
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
EFTA00018036

=== Page 5 ===
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
From:
)
Date: Monday, March 8, 2021 at 1:32 PM
To: Joe Nascimento
Cc:
)
)
Subject: RE:
)
- Epstein
Hi Joe,
Thanks, hope all is well with you. We're free for a call at 10:30 tomorrow morning, would that work for you?
Thanks,
From: Joe Nascimento
Sent: Monday, March 8, 2021 1:24 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
,
I hope you are well. Please let me know if you have 5 min for a quick call.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
EFTA00018037

=== Page 6 ===
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 we
hope your client recovers well (and congratulations).
All the best,
From: Joe Nascimento
Sent: Thursday, July 2, 2020 11:07 AM
To:
Cc:
>;
-
Subject: Re:
- Epstein
Good morning,
Hope you are all well. Just wanted to check in after seeing the reports of Ghislaine's arrest.
If you need anything
from us, let us know.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
EFTA00018038

=== Page 7 ===
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:
>;
)
Subject: Re:
- Epstein
We really appreciate this email. I was able to speak with
a few weeks ago and gave the green light to share
name and information provided with anyone necessary in your investigation. We will wait to hear from
you if you need anything further.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Monday, February 17, 2020 at 3:40 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Joe,
We just wanted to check in very briefly-we had been hopeful that we'd be able to circle back with you earlier,
but our investigation is currently still ongoing, so at the very least we wanted to let you know that we continue to
EFTA00018039

=== Page 8 ===
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:
>;
Subject: Re:
- Epstein
Hi Joe,
Thanks for checking in-
,
so no issues on our end, but we appreciate
your following up.
Thanks,
Sent from my iPhone
On Nov 30, 2019, at 8:54 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check-in as
Please let us know if you need anything from us.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
EFTA00018040

=== Page 9 ===
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
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:
EFTA00018041

=== Page 10 ===
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:
is
Subject: Re:
)
- Epstein
Good morning,
Yes, we had to hunker down for 2 days but were spared. Thanks. For next week, the 10th, 11th or
13th work best for me. Look forward to hearing from you.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 10:04 AM,
)
wrote:
Hi Joe,
Hope the storm missed you this week, and that you and your client are doing okay.
Our team is working out some scheduling issues today, and we should know more by this
afternoon. I'll plan to reach out then to discuss scheduling, if that's okay.
Thanks,
EFTA00018042

=== Page 11 ===
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 I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 21, 2019, at 2:40 PM,
)
wrote:
Hi Joe,
Thanks very much, we'll plan to see you then. We'll most likely meet at a conference space at a hotel
in West Palm Beach, and l'll let you know closer in time which location.
Thanks,
From: Joe Nascimento
Sent: Monday, August 19, 2019 6:37 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
,
Both the time and date work for us. Let me know the location when you have it confirmed.
EFTA00018043

=== Page 12 ===
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 19, 2019, at 11:11 AM,
)
wrote:
Joe,
Following up on scheduling, we were wondering if your client is available for a proffer on September
4th. We're flexible on timing that day, but we would propose meeting at 12:30 p.m., if that works.
Thanks,
From: Joe Nascimento
Sent: Wednesday, August 7, 2019 4:53 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
I just wanted to follow up re the August 14th meeting. Is it possible to schedule for early afternoon
(anytime after 1)? I have proactive cooperation ongoing in another case involving multiple
jurisdictions, and they are looking to meet the morning of 8/14. I understand if your schedule is
already set, and will work around it.
Thanks,
EFTA00018044

=== Page 13 ===
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
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.
EFTA00018045

=== Page 14 ===
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, August 1, 2019 at 6:10 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Joe,
As we start thinking about scheduling a next meeting with
we were wondering if you
could please let us know if there are any particular weeks that would not work for you or your client
for a meeting in Florida (in particular, we don't want to interfere with anyone's summer vacation
plans).
We will of course be in touch to talk about a next meeting in more detail, but in the first instance it
would be helpful to get a sense of your schedules, for planning purposes.
Thanks,
From: Joe Nascimento
Sent: Wednesday, July 17, 2019 6:25 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
,
That works for me. Please call me on my cell
(
). Thanks.
Sent from my iPhone
EFTA00018046

=== Page 15 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 17, 2019, at 5:58 PM,
)
wrote:
Hi Joe,
Following up, we were wondering if you were available for a call to discuss next steps. We're
available on Friday at 2:30, if that works, but let us know if there are other times that would be
more convenient for you.
Thanks,
From: Joe Nascimento
Sent: Saturday, July 13, 2019 12:39 PM
To:
Cc:
is
Subject: Re:
- Epstein
Good afternoon,
It was a pleasure to meet you yesterday. In light of the recent filing and media reports,
As always, feel free to contact me at any time if we can be of further assistance. Look forward to
meeting again.
-Joe
EFTA00018047

=== Page 16 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
"
)"
Date: Thursday, July 11, 2019 at 9:07 PM
To: Joe Nascimento
Cc:
)"
i
)"
Subject: RE:
)
- Epstein
Hi Joe,
We will be at the Hilton in West Palm Beach, at 600 Okeechobee Blvd. Please call me when you are
here, and we will meet you in the lobby.
Thanks,
From: Joe Nascimento
Sent: Thursday, July 11, 2019 9:02 PM
To:
Cc:
is
Subject: Re:
- Epstein
Good evening,
Have you set a location for our meeting tomorrow?
Thanks,
Joe
Sent from my iPhone
EFTA00018048

=== Page 17 ===
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. 3<x-apple-data-detectors://2/0>rd<x-apple-data-
detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com/
On Jul 10, 2019, at 11:34 AM,
<mailto:
wrote:
Joe,
Would it be possible to meet earlier, perhaps at noon on Friday? Thank you.
Sent from my iPhone
EFTA00018049

=== Page 18 ===
On Jul 9, 2019, at 10:51 PM, Joe Nascimento
<mailto:
<mailto:
wrote:
Can we meet Friday, early afternoon (around 1-1:30)? Please send me your proffer letter.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. <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:
<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?
EFTA00018050

=== Page 19 ===
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza 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:
<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.
EFTA00018051

=== Page 20 ===
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,
)
<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.
EFTA00018052

=== Page 21 ===
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:
X
<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
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza
|
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>
EFTA00018053

=== Page 22 ===
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/
EFTA00018054


c1: EFTA00020108
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020108.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: "Moyne, Parvin"
Cc: "Moyer, Thomas"
)"
)"
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Date: Thu, 22 Aug 2019 03:29:11 +0000
Thanks, let's do 10:30 a.m. on Thursday the 12th. Please let us know if your schedule changes, or if it's useful to talk
substantively in the interim, and we look forward to seeing you then.
From: Moyne, Parvin
Sent: Wednesday, August 21, 2019 20:01
To:
Cc: Moyer, Thomas
y
i
Subject: Re: 2019.8.15 - SDNY Production Index.xlsx
Either works for us so please choose what is most convenient for you.
Best,
Parvin
On Aug 21, 2019, at 6:45 PM,
)
wrote:
Parvin,
Not a problem. We could do any time after noon on that Tuesday (the 10th) or any time on the Thursday (the 12th).
Would either of those work?
thanks,
From: Moyne, Parvin
Sent: Wednesday, August 21, 2019 09:25
To:
Cc: Moyer, Thomas
i
is
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
I'm so sorry for the inconvenience but those dates are not good on our end.
The following week is relatively clear. Might September 9th work? Or other dates that week?
Best,
Parvin
EFTA00020108

=== Page 2 ===
From:
Sent: Tuesday, August 20, 2019 11:58 PM
To: Moyne, Parvin
Cc: Moyer, Thomas
is
is
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Parvin,
That makes good sense, thanks. Because of the scheduling issues I mentioned, we'd like to set it for a time in early
September, if we can - is there a time during the afternoon of September 5 or the morning of September 6 that would
work for you? We should be able to do either of those dates and times. Or if not, we can propose possible times the
following week.
thank you,
From: Moyne, Parvin
Sent: Tuesday, August 20, 2019 14:03
To:
is
)
V.
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Initially, we propose that the lawyers (myself, my colleagues at Akin Gump, and someone from DB Legal) deliver a
presentation that provides an overview of Epstein's
In terms of timing, I estimate 2-3 hours for the attorney proffer. (I think closer to 2 hours but I hate to underestimate.)
Best,
Parvin
From:
Sent: Monday, August 19, 2019 8:14 PM
To: Moyne, Parvin
is
is
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Parvin,
EFTA00020109

=== Page 3 ===
Could you please let us know what format we should expect in terms of the proffer? That will help us with figuring out
scheduling. I.e., do you expect to make an attorney proffer in the first instance, or should be expect to be meeting with
Deutsche Bank personnel, etc? And approximately how long should we be planning to block out?
thanks,
From: Moyne, Parvin
Sent: Monday, August 19, 2019 12:04
To:
is
)
V.
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Hi
-
The proffer may be helpful in guiding you through the production. That said, we can be available whenever makes most
sense on your ends.
We have time this week (Thursday or Friday afternoon) and next week (Monday - Wednesday), and we have time in
September. If you give us a few options in terms of dates/times, we will sort out schedules on our ends.
Best
Parvin
From:
)
Sent: Saturday, August 17, 2019 1:59 PM
To: Moyne, Parvin
is
is
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
*EXTERNAL Email*
Parvin,
We received the index, thank you. In terms of a proffer, what generally did you have in mind regarding timing? I think
we'd like to have some time with the subpoena returns to get familiarized, and our team has a combination of travel and
trials in the next couple weeks, but we could do early September if that works on your end. Thoughts?
thanks,
From: Moyne, Parvin
Sent: Thursday, August 15, 2019 09:48
To:
is
V.
Cc: Moyer, Thomas
Subject: 2019.8.15 - SDNY Production Index.xlsx
&
EFTA00020110

=== Page 4 ===
Please find attached an index to our productions to date. This is a work in progress - we will update it as we gather and
produce additional documents.
Would you like to touch base later today about scheduling a proffer? We are free after 4 p.m.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
One Bryant Park
New York, NY 10036-6745
USA
Direct: +1
Internal:
Fax: +1
akingump.com
Bio
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
EFTA00020111


c1: EFTA00019212
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019212.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
CORRECTOR
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
New York, New York 10007
November 10, 2020
BY ECF
Legal Counsel
Federal Bureau of Prisons
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear
Enclosed is a laptop for Ghislaine Maxwell, an inmate at the Metropolitan Detention
Center. We are providing this laptop to Ms. Maxwell for the sole purpose of reviewing discovery
materials in connection with the above-captioned case. The laptop has been reviewed by support
staff at our Office, who have informed us that they have successfully modified the laptop to meet
the specifications you have requested. In particular, we have been informed that:
The laptop contains a microphone and camera, which have both been disabled. As a result,
the laptop has no recording capabilities.
The laptop does not contain any programs for games.
Communication capabilities have been disabled. In particular, the laptop has no Wi-Fi,
Bluetooth, or Ethernet connection capabilities.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By:
Went me
Assistant United States Attorneys
Southern District of New York
Tel:
EFTA00019212


c1: EFTA00017952
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017952.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: 302 for seized hard drives from MCC
Date: Mon, 09 Mar 2020 21:29:22 +0000
Attachments: Seizure_of_hard_Drives_Associated_with_DVR_2.pdf
Hi
Sorry for the delay... here is the 302. I am going to forward you quite a few of emails going back from the beginning concerning the
DVRs and the video system.
Let me know if you have any questions regarding anything I send you!
Thanks!
Special Agent
FBI New York Field Office
Violent Crimes Task Force
EFTA00017952


c1: EFTA00019916
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019916.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
June 9, 2021
prep
AUSA
Det
called her mother,
to ask whether the mother would be willing to
meet with AUSA and FBI. Call was placed on speakerphone.
asked
to meet with government to tell what
remembers from when
was a teenager and interacting with Maxwell
Without prompting,
said she remembered that
was spending a lot of time
with
who would borrow
,
car;
remembers receiving calls on her
phone from
and "Giselle or whatever her name is";
remembers
receiving packages of Victoria's Secret lingerie
told
repeatedly not to tell
what she remembers but just to meet with
the government and tell them because it could be helpful
is willing to meet with government if
is present
prepared for direct testimony
attended
in Palm Beach; lived with her mother and her
younger brother; did what she wanted to because her mother was addicted to crack and an
alcoholic
first went to JE's house because of
, who
met through
was
boyfriend, who was older than
and lived across the street
from
recalled meeting
when she was 13.
recalled telling
that she
was in fact 16 and about to be 17 years old. When
turned 14, she told
her true age.
was 17 when
met him and is about 3 years older than
went to the same charter school as
and her boyfriend
was skinny with blonde hair and very pretty
was about 14 when she met
does not recall knowing
age, does not recall asking
how
old she was
and
would smoke weed and drink when they hung out
recalls one time when she and
were alone in the bathroom and
asked if
wanted to make money by giving a guy a massage.
asked how much money she would get, and
said $300 or $300, so
agreed.
recalls that
gave
an outfit to wear the first time
went to JE's
house. It was short shorts and a skimpy top.
first went to JE's house when she was about 14 years old.
drove
in
car to JE's house that first time.
JE's house was on Palm Beach off the intercoastal. The house was pink when
first went there, but was later painted white.
1
EFTA00019916

=== Page 2 ===
When
&
first arrived at JE's house, they walked into the kitchen
where there was a chef cooking, who asked if
wanted food. Then Maxwell
approached.
believes Maxwell's first name may have been "Giselle" or
"Gisine," but she is not certain.
is certain her last name was Maxwell, and
referred to her as Maxwell.
does not know how to pronounce Maxwell's
first name.
Maxwell was an older lady with black hair, about shoulder length.
Maxwell appeared to be in her 40s. Maxwell had an accent, which
recalls seeming like a mix of French and Australian.
introduced
to Maxwell as my friend
Maxwell told
in
presence that Jeffrey will be back soon and
that
should take
upstairs and show her what to do.
and
then went upstairs into Jeffrey's bedroom, past his bed into his
bathroom.
When
walked into the bathroom, she saw the sink to the right, shower
and steamroom in front, toilet to the left, and ugly polka dot couch to the
left.
recalls seeing a bunch of naked pictures of different women in
the closet handing on the wall and the massage table.
believes that the clock in the bathroom had a camera in it.
also
believes that the house across the street from JE's house had the FBI in it
because she saw a telescope in one of the windows.
acknowledged
that no one ever told her there was a camera in the clock or that the FBI
was across the street.
never saw the camera itself or the FBI across
the street.
indicated that she gets feelings like premonitions and
believes strongly that the camera had a clock and the building across the
street had the FBI in it.
showed
how to set up the massage table, where the oils and lotions
were. Lotions were in the dresser to left as
walked into the bathroom.
also saw massagers that she later learned were sex toys.
got fully naked.
got into her bra and underwear.
JE then came into the room, brushed his teeth, got undressed, and laid on the
massage table on his stomach.
and
each rubbed on of JE's legs and butt cheek. They
continued massaging him for about 45 minutes.
After about 45 minutes, JE turned over, and
got on top of him.
told
she could sit on the couch.
sat on the couch while
had sexual intercourse with JE.
JE did not touch
during this massage.
After JE finished having sex with
he got into the shower.
After the massage,
gave
$400.
got $600.
recalls the
cash being in 20s and 100s.
2
EFTA00019917

=== Page 3 ===
When
and
went downstairs, Maxwell asked
for her number so
could massage JE again.
gave Maxwell her cellphone number.
saw
Maxwell write the phone number down in a black book.
provided over 100 paid sexualized massages to JE after that first time. About 2 or 3
times per week. Stopped massaging JE when
was about 18, almost 19 years old.
Around that time, JE asked
if she knew anyone younger she could bring.
figured
she was too old at that point.
The details of each massage run together in
memory, but certain events
stand out more than others.
would get to JE's house by taking cabs that JE would pay for, or
would drive
in
mom's car.
To schedule massages, either Maxwell or
would call
Sometimes
called herself to ask if she could schedule a massage when she ran out of money
for drugs.
recalls that Maxwell called her for the first year or two that
was
going over to JE's house, after which
became the person who called.
was an assistant who was younger than Maxwell with light brown
hair
After Maxwell stopped calling to schedule appointments,
would still
see Maxwell at JE's house, but Maxwell would mainly stay in the office
area
Maxwell and
would call
cellphone,
mom's cellphone,
and
phone number to schedule
for massages
gave all of those numbers to Maxwell or
At one point, Maxwell asked
if she could call
back on the number
had called from, which was
number.
recalls that
Maxwell put that number in the black book.
When someone would call
mom, her mom would tell
that a
lady is calling for her and would give her the phone
When someone would call
phone, he would give
the
phone and tell her to schedule an appointment
When Maxwell would call, she would ask
if she could come over at a
particular time
A couple times, Maxwell told
that Maxwell and Epstein were in New
York and that she and Epstein and
would be coming back to Palm
Beach.
estimates this happened about ten to twelve times.
recalls
that Maxwell was calling from a Manhattan area code during those calls.
Other times, when Maxwell would say she was calling from Florida, the
calls came from a Palm Beach area code.
When
would call, she would ask if
would be available to come
to Palm Beach at a particular time
3
EFTA00019918

=== Page 4 ===
would reach out to schedule appointments herself because she was
addicted to drugs and wanted to numb everything.
would use
marijuana and cocaine before going to JE's house.
only recalls speaking with JE on the phone once. She recalls he said
he was in New York and Palm Beach. JE wired
$200 because she
needed money.
When
didn't drive
she would either take a cab, or JE had a couple
male employees who would drive town cars. Maxwell or
would tell
either they'd pay for the cab or would send a car for her.
would borrow
mom's car to drive
sometimes.
was too young to get her license so couldn't legally drive herself, but
she nevertheless drove herself to JE's house in her mom's car once or
twice.
never went inside JE's house.
met JE once or twice.
recalls
talking with JE about the cars JE owned.
never entered JE's house through the front door, always entered through the
door that led into the kitchen. Once inside,
would usually see Maxwell and
the chef. Once or twice,
saw the housekeeper and his wife, but they were
only at JE's house for the beginning of
time going to JE's house, then they
left.
Maxwell would offer
food or water, and
would wait for JE
Maxwell engaged
in conversation sometimes. Maxwell asked
if
she was an only child and asked about
parents.
told Maxwell
that
and that
mother was an addict and an
alcoholic. Maxwell asked if anything bad had ever happened to
because of her mother's addiction, and
told Maxwell that
cousins
Maxwell asked
, and
told Maxwell
Maxwell asked
if she ever
masturbated and told
there were sex toys upstairs (this was the same
day JE tried to put a massager on
vagina).
told Maxwell that
Maxwell asked
what her bust and hip sizes were. A couple weeks
later,
began receiving packages with bras and underwear from
Victoria's Secret. Maxwell asked
to wear the lingerie so Epstein
could see them.
Maxwell told
that JE would pay for
to go to massage school, but
told Maxwell that
was too young. That same appointment, JE
gave
with a book called Massage for Dummies.
Maxwell asked
if she'd like to go to an island that JE owned.
responded that
mom would not let her because she was 15 years old.
Maxwell acted like she didn't hear
and said ok then walked back into
the office. Maxwell continued to call
to schedule massages with JE
after
told Maxwell her age.
4
EFTA00019919

=== Page 5 ===
After going into the kitchen for each massage,
went upstairs into JE's
bathroom, put the massage table together, then got undressed.
At first,
just got into her bra and underwear.
Later on,
would get fully nude and put her clothes on the couch. JE
offered to pay
an extra $100 if she would take off her bra, and an extra
$100 if she would take off her underwear.
Maxwell saw
nude in the massage room about two times when
was about
15 years old.
First time, Maxwell just looked at
and said
had a nice body
Second time, Maxwell fondled
breasts and touched
buttocks and
said
had a nice body for Mr. Epstein's friends.
recalls feeling
weird about this because JE wouldn't touch
the way that Maxwell did.
JE would touch
breasts and bottom, but not the way that Maxwell
did.
also felt weird because Maxwell was talking about other people.
After Maxwell saw
nude in the massage room, Maxwell called
to
schedule additional massage appointments about a couple more times
came into the massage room and saw
naked in the room a couple times.
also took naked photos of
called
and said JE would like to take pictures of
would be the one taking pictures, and
could bring a bathing suit.
asked to take some nude photos too.
paid
$500 for the photos.
took the photos inside and outside on JE's property.
remembers telling
that
was 16 years old.
said
was really beautiful and asked how old
was.
was young and
looked like she was about 20 years old.
does not know what happened to the photos
took.
During massage appointments, JE would come in,
would first massage JE for
about 45 minutes, then JE would turn over.
A couple times,
got into the steamroom with JE.
During the massage portion, JE would engage
in conversation.
JE asked about
family life, things
had been through, and what
wanted to do with her life. JE asked about
family, and she told
him she lived with her mom and her mom is a drug addict and an
alcoholic. JE asked if
had ever been to a massage shop, and
said
no.
told JE
JE asked if
was willing to go to Paris, and
told JE she was 14
years old and her mom would never let her go on a trip. JE also invited
to his house on the island, but
said her mom wouldn't let her. JE
asked
if she could get a passport, and
said she was 15 and her
mom would not allow her to travel.
JE told
that
had gone to Thailand.
does not remember JE
telling
anything about travel with
5
EFTA00019920

=== Page 6 ===
After each massage,
would get paid.
recalls being paid $300 or $400
stole an extra $100 from JE a couple times, so would get up to $500
total
Usually the money was waiting on the sink in the bathroom
Maxwell handed
the money a couple times (more than twice)
handed
the money a couple times
recalls that the money would be 100s, 50s, or 20s, but mostly 100s
received gifts from JE
Massage for Dummies book
Lingerie from Victoria's Secret, would arrive via FedEx from New York
(Manhattan address) in either Epstein's or Maxwell's name
One time, Maxwell called
, told
Epstein would like to send
some things, and asked for
address.
provided her address, which
was in West Gate in Florida. This was after Maxwell had asked for
hip and bust size.
JE asked
to bring female friends. JE asked if
had anyone her age or
younger to bring.
recalls bringing about 3 or 4 friends to JE's house. Remembers
, and
little sister.
was about
,
17,
was younger than
was in her 30s so JE kicked
out and didn't want her there,
little sister was about 15.
Maxwell once asked
if she had any friends who would be interested in
massaging JE.
would bring her friends into the kitchen at JE's house, then upstairs.
remembers being paid $200 extra when she brought a friend, so
would get $500, and the friend would get $300.
Each massage with JE lasted about one hour
After the massage part, JE would roll over, masturbate, tell
to touch
his nipples, and touch
breasts or buttocks
JE masturbated during every massage
JE touched
breasts during every massage
JE touched
buttocks during every massage
JE touched
vagina during a couple massages
recalls seeing multiple naked photos of Maxwell in JE's house, including a
photograph of Maxwell pregnant. Based on those photos,
believed Maxwell was
JE's wife.
When
was going to JE's house,
would lie to her mother and say she was cleaning
JE's house
When
was older,
engaged in paid sex acts to pay for hotel rooms when her family
was homeless
6
EFTA00019921

=== Page 7 ===
After
had her baby, when she went back to JE's home, JE asked
to give him
breast milk, tried to suck on
breast,
stopped him, then gave him breast milk in a
cup
7
EFTA00019922


c1: EFTA00020347
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020347.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: for new victim witness services website, for the Maxwell case
Date: Wed, 08 Jul 2020 16:18:07 +0000
Hey I'm sorry, I neglected to include info about the next hearing date - let's please use the following instead, and thanks
again:
On July 2, 2020, the United States Attorney's Office announced the unsealing of federal felony charges against GHISLAINE
MAXWELL on charges of enticement of a minor to engage in illegal sex acts, transportation of a minor to engage in illegal
sex acts, conspiracy, and perjury. These crimes are alleged to have occurred in locations including, but not limited to, New
York, Florida, New Mexico, and the United Kingdom.
The next conference, which will include an arraignment and bail hearing, is scheduled for Tuesday, July 14, 2020, at 1:00
p.m. before the Honorable Alison J. Nathan, United States District Judge for the Southern District of New York. This
proceeding will occur as a remote video / teleconference using an internet platform. Members of the public may access
an audio feed of the proceeding by calling a dial-in number, which the Court will provide in advance of the proceeding.
Pursuant to the Crime Victims' Rights Act, Title 18, United States Code, Section 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. If you
believe you are a victim in connection with this case, and would like to be heard in connection with the hearing scheduled
for July 14, 2020, please contact Wendy Olsen, Victim / Witness Coordinator, at the telephone number or email address
listed below.
If you believe you are a victim of GHISLAINE MAXWELL, from during any time period and in any location, please contact
the Victim / Witness specialists at the U.S. Attorney's Office listed below.
The charges are contained in Indictment 20 Cr. 330 (AJN). You may view a copy of the Indictment here.
Updates regarding the progress of this case will be posted on this site.
The United States Attorney's Office for the Southern District of New York is committed to protecting the rights of crime
victims. If you believe you are a victim of the offense charged, our Victim/Witness Unit can make sure that you are
notified of important stages of the case to help you exercise your rights. In addition, our Victim/Witness Unit can help
refer you to agencies that provide other services to witnesses, such as compensation (under certain circumstances) and
counseling. If you believe you are a victim, of if you would like information or assistance with referrals, please contact:
Victim/Witness Coordinator
United States Attorney's Office
New York, New York 10007
From:
Sent: Wednesday, July 08, 2020 11:51
EFTA00020347

=== Page 2 ===
To:
Cc:
Subject: Re: for new victim witness services website, for the Maxwell case
Of course, will do.
Sent from my iPhone
On Jul 8, 2020, at 11:30 AM,
wrote:
Could we please create a new Victim & Witnesses Services page for the Maxwell case, similar to what we did for the
Epstein case last year? The header can be the same format as Epstein, with the top two lines as:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
If you believe you were a victim of Ghislaine Maxwell or have information about the allegations in the Indictment,
please call 1-800-Call-FBI
And then for the first entry, a "July 8, 2020 update", could we please post the following, along with a link to the PDF of
the indictment:
On July 2, 2020, the United States Attorney's Office announced the unsealing of federal felony charges against
GHISLAINE MAXWELL on charges of enticement of a minor to engage in illegal sex acts, transportation of a minor to
engage in illegal sex acts, conspiracy, and perjury. These crimes are alleged to have occurred in locations including, but
not limited to, New York, Florida, New Mexico, and the United Kingdom.
If you believe you are a victim of GHISLAINE MAXWELL, from during any time period and in any location, please contact
the Victim / Witness specialists at the U.S. Attorney's Office listed below.
The charges are contained in Indictment 20 Cr. 330 (AJN). You may view a copy of the Indictment here.
Updates regarding the progress of this case will be posted on this site.
The United States Attorney's Office for the Southern District of New York is committed to protecting the rights of crime
victims. If you believe you are a victim of the offense charged, our Victim/Witness Unit can make sure that you are
notified of important stages of the case to help you exercise your rights. In addition, our Victim/Witness Unit can help
refer you to agencies that provide other services to witnesses, such as compensation (under certain circumstances) and
counseling. If you believe you are a victim, of if you would like information or assistance with referrals, please contact:
Victim/Witness Coordinator
United States Attorney's Office
New York, New York 10007
*
EFTA00020348

=== Page 3 ===
Let us know if any questions or issues at all? And thanks very much as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00020349


c1: EFTA00020396
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020396.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: brief
Date: Sun, 12 Jul 2020 17:02:40 +0000
Attachments: 2020-07-12_GM_detention_reply_brief.docx
Attached.
From:
Sent: Sunday, July 12, 2020 12:39 PM
To:
Cc:
Subject: Re: brief
yup
Sent from my iPhone
On Jul 12, 2020, at 12:38,
wrote:
Hi team - I'm going to send you the draft incorporating
's changes in about half an hour. Are you able to give it a
quick read to make sure you're comfortable with some of the alterations/additions? Thanks.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00020396


c1: EFTA00020174
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020174.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: "Miller, Michael"
>, "Martin G. Weinberg"
Cc: "Weingarten, Reid"
X
"Gilbert, Sara"
)"
)"
Subject: RE: US V Epstein
Date: Wed, 14 Aug 2019 22:07:42 +0000
Mike, Marty,
Following up on our prior conversations, we are able to provide you with the contact information for the Assistant U.S.
Attorneys who are assigned to the investigation of Mr. Epstein's death. They are:
I have also provided them with your contact information.
thank you,
From: Miller, Michael
Sent: Wednesday, August 14, 2019 16:52
To:
>; Martin G. Weinberg
Cc:
>;
>;
Weingarten, Reid
>; Gilbert, Sara
Subject: RE: US V Epstein
Why don't we use the following dial-in for tomorrow at 9:30?
80943#
Mike
Michael C. Miller
Partner
Steptoe
Steptoe & Johnson LLP
1114 Avenue of the Americas I New York, NY 10036
www.steptoe.com
This message and any attached documents contain information from the law firm Steptoe & Johnson LLP that may be confidential and/or privileged. If you
are not the intended recipient, please do not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the
sender immediately by reply e-mail and then delete this message.
EFTA00020174

=== Page 2 ===
From:
Sent: Wednesday, August 14, 2019 4:42 PM
To: Martin G. Weinberg
Cc:
is
>; ; Miller, Michael
>; Weingarten, Reid
Subject: Re: US V Epstein
Marty,
That time works for us, thanks. Could you please circulate a dial-in?
Thanks.
Sent from my iPhone
On Aug 14, 2019, at 11:23 AM, Martin G. Weinberg
wrote:
Mike and I are authorized to continue the discussion of potential civil forfeiture issues with you. Are you available
at 930 tomorrow morning? Thanks
Martin G. Weinberg, Esq.
Boston, MA 02116
This Electronic Message contains information from the Law
Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the
addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of
the contents of this message is prohibited.
EFTA00020175


c1: EFTA00019518
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019518.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: FW: Relativity access,
Date: Fri, 11 Jan 2019 17:21:32 +0000
Importance: Normal
Attachments: EOUSA_MEGA4_Account_Request_and_ROB_Form.pdf
welcome to the glorious world of mass-document management! If you could please fill out the
attached form and send to
cc'd, he'll get you an RSA token that you'll need for logging in. Relativity is web-
based so we all can access it from anywhere.
thanks,
From:
Sent: Friday January 11 2019 11:27
To:
Subject: RE: Relativity access, 2018R01618
Good Morning
The following people will need to fill out the attached form as they do not have an RSA token to access Relativity
Please have everyone send the attached form back to me and I will have an RSA token sent to them.
Thank you.
From:
Sent: Thursday, January 10, 2019 12:04 PM
To:
Cc:
Subject: RE: Relativity access,
EFTA00019518

=== Page 2 ===
We'd like to set up a Relativity database, please, for U.S. V. Epstein,
and to grant access to AUSAs
Currently the only documents we need to have uploaded are in the following folder:
USvEpstein-2
Investigation\FI materials (reports, FOIA,
etc)\2018-12-04, FBI Case File
We'd like the PDF files in the folder uploaded but NOT the files in the subfolder (titled "Files combined and manifest").
We also expect to be receiving a large amount of case files in the coming weeks, and so want to get up and running,
including agent access, so there's no delay once we receive the large batch of documents.
With respect to anticipate review process, it's possible that at some point we might receive materials that would
necessitate a privilege review, but not at this stage and not with respect to the materials in the linked folder.
Please let me know if any other information would be helpful, and thanks very much.
Assistant U.S. Attorney
Southern District of New York
EFTA00019519


c1: EFTA00019440
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019440.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: review project
Date: Fri, 19 Nov 2021 16:06:47 +0000
Attachments: SDNY_GM_00405522.pdf; SDNY_GM_00405330.pdf; SDNY_GM_00405333.pdf;
SDNY_GM_00405348.pdf; SDNY_GM_00405351.pdf
Our intern
reviewed these and confirmed that there are no records from the 1990s (all were from 2004 or 2005).
and
were not mentioned, though the attached mentioned a
with no last name provided. Let
me know if you need anything further on this project.
From:
Sent: Sunday, November 14, 2021 7:05 PM
To:
Cc:
Subject: review project
Hi
Are you able to ask another paralegal to review the flight records in these folders and let us know if there are any records
from the 1990s? Or if any of the records name
or
?
Thanks!
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Discovery\GM\Defense Rule 16
Disclosures\2021.11.08 Defense Rule 16 Disclosure\6.
Flight Manifests
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019440


c1: EFTA00019021
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019021.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
Subject: FW: Maxwell Review
Date: Wed, 17 Mar 2021 19:32:43 +0000
From:
(USANYS)
Sent: Wednesday, March 17, 2021 3:26 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Maxwell Review
Got it.
From:
(USANYS)
Sent: Wednesday, March 17, 2021 3:20 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: Maxwell Review
Hi
Just want to put an issue on your radar. As you may recall, we paid a vendor to scan the SDFL Epstein file in October, and
we are hopeful that it will be loaded into Relativity by the end of March (the delay was unfortunate, but we're hopeful
PAE can make it happen soon). In order to meet pretrial disclosure deadlines, we need to review the file (which we
understand to be 30k documents) to determine what has already been produced. We have recruited 4 paralegals and an
intern in PC to help conduct this review, and have requested an additional 3-4 paralegals from Darcy to assist. The
deadline is the end of April, so the team has about a month to complete the review.
Happy to discuss any further if you have any questions.
Thanks very much,
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
Desk
Cell
EFTA00019021


c1: EFTA00019757
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019757.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
<
Cc:
Subject: Re: Automatic reply: Epstein update
Date: Sat, 10 Aug 2019 15:26:13 +0000
Attachments: Press_Release_-_MCC_New_York.pdf
Good morning all,
I have been in contact this morning through
and am going to see what other information I can get now that I am here
at the institution. I am attaching the press release that just went out. I will call
but then I'll be out of touch inside the
institution for a bit. If you need to reach me, contact Control at
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
New York, New York 10007
>>>
>
8/10/2019 10:48 AM >>>
Sent from my iPhone
On Aug 10, 2019, at 10:48,
> wrote:
What's a good number to call you.
On Aug 10, 2019, at 10:43 AM,
wrote:
As you might imagine, we are getting increasingly frantic calls from defense counsel who continue to be seeing
information in the press that we-the U.S. Attorney's Office-haven't yet received. We need to know as soon as possible
the very basic facts, such as time and cause of death at the absolute minimum. It has now been hours since this was
reported publicly. Please advise when we can expect to receive either a written report on those basic facts or when we can
have a call to get that information to relay to his counsel. It is extraordinarily frustrating to have to tell them that we have
less information than the press. Please advise.
Thank you,
EFTA00019757

=== Page 2 ===
On Aug 10, 2019, at 08:46,
> wrote:
Passed away. We are completing a significant incident report for HQ for Death of a Federal Inmatehowever, I do not
have any specifics from the BOP yet.
From:
Sent: Saturday, August 10, 2019 8:44 AM
To:
Subject: Re: Automatic reply: Epstein update
Thank you for telling us. What do you mean by "passed"?
Thanks,
Sent from my iPhone
On Aug 10, 2019, at 8:18 AM,
wrote:
BOP just provided another update- Epstein has passed. I have no additional info. I will push out updates as we
receive.
From:
Sent: Saturday, August 10, 2019 7:52 AM
To:
Subject: Re: Automatic reply: Epstein update
FYI:
The BOP just informed us that Epstein is being taken by ambulance to the hospital from another apparent suicide
attempt- no other information was provided.
They will update us as more info becomes available.
On Aug 10, 2019, at 7:26 AM,
wrote:
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses
may be delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
at
or
EFTA00019758


c1: EFTA00019491
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019491.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Friendly Subpoena
Date: Fri, 26 Mar 2021 14:10:42 +0000
Sure. Will look for it.
From:
Sent: Friday, March 26, 2021 9:42 AM
To:
Cc:
Subject: Friendly Subpoena
Hi
- Just a heads up that the Maxwell team is going to seek your approval this morning to issue a friendly
subpoena to counsel for Minor Victim-4, the latest victim whose abuse gives rise to the superseder, for a non-privileged
materials related to her settlement with Epstein back in 2008 or thereabouts. As you can imagine, we think we need this
stuff both to prepare for trial but also as potential Giglio for the witness, and her lawyer is happy to provide it to us but
believes he needs a subpoena.
Happy to chat further if that would be helpful, but otherwise will have the team send you an email shortly so you can
approve.
Thanks,
Chief, Public Corruption Unit
U.S. Attorney's Offfice for the
Southern District of New York
Tel:
Cell:
EFTA00019491


c1: EFTA00019697
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019697.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Subpoena request
Date: Fri, 27 Sep 2019 14:44:33 +0000
Hi, unfortunately we can't provide it to you directly but if you request it from OCME they will be able to provide it to you.
Let me know if you need a contact (Florence Hutner, their GC, is the right person - Hutner, Florence (OCME)
>).
From:
Sent: Friday, September 27, 2019 9:28 AM
To:
Subject: Re: Subpoena request
Are you guys able to turn over the requested documents yet. I'm still waiting to close this case out.
On Aug 19, 2019, at 12:13 PM,
wrote:
Hi
We are requesting that information today and will give it to you when we get it.
In the meantime, we had heard that the Marshals may have a form that Epstein may have/may not have signed noting
he had suicidal tendencies, and this happened around 8/1. Do you know anything about this?
Give me a call with any questions, thanks.
From:
Sent: Monday, August 19, 2019 11:55 AM
To:
Subject: FW: Subpoena request
From:
Sent: Monday, August 19, 2019 11:48 AM
To:
Subject: FW: Subpoena request
AUSA
advised that I should reach out to you guys for the below:
We need to obtain a copy of the death certificate and autopsy report to close out Jeffrey Epstein's case. Can I please get
subpoenas for both?
Death Certificate:
Office Of Vital Records
Bureau of Vital Statistics
EFTA00019697

=== Page 2 ===
New York City Department of Health and Mental Hygiene
Autopsy Report:
New York City Office of Chief Medical Examiner
You can use my info for the return:
Thank you
Supervisory Deputy U.S. Marshal
Southern District of New York
EFTA00019698


c1: EFTA00019130
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019130.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "Weinstein, Marc A.'
To:
Andrew Tomback
,
Subject: Epstein Estate
Date: Mon, 09 Nov 2020 15:30:16 +0000
Importance: Normal
Attachments: unnamed
Inline-Images: ATT90747_1.jpg
HHR OnlineMeetingCenter
Dial-In Information (for meetings with no presentations or video)
Dial-In Number: +1 (201) 630-0824
Conference ID: 570579045
One touch dial-in from mobile phone (via cellular service)
Additional Dial-In Numbers
Brazil +55 11 3181-5692
Canada +1 647-749-1240
China +86 400 842 8305
France +33 1 73 24 04 53
Germany +49 69 667737017
India +91 22 6001 6148
Ireland +353 1 566 1143
Israel +972 3 3762055
Japan +81 3-4510-7259
Korea (Seoul) +82 70-7488-2208
Singapore +65 3157 0147
United Kingdom +44 20 3443 6288
United States +1 (201) 630-0824
Full list of dial-in numbers
Meetings with a presentation or video
Connect from computer or mobile device (via network/internet connection)
Help
Try Skype Web App if you are having trouble joining
Joining from a computer using the "Connect from computer or mobile device" link provides additional
capabilities, however you can simply call in from your telephone using the number provided above if your
meeting will not include video or a presentation. Click the "Help" link for additional information if you are a
guest joining a Skype for Business meeting from your computer or mobile device for the first time.
For meeting organizers: Reset your dial-in PIN?
EFTA00019130


c1: EFTA00019923
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019923.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
)"
)"
Subject: FW: U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Thu, 29 Apr 2021 19:03:30 +0000
Attachments: Letter_re-_Sleep_Deprivation-4-29-21.pdf
From: BOBBI C STERNHEIM
Sent: Thursday, April 29, 2021 3:01 PM
To:
)
is
>;
(USANYS)
>;
Cc: Christian Everdell
; Laura Menninger
>; Jeff Pagliuca
Subject: U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Good afternoon-
Attached is a courtesy copy of today's ECF fling.
Regards-
Bobbi
BOBBI C. STERNHEIM, ESQ.
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
EFTA00019923

=== Page 2 ===
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
EFTA00019924


c1: EFTA00019580
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019580.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: TVPA and Forfeiture.docx
Date: Thu, 18 Apr 2019 14:06:26 +0000
Importance: Normal
Attachments: TVPA_and_Forfeiture.docx
FYI - this is on the share and is a work in progress in the early stages.
Once I start getting 302s I can start filling in the victim details.
EFTA00019580


c1: EFTA00018006
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018006.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: [EXTERNAL] Beyond a Reasonable Doubt
Date: Fri, 24 Sep 2021 22:37:11 +0000
Attachments: GM_jury_exercise_RTC_-_revised.docx
Ah, good catch--I don't think so. The only instruction I received is the attached (which is preponderance of the
evidence). Could one of you please send me a copy of or steer me in the direction of where to find the reasonable
doubt instructions (I don't obviously see it on the shared, sorry if I am missing anything)?
Original Message
From:
Sent: Friday, September 24, 2021 6:32 PM
To:
Cc:
Subject: Re: [EXTERNAL] Beyond a Reasonable Doubt
3 copies of the reasonable doubt instruction? (Sorry that was the subject of the email so maybe not clear)
Sent from my iPhone
> On Sep 24, 2021, at 6:30 PM,
wrote:
V
> Hi all,
>
> I have the following organized and ready to go for tomorrow:
>
> - 50 copies of jury instructions/RTC document (40 copies for jurors, 3 copies per
email below,
additional copies for us)
> - 40 copies of govt slides and 40 copies of closing slides, each marked with a number 1-40 in a numbered
folder, which we'll use to make sure we have all of our materials back at the end
> - 5 extra copies of govt slides and 5 extra copies of closing slides
> -
opening,
opening and closing
(
is printing hers, I have supplied her with a binder and
label for it)
> - back up copies of slides on a thumb drive
> - back up speaker in case there's an issue with their audio system
> - a small set of supplies (notepads, pens, etc.)
> - a small variety of snacks
>
> Please let me know if there is anything else you can think of that you'd like me to bring or prepare. I will be
departing 1SA around 7:15am tomorrow (courtesy of
and
who helped arrange for a CSO to drive me
with our materials to the site), so if there's anything else you need please let me know before 7am.
V
> Thanks,
V
V
EFTA00018006

=== Page 2 ===
>
Original Message
> From:
> Sent: Friday, September 24, 2021 2:57 PM
> To:
> Cc:
i
> Subject: FW: [EXTERNAL] Beyond a Reasonable Doubt
>
>
Can you pls include this in the materials being prepped. I think I'm just under the 3pm deadline!
V
>
Original Message
> From:
> Sent: Friday, September 24, 2021 2:56 PM
> To:
> Subject: [EXTERNAL] Beyond a Reasonable Doubt
V
> Please bring 3 copies of the instruction tomorrow.
V
> Thanks.
V
>
> Sent from my iPhone
EFTA00018007


c1: EFTA00018298
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018298.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Ghislaine Maxwell's accuser 'was paid to set up Tom Parker Bowles in 1999 cocaine sting'
Date: Tue, 23 Nov 2021 01:08:40 +0000
https://www.dailymail.co.uk/news/article-10224407/Ghislaine-Maxwells-accuser-paid-set-Tom-Parker-Bowles-
1999-cocaine-sting.html
Sent from my iPhone
EFTA00018298


c1: EFTA00018628
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018628.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: Expert Witness
Date: Wed, 28 Oct 2020 22:22:59 +0000
Also, I have some availability tomorrow before noon or after 3:00pm, if that works better.
Please let me know what works for you and if you'd like a CV and fee schedule in the interim.
Best,
Kim
Sent from my iPhone
On Oct 28, 2020, at 1:17 PM, Kimberly Mehlman-Orozco wrote:
Hi
Yes, I have some time to chat this week. I have availability today or Friday before noon or after 3:00pm.
I can be reached on my cell
or feel free to circulate a call-in number.
Best,
Kim
Sent from my iPhone
On Oct 28, 2020, at 1:10 PM,
wrote:
Dr. Mehlman-Orozco,
My colleagues,
and
and I are the prosecutors in the case of United States V. Ghislaine
Maxwell, which is scheduled to go to trial on July 12, 2020 in the Southern District of New York. We would be
interested in speaking with you about your availability to testify at trial. Are you available for a call this week to
discuss?
Thanks very much,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00018628


c1: EFTA00019409
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019409.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Steptoe
STEPTOE & JOHNSON LLP
Michael C. Miller
212 506 3955 direct
212 506 3950 fax
1114 Avenue of the Americas
New York, NY 10036
212 506 3900 main
www.steptoe.com
August 20, 2019
Via Electronic Mail
Legal Department
Metropolitan Correctional Center
150 Park Row
New York, NY 10007
Re:
United States v. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.)
Dear
,
We represent Jeffrey Epstein, Reg No. 76318-054, who was previously
incarcerated at the Metropolitan Correction Center in New York, New York (the "MCC")
while awaiting trial on federal charges in the above-captioned case. We have been
authorized by his estate to write pursuant to 28 C.F.R. §§ 16.21-16.26 to request
documents and records from the U.S. Department of Justice related to Mr. Epstein.
Specifically, we are seeking: any (1) protocols relating to the response
to/investigation of inmate deaths within the MCC; (2) video recordings of all entrances
and exits to the MCC; (3) entry and exit logs for the MCC; (4) video recordings of the
hallways of the floor on which Mr. Epstein's cell was located; and (5) logs related to the
guards on duty at the MCC (collectively, the "Requested Evidence"). The applicable
time period for the requests is from 7:00 am on Friday, August 9, 2019 until 8:00 am on
Saturday, August 10, 2019. As required by the regulations, we set forth below a
summary of the relevance of the Requested Evidence.
Mr. Epstein died in federal custody in his cell at the MCC. We are troubled by the
circumstances of his death and by reports of irregularities at the facility. According to a
statement issued by the Federal Bureau of Prisons:
EFTA00019409

=== Page 2 ===
August 20, 2019
Page 2
On Saturday, August 10, 2019, at approximately 6:30 a.m., inmate Jeffrey
Edward Epstein was found unresponsive in his cell in the Special Housing Unit
from an apparent suicide at the Metropolitan Correctional Center (MCC) in New
York, New York. Life-saving measures were initiated immediately by responding
staff. Staff requested emergency medical services (EMS) and life-saving efforts
continued. Mr. Epstein was transported by EMS to a local hospital for treatment
of life-threatening injuries, and subsequently pronounced dead by hospital staff.
The FBI is investigating the incident.
In a separate statement, Attorney General William P. Barr indicated that "Mr. Epstein's
death raises serious questions that must be answered." On August 12, Mr. Barr further
stated, "We are now learning of serious irregularities at this facility that are deeply
concerning and that demand a thorough investigation."
Moreover, there was initial uncertainty about the cause and manner of Mr.
Epstein's death. The New York City Office of Chief Medical Examiner ("OCME")
declined to immediately release a determination, citing the need for "further
information." Days later, the OCME announced that it had reached a conclusion
following a "careful review of all investigative information."
We intend to conduct our own investigation into the circumstances of Mr.
Epstein's death. In order to do so, we ask that the Requested Evidence be made
available to counsel.
Please let us know if you would like to discuss this request.
Sincerely,
Michael Miller
Steptoe & Johnson LLP
1114 Avenue of the Americas
New York, NY 10036
Martin G. Weinberg
Martin G. Weinberg, P.C.
20 Park Plaza, Suite 1000
Boston, MA 02116
EFTA00019410


c1: EFTA00018249
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018249.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Object of the conspiracy was to meet Epstein.docx
Date: Mon, 06 Jan 2020 13:48:49 +0000
Attachments: Object_of_the_conspiracy_was_to_meet_Epstein.docx
EFTA00018249


c1: EFTA00020372
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020372.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Original
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re: Second Warrant and Order For
Prospective and Historical Location
AMENDED APPLICATION
Information and Pen Register
Information for the Cellphone Assigned
20
Mag.
6828
Call Number
USAO
,
Reference No. 2018R01618
Amended Application for Second Warrant and Order
for Cellphone Location and Pen Register Information
The United States of America, by its attorney, Audrey Strauss, Acting United States
Attorney for the Southern District of New York,
Assistant United States
,
Attorney, of counsel, respectfully requests that the Court issue the accompanying proposed Second
Warrant and Order for prospective and historical location information and pen register information
for a cellphone. As grounds for this Amended Application the Government relies on the following
facts and authorities.
I. Introduction
1. I am an Assistant United States Attorney in the U.S. Attorney's Office for the Southern
District of New York. This Amended Application is submitted in conjunction with the
accompanying amended affidavit of a law enforcement agent ("Amended Agent Affidavit"), to be
sworn before this Court, and incorporated by reference herein. I make this Amended Application
based on information and belief, including the Amended Agent Affidavit, my review of other
documents in the case, and information received from investigative personnel.
2. The Investigating Agency, Target Cellphone, Subscriber, Target Subject, Service
Provider, Subject Offenses, Successor Service Provider, and Successor Cellphone referenced in
this Amended Application are as specified in the Amended Agent Affidavit.
2019.07.24
EFTA00020372

=== Page 2 ===
II. Legal Authority
A. Prospective Location Information
3. The Government seeks to obtain both precision location information and cell site data
for the Target Cellphone on a prospective basis (the "Prospective Location Information") for a
period of 45 days from the date of this order - the same period of time for which a warrant for a
tracking device may be granted under Rule 41(e)(2)(C). It bears noting, however, that while the
Prospective Location Information may permit "tracking" the user of the phone in the colloquial
sense, this is not an application for a warrant for a "tracking device" as defined in Fed. R. Crim.
P. 41(a)(2)(E) and 18 U.S.C. $ 3117(b). Those provisions only apply where an agent is seeking to
physically install a tracking device on a given object. Instead, the Prospective Location
Information will be obtained by requiring the Service Provider to provide the information.
4. The authority for this application is found in 18 U.S.C. § 2703(c)(1), which authorizes
a court of competent jurisdiction to require any electronic communication service provider (which
includes a cellular telephone service provider¹) to disclose any "record or other information
pertaining to a subscriber" other than the "contents of communications," when the government
obtains, inter alia, a warrant under the applicable procedures of Rule 41. See 18 U.S.C. $
2703(c)(1)(A). Because data concerning a subscriber's location, such as precision location
information and cell site data, constitutes "information pertaining to a subscriber" that does not
include the "contents of communications," that data is among the types of information available
1 See 18 U.S.C. $ 2711(1) (incorporating by cross-reference statutory definitions set forth in 18
U.S.C. $ 2510); 18 U.S.C. $ 2510(15) (defining "electronic communication service" as "any
service which provides to users thereof the ability to send or receive wire or electronic
communications").
2
2019.07.24
EFTA00020373

=== Page 3 ===
under $ 2703(c)(1)(A).² Further, as specified in 18 U.S.C. $ 2711(3), this Court is a court of
competent jurisdiction under the Stored Communications Act because it has jurisdiction over the
Subject Offenses.
5. The Government's request for cell site data also implicates the pen register statute,
because such data constitutes signaling information used by the Service Provider to route
communications to and from the Target Cellphone. In order to collect such data, a valid pen
register order is required.³ Accordingly, I hereby certify pursuant to 18 U.S.C. § 3122 that such
signaling information is relevant to an ongoing investigation being conducted by the Investigating
Agency into suspected violations of the Subject Offenses by the Target Subject.
B. Historical Location Information
6. The Government also seeks historical cell site data for the Target Cellphone for the
period from June 1, 2020 to the present (the "Historical Location Information"). Because such
data-like "Prospective Location Information"-constitutes information concerning a subscriber,
the Court is authorized to order the Service Provider to provide this data pursuant to a warrant
2 See In re Application, 460 F. Supp. 2d 448, 459-60 & n. 55 (S.D.N.Y. 2006) (Kaplan, J.)
(cellphone location information falls within $ 2703(c)(1)); accord, e.g., United States V. Caraballo,
963 F. Supp. 2d 341, 361 (D.Vt. 2013); In re Order, 632 F. Supp. 2d 202, 207 (E.D.N.Y. 2008);
In re Application, 405 F. Supp. 2d 435, 444-45 (S.D.N.Y. 2005). But see In re Application, 849
F. Supp. 2d 526, 574 (D.Md. 2011) (rejecting view that cellular location data falls within the scope
of the SCA and finding that phone must be treated as "tracking device" for purposes of Rule 41
where used to collect location data); In re Application, 2009 WL 159187, at *5-*6 (S.D.N.Y.
Jan. 13, 2009) (McMahon, J.) (same).
3 See 18 U.S.C. $ 3121 (prohibiting use of pen register or trap and trace device without an order
under the pen register statute); 3127(3) & (4) (defining pen register and trap and trace device to
include devices or processes that record, inter alia, signaling information). Although cell site data
constitutes "signaling" information within the meaning of the pen register statute, a separate statute
precludes the Government from relying "solely" on the authority provided by the pen register
statute to ascertain a subscriber's location. 47 U.S.C. § 1002(a). Here, the Government seeks to
obtain such data pursuant to 18 U.S.C. $ 2703(c) as well as the pen register statute, rather than
"solely" under the latter statute. See In re Application, 460 F. Supp. 2d at 456-59.
3
2019.07.24
EFTA00020374

=== Page 4 ===
application under 18 U.S.C. $ 2703(c), under the applicable procedures of Rule 41. See 18 U.S.C.
$ 2703(c)(1)(A). I respectfully submit that the same probable cause supporting the Government's
request for a warrant to obtain the Prospective Location Information requested above also supports
the issuance of a warrant under $ 2703(c) for the requested Historical Location Information. In
addition, the Government seeks toll records for the same period as the Historical Location
Information. Pursuant to 18 U.S.C. $ 2703(d), I respectfully submit that the Amended Agent
Affidavit offers specific and articulable facts showing that there are reasonable grounds to believe
that the toll record information sought is relevant and material to an ongoing criminal investigation.
C. Pen Register Information
7. Finally, the Government seeks an order pursuant to 18 U.S.C. §§ 3121-26 authorizing
the use of a pen register on the Target Cellphone for a period of 45 days from the date of this order.
Specifically, the Government seeks an order directing the Service Provider to furnish any
information, facilities, and technical assistance necessary to operate, unobtrusively and with
minimum disruption of service, a pen register and trap and trace device to capture all dialing,
routing, addressing, or signaling information associated with each call transmitted to or from the
Target Cellphone, as specified further in the proposed Second Warrant and Order (the "Pen
Register Information").⁴
4 The Government is also not seeking authorization to obtain post-cut-through dialed digits
("PCTDD"), or digits that are dialed after a telephone call from the Target Cellphone has been
connected. Pursuant to the attached Order, if possible, the Service Provider will forward only pre-
cut-through-dialed digits to the Investigating Agency. However, if the Service Provider's
technical capabilities require it to forward all dialed digits, including PCTDD, to the Investigating
Agency, the Investigating Agency will only decode and forward to the agents assigned to the
investigation the numbers that are dialed before the call is cut through.
4
2019.07.24
EFTA00020375

=== Page 5 ===
8. I hereby certify pursuant to 18 U.S.C. $ 3122 that the Pen Register Information is
relevant to an ongoing investigation being conducted by the Investigating Agency into suspected
violations of the Subject Offenses by the Target Subject.
D. Sealing and Non-Disclosure Order to Service Provider
9. When the Government obtains records or information under $ 2703(c), it is not required
to notify the subscriber or customer. 18 U.S.C. § 2703(c)(3). Additionally, the Government may
obtain an order precluding the Service Provider from notifying the subscriber or any other third-
party of the warrant or order obtained, for such period as the Court deems appropriate, where there
is reason to believe that such notification will result in endangering the life or physical safety of
an individual, flight from prosecution, destruction of or tampering with evidence, or intimidation
of potential witnesses, or will otherwise seriously jeopardize the investigation. 18 U.S.C.
$ 2705(b).
10. Further, 18 U.S.C. $ 3123(d) provides that an order directing installation of a pen
register or trap and trace device shall direct the pertinent service provider "not to disclose the
existence of the pen register or trap and trace device or the existence of the investigation to the
listed subscriber, or to any other person unless or until otherwise ordered by the Court."
11. Accordingly, as explained further in the Amended Agent Affidavit, in light of the
confidential nature of the continuing criminal investigation and the adverse consequences expected
in the event of premature notification, the Government respectfully requests that the Court direct
the Service Provider not to notify the Subscriber or any other person of the Second Warrant and
Order sought herein for a period of one year, subject to extension upon application to the Court, if
necessary.
12. For similar reasons, I respectfully request that the proposed Second Warrant and Order,
this Amended Application, and the accompanying Amended Agent Affidavit, be maintained under
5
2019.07.24
EFTA00020376

=== Page 6 ===
seal until the Court orders otherwise, except that the Government be permitted without further
order of this Court to serve this Second Warrant and Order on the Service Provider; provide copies
of the Second Warrant and Order or the supporting Amended Application and Amended Agent
Affidavit as need be to personnel assisting the Government in the investigation and prosecution of
this matter; and disclose these materials as necessary to comply with discovery and disclosure
obligations in any prosecutions related to this matter.
III. Prior Requests
13. As set forth in the Amended Agent Affidavit, the Government previously requested
Cellphone Location and Pen Register information for the Target Cellphone in an Application and
Agent Affidavit submitted on or about June 29, 2020. Also on or about June 29, 2020, United
States Magistrate Judge Katharine H. Parker granted the application and signed a Warrant and
Order for the requested information. On June 30, 2020, the Government learned that the Agent
Affidavit contained two inadvertent errors. Accordingly, the Government is submitting this
Amended Application and Amended Agent Affidavit to correct those errors and to seek a Second
Warrant and Order.
5 The original application also sought authorization for Cellphone Location and Pen Register
information for a second Target Cellphone,
,
which was identified as Target
Cellphone-1 in that application and which was also granted on or about June 29, 2020. Because
there were no errors in the application with respect to Target Cellphone-1, the Government does
seek a Second Warrant and Order with respect to that phone.
6
2019.07.24
EFTA00020377

=== Page 7 ===
14. Except as may be set forth above, no prior request for the relief requested herein has
been made.
Dated: New York, New York
June 30, 2020
Assistant United States Attorney
Tel.:
7
2019.07.24
EFTA00020378

=== Page 8 ===
Original
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re: Second Warrant and Order For
Prospective and Historical Location
AMENDED
Information and Pen Register
AGENT AFFIDAVIT
Information for the Cellphone Assigned
Call Number
USAO
,
Reference No. 2018R01618
20
Mag.
6828
Amended Agent Affidavit in Support of Second Warrant and Order
for Cellphone Location and Pen Register Information
STATE OF NEW YORK
)
) SS.
COUNTY OF NEW YORK )
,
being duly sworn, deposes and states:
I. Introduction
1. I have been a Special Agent with the Federal Bureau of Investigation ("FBI" or
"Investigating Agency") since 2017. As such, I am a "federal law enforcement officer" within the
meaning of Federal Rule of Criminal Procedure 41(a)(2)(C), that is, a government agent engaged
in enforcing the criminal laws and duly authorized by the Attorney General to request a search
warrant. I am currently assigned to investigate violations of criminal law relating to the sexual
exploitation of children as part of an FBI Task Force. I have gained expertise in this area through
classroom training and daily work related to these types of investigations. As part of my
responsibilities, I have been involved in the investigation of cases involving sex trafficking,
enticement of minors, and transportation of minors for illegal sex acts, and have participated in the
execution of search warrants involving electronic evidence.
2. Requested Information. I respectfully submit this Affidavit pursuant to 18 U.S.C.
§§ 2703(c) and (c)(1)(A) and the applicable procedures of Federal Rule of Criminal Procedure 41;
2019.07.24
EFTA00020379

=== Page 9 ===
18 U.S.C. §§ 2703(d) & 2705; and 18 U.S.C. §§ 3121-3126, in support of a second warrant and
order for prospective location information, historical location information, toll records, and pen
register information, for the Target Cellphone identified below (collectively, the "Requested
Information").
3. Basis for Knowledge. This Affidavit is based upon my participation in the
investigation, my examination of reports and records, and my conversations with other law
enforcement agents and other individuals, as well as my training and experience. Because this
Affidavit is being submitted for the limited purpose of obtaining the Requested Information, it
does not include all the facts that I have learned during the course of this 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. In addition, unless
otherwise indicated, statements by others referenced in this Affidavit were not necessarily made
to me, but may have been provided to me by someone else to whom I have spoken or whose report
I have read (and who in turn may have had either direct or indirect knowledge of the statement).
Similarly, unless otherwise indicated, information in this Affidavit resulting from surveillance
does not necessarily set forth my personal observations, but may have been provided to me by
other law enforcement agents who observed the events, and to whom I have spoken or whose
report I have read.
4. Target Cellphone, Subscriber, Target Subject, and Service Provider. The Target
Cellphone referenced in this Affidavit is the cellphone assigned call number
(the
"Target Cellphone"). As further discussed below, the Target Cellphone is subscribed to in the
name of "G Max" (the "Subscriber"). GHISLAINE MAXWELL is believed to use the Target
2
2019.07.24
EFTA00020380

=== Page 10 ===
Cellphone and is a Target Subject of this investigation. AT&T is the Service Provider for the
Target Cellphone.
5. Precision Location Capability. Cellphone service providers have technical
capabilities that allow them to collect at least two kinds of information about the locations of the
cellphones to which they provide service: (a) precision location information, also known as E-911
Phase II data, GPS data, or latitude-longitude data, and (b) cell site data, also known as
"tower/face" or "tower/sector" information. Precision location information provides relatively
precise location information about a cellphone, which a provider can typically collect either via
GPS tracking technology built into the phone or by triangulating the device's signal as received
by the provider's nearby cell towers. Cell site data, by contrast, reflects only the cell tower and
sector thereof utilized in routing any communication to and from the cellphone, as well as the
approximate range of the cellphone from the tower during the communication (sometimes referred
to as "per-call measurement" ("PCM") or "round-trip time" ("RTT") data). Because cell towers
are often a half-mile or more apart, even in urban areas, and can be ten or more miles apart in rural
areas, cell site data is typically less precise than precision location information. Based on my
training and experience, I know that the Service Provider has the technical ability to collect
precision location information from any cellphone on its network, including by initiating a signal
on the Service Provider's network to determine the phone's location. I further know that cell site
data is routinely collected by the Service Provider in the course of routing calls placed to or from
any cellphone on their network.¹
1 Toll records are sometimes necessary or helpful in order to obtain or interpret historical cell site
data and are therefore also requested herein.
3
2019.07.24
EFTA00020381

=== Page 11 ===
6. Successor Service Provider. Because it is possible that the Target Subject may change
cellphone service provider during the course of this investigation, it is requested that the warrant
and investigative order requested apply without need for further order to any Successor Service
Provider who may provide service to the Target Cellphone during the time frames at issue herein.
II. Corrected Facts Establishing Probable Cause
7. Although I understand that probable cause is not necessary to obtain all of the
Requested Information, I respectfully submit that probable cause exists to believe that the
Requested Information will lead to the location of a person, GHISLAINE MAXWELL, to be
arrested for the crimes of conspiracy to entice minors to travel to engage in illegal sex acts, in
violation of 18 U.S.C. $ 371; enticement of a minor to travel to engage in illegal sex acts, in
violation of 18 U.S.C. $ 2422; conspiracy to transport minors with intent to engage in criminal
sexual activity, in violation of 18 U.S.C. $ 371; transporting a minor with intent to engage in
criminal sexual activity, in violation of 18 U.S.C. $ 2423(a); and perjury, in violation of 18 U.S.C.
§ 1623 (the "Subject Offenses").
8. On June 29, 2020, a grand jury in the Southern District of New York returned an
indictment charging GHISLAINE MAXWELL with the Subject Offenses. The Indictment
charging MAXWELL is attached as Exhibit A hereto (the "Indictment"). That same day, United
States Magistrate Judge Lisa Margaret Smith signed a warrant for MAXWELL's arrest, which is
attached as Exhibit B hereto (the "Arrest Warrant").
9. In light of these pending charges in the Indictment and the issuance of the Arrest
Warrant, GHISLAINE MAXWELL is subject to arrest for the Subject Offenses.
10. Also on or about June 29, 2020, the Government submitted an Application and
accompanying Agent Affidavit seeking a Warrant and Order permitting the FBI to obtain, among
4
2019.07.24
EFTA00020382

=== Page 12 ===
other things, Cellphone Location Information and Pen Register Information for the Target
Cellphone. 1 Those documents were filed under the docket number 20 Mag. 6770. The original
Application and Agent Affidavit are attached as Exhibit C hereto. That same day, United States
Magistrate Judge Katharine H. Parker signed the requested Warrant and Order for the Target
Cellphone, also filed under docket number 20 Mag. 6770. The original Warrant and Order for the
Target Cellphone is attached as Exhibit D hereto. Pursuant to the Warrant and Order contained in
Exhibit D, the FBI subsequently obtained historical cell site and GPS location data for the Target
Cellphone. The collection of prospective location data pursuant to that Warrant and Order began
on or about June 30, 2020 and remains ongoing.
11. On the afternoon of June 30, 2020, and in the process of re-reviewing certain relevant
phone data in connection with another potential application, I realized that my June 29, 2020 Agent
Affidavit contained two inadvertent errors. First, the Agent Affidavit incorrectly stated that the
Target Cellphone had been in contact with a phone identified as the Isabel Maxwell Phone within
the last 30 days. In fact, the Target Cellphone was most recently in contact with the Isabel Maxwell
Phone in or about May 2020, or within the last 60 days, not the last 30 days. Second, the Agent
Affidavit incorrectly stated that the Target Cellphone had been in contact with a phone identified
as the Scott Borgerson Phone within the last 30 days. In fact, the Target Cellphone was most
recently in contact with the Scott Borgerson Phone in or about March 2020. The errors resulted
from my misreading of certain phone records for the Target Cellphone. In particular, while one
1 The original application also sought authorization for Cellphone Location and Pen Register
information for a second Target Cellphone,
,
which was identified as Target
Cellphone-1 in that application and which was also granted on or about June 29, 2020. Because
there were no errors in my affidavit with respect to Target Cellphone-1, this Amended Affidavit
does not seek a Second Warrant and Order with respect to that phone.
5
2019.07.24
EFTA00020383

=== Page 13 ===
column in those records indicated that the Isabel Maxwell Phone and Scott Borgerson Phone had
themselves been active within the last 30 days, I mistook those dates to be the dates of those
phones' most recent contact with the Target Cellphone. I submit this Amended Agent Affidavit
now to inform the Court of the error, to set forth a corrected statement of the facts supporting
probable cause, and to seek a Second Warrant and Order authorizing the FBI to continue receiving
prospective location data for the Target Cellphone.
12. As detailed in my original affidavit, and based on my review of AT&T records, I have
learned that the Target Cellphone is subscribed in the name of "G Max," which appears to be a
shortened version of GHISLAINE MAXWELL's name. I further know from my review of AT&T
records the following:
a. The Target Cellphone has been active within the last 30 days.
b. The Target Cellphone has been in contact with a phone subscribed to the
business "Haddon, Morgan, & Foreman," which I know from my review of court records is the
name of a law firm that currently represents GHISLAINE MAXWELL in civil litigation (the
"Haddon, Morgan, & Foreman Phone"). The most recent contact between The Target Cellphone
and the Haddon, Morgan, & Foreman Phone occurred within the last 30 days.
c. The Target Cellular Device has also been in contact with a phone subscribed to
in the name of "Laura Menninger," which I know from my review of court records is the name of
an attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
Menninger Phone"). The most recent contact between The Target Cellular Device and the Laura
Menninger Phone occurred within the last 30 days.
d. The Target Cellular Device has also been in contact with a phone subscribed to
in the name of "Isabel Maxwell," which I know from my review of a law enforcement database is
6
2019.07.24
EFTA00020384

=== Page 14 ===
the name of GHISLAINE MAXWELL's sister (the "Isabel Maxwell Phone"). The most recent
contact between The Target Cellular Device and the Isabel Maxwell Phone occurred in or about
May 2020.
e. The Target Cellular Device has also been in contact with a phone subscribed to
in the name of "Scott Borgerson," which I know from my review of bank records and Amazon
records is the name of an individual with whom GHISLAINE MAXWELL shares a joint bank
account and to whom MAXWELL's Amazon account has sent multiple packages within
approximately the last year (the "Scott Borgerson Phone"). The most recent contact between The
Target Cellular Device and the Scott Borgerson Phone occurred in or about March 2020.
13. Accordingly, I respectfully submit that there is probable cause to believe that the
location of the Target Cellphone will reveal the location of GHISLAINE MAXWELL.
III. Request for Second Warrant and Order
14. Based on the foregoing, I respectfully request that the Court require the Service
Provider to provide the Requested Information as specified further in the Second Warrant and
Order proposed herewith, including prospective precision location and cell site data for a period
of 45 days from the date of this Order, historical cell site data and toll records for the period from
June 1, 2020 through the date of this Order, and pen register information for a period of 45 days
from the date of this Order.
1.
Nondisclosure. The scope of this ongoing criminal investigation and existence of
the Indictment and Arrest Warrant are not publicly known. As a result, premature public disclosure
of this affidavit or the requested Second Warrant and Order could alert GHISLAINE MAXWELL
that she is under investigation and subject to arrest, causing her to destroy evidence, flee from
prosecution, or otherwise seriously jeopardize the investigation. Specifically:
7
2019.07.24
EFTA00020385

=== Page 15 ===
a. As evidenced by the charges alleged in the Indictment, MAXWELL is known
to have participated in acts of sexual abuse of minors. Alerting her to the existence and scope of
the investigation may lead her to intimidate witnesses. See 18 U.S.C. $ 2705(b)(1),(4).
b. Additionally, the Target Subject is at liberty in the community. Premature
disclosure of the existence of this application and the charges contained in the Indictment could
result in the Target Subject fleeing from prosecution if she were made aware of the pending charges
before arrest. See 18 U.S.C. $ 2705(b)(2).
15. Accordingly, there is reason to believe that, were the Service Provider to notify the
subscriber or others of the existence of the warrant, the investigation would be seriously
jeopardized. Pursuant to 18 U.S.C. $ 2705(b), I therefore respectfully request that the Service
Provider be directed not to notify the Subscriber or others of the existence of the Second Warrant
and Order for a period of one year, and that the Second Warrant and Order and all supporting
papers be maintained under seal until the Court orders otherwise, as specified in the Amended
Application submitted in conjunction with this Amended Affidavit.
S
Special Agent
Federal Bureau of Investigation
Sworn to before me this
30
day of June, 2020
*sworn to before me by reliable electronic means (telephone)
pursuant to Fed. R. Crim. P 4.1
Kathaw H Parke
HONORABLE KATHARINE H. PARKER
United States Magistrate Judge
Southern District of New York
8
2019.07.24
EFTA00020386

=== Page 16 ===
Original
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re: Second Warrant and Order For
Prospective and Historical Location
SECOND
Information and Pen Register
WARRANT AND ORDER
Information for the Cellphone Assigned
Call Number
USAO
Reference No. 2018R01618
20
Mag.
6828
Second Warrant and Order
for Cellphone Location Information and Pen Register Information
and for Sealing and Non-Disclosure
TO:
AT&T ("Service Provider"), and any subsequent provider of service to the Target
Cellphone specified below ("Subsequent Service Provider")
Federal Bureau of Investigation ("Investigative Agency")
Upon the Application and Agent Affidavit submitted by the Government in this matter:
I. Findings
The Court hereby finds:
1. The Target Cellphone (the "Target Cellphone") that is the subject of this Order is
assigned call number
is subscribed to in the name of "G Max" (the "Subscriber"),
and is currently serviced by the Service Provider.
2. Pursuant to 18 U.S.C. $ 2703(c)(1)(A) and the applicable provisions of Rule 41 of the
Federal Rules of Criminal Procedure, the Government's application sets forth probable cause to
believe that the prospective and historical location information for the Target Cellphone will reveal
the location of a person to be arrested for suspected violations of 18 U.S.C. §§ 371, 2422, 2423(a),
and 1623 ("the Subject Offenses").
3. Pursuant to 18 U.S.C. $ 2703(d), the Government's application also sets forth specific
and articulable facts showing that there are reasonable grounds to believe that the toll records for
the Target Cellphone are relevant and material to an ongoing criminal investigation.
2019.07.24
EFTA00020387

=== Page 17 ===
4. Pursuant to 18 U.S.C. $ 3123(b)(1), the Government has certified that the pen register
information for the Target Cellphone is relevant to an ongoing investigation by the Investigating
Agency of GHISLAINE MAXWELL and others unknown in connection with suspected violations
of the Subject Offenses.
5. Pursuant to 18 U.S.C. $ 2705(b), there is reason to believe that notification of the
existence of this Warrant and Order will result in flight from prosecution, and/or intimidation of
potential witnesses, or otherwise will seriously jeopardize an ongoing investigation.
NOW, THEREFORE, pursuant to Fed. R. Crim. P. 41, 18 U.S.C. §§ 3121 et seq., 18 U.S.C.
§§ 2701 et seq., and 18 U.S.C. $ 3103a, IT IS HEREBY ORDERED:
II. Order to Service Provider
6. Service Provider. This Order shall apply to the Service Provider specified above, and
to any subsequent provider of service to the Target Cellphone without need for further Order of
this Court.
7. Prospective Location Information. The Service Provider shall provide to the
Investigating Agency on a prospective basis, for a period of 45 days from the date of this Order,
information concerning the location of the Target Cellphone ("Prospective Location
Information"), including all available:
a. precision location information, including GPS data, E-911 Phase II data, and
latitude-longitude data; and
b. cell site data, including any data reflecting (a) the cell towers and sectors thereof
utilized in routing any phone, text, or data communication to or from the Target Cellphone, and
(b) the approximate range of the target phone from the cell towers during the communication
(including per-call measurement ("PCM") or round-trip time ("RTT") data);
2
2019.07.24
EFTA00020388

=== Page 18 ===
8. Historical Location Information and Toll Records. The Service Provider shall
provide to the Investigating Agency all available historical cell site location information reflecting
the cell towers and sectors thereof utilized in routing any phone, text, or data communication to or
from the Target Cellphone, and the approximate range of the target phone from the cell towers
during the communication (PCM/RTT data), for the period from June 1, 2020 through the present,
as well as all available toll records (including call detail, SMS detail, or data session detail records)
for the communications.
9. Pen register with caller identification and/or trap and trace device. The Service
Provider shall provide to the Investigating Agency, for a period of 45 days from the date of this
order, all dialing, routing, addressing, or signaling information associated with each voice, text, or
data communication transmitted to or from the Target Cellphone, including but not limited to:
a. any unique identifiers associated with the phone, including ESN, MEIN,
MSISDN, IMSI, IMEI, SIM, MIN, or MAC address;
b. source and destination telephone numbers and/or Internet protocol ("IP")
addresses;
c. date, time, and duration of the communication; and
d. cell-site information as specified above.
1 The Service Provider is not required to provide post-cut-through dialed digits ("PCTDD"), or
digits that are dialed after a telephone call from the Target Phone has been connected. If possible,
the Service Provider will forward only pre-cut-through-dialed digits to the Investigative Agency.
However, if the Service Provider's technical capabilities require it to forward all dialed digits,
including PCTDD, to the Investigative Agency, the Investigative Agency will only decode and
forward to the agents assigned to the investigation, the numbers that are dialed before the call is
cut through.
3
2019.07.24
EFTA00020389

=== Page 19 ===
10. Technical Assistance. The Service Provider shall furnish the Investigating Agency all
information, facilities, and technical assistance necessary to accomplish the disclosure of all of the
foregoing information relating to the Target Cellphone unobtrusively and with the minimum
interference to the service presently provided to the Subscriber.
11. Non-Disclosure to Subscriber. The Service Provider, including its affiliates, officers,
employees, and agents, shall not disclose the existence of this Warrant and Order, or the underlying
investigation, to the Subscriber or any other person, for a period of one year from the date of this
Warrant and Order, subject to extension upon application to the Court, if necessary.
4
2019.07.24
EFTA00020390

=== Page 20 ===
III. Additional Provisions
12. Compensation for Costs. The Investigating Agency shall compensate the Service
Provider for reasonable expenses incurred in complying with the Warrant and this Order.
13. Sealing. This Warrant and Order, and the supporting Application and Agent Affidavit,
shall be sealed until otherwise ordered by the Court, except that the Government may without
further order of this Court: serve this Warrant and Order on the Service Provider; provide copies
of the Warrant and Order or the supporting Application and Agent Affidavit as need be to
personnel assisting the Government in the investigation and prosecution of this matter; and
disclose these materials as necessary to comply with discovery and disclosure obligations in any
prosecutions related to this matter.
Dated: New York, New York
6/30/2020
10:08 a.m.
Date Issued
Time Issued
Kathaw H Parke
UNITED STATES MAGISTRATE JUDGE
Southern District of New York
5
2019.07.24
EFTA00020391


c1: EFTA00018869
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018869.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Re: Yo
Date: Tue, 27 Aug 2019 18:30:27 +0000
Great. The Epstein circus just wrapped up. It's been a day.
Sent from my iPhone
> On Aug 27, 2019, at 2:29 PM,
(USANYS)
wrote:
V
>
did a gorgeous redirect FYI
EFTA00018869


c1: EFTA00020141
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020141.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES DISTRICT COURT
VIRGIN ISLANDS
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 Little Saint James Island, U.S. Virgin Islands,
Application for Search and Seizure
Any Buildings or Other Structures Contained
Warrant
Thereon, and Any Locked or Closed
Containers/Items Contained Therein
DISTRICT OF THE VIRGIN ISLANDS) 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. As such, I am a "federal law enforcement officer" within the meaning of Federal Rule of
Criminal Procedure 41(a)(2)(C), that is, a government agent engaged in enforcing the criminal
laws and duly authorized by the Attorney General to request a search warrant. I have been
employed by the FBI for approximately two years, and I am currently assigned to investigate
violations of criminal law relating to the sexual exploitation of children. I have gained expertise
in this area through classroom training and daily work related to these types of investigations. As
part of my responsibilities, I have been involved in the investigation of sex trafficking cases, and
have participated in the execution of search warrants for physical premises.
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 seizing 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
1
2017.08.02
EFTA00020141

=== Page 2 ===
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 private island in the U.S.
Virgin Islands, known as Little Saint James, any buildings or other structures contained thereon,
and any closed containers/items contained therein. Little Saint James is an approximately 75 acre
island located approximately four miles off the southeast coast of St. Thomas Island. The Subject
Premises is depicted in the following photograph:
Little
James Island
Ledges of
Based on my conversations with a law enforcement agent who has reviewed publicly available
satellite information, images, and drone videos, I am aware that the Subject Premises contains
multiple structures, including but not limited to:
2
2017.08.02
EFTA00020142

=== Page 3 ===
a.
On the northeast end of the Subject Premises, there is a single story structure next to
a pool.
b.
On the southwest end of the Subject Premises, there is a single-story, four-wall
structure. The walls are painted with blue and white stripes. The structure has large double doors
as its main entrance and large windows on the three remaining walls.
c.
On the north east end of the Subject Premises, there are multiple structures. The
main structure is a single story residence (the "Main Residence") with a stone exterior, a blue roof,
and a white detailed exterior that includes white columns.
d.
A separate structure ("Residence One") with a blue roof and stone exterior is at the
back of the Main Residence, located at the end of the northeast tip of the island and surrounded by
coastline on two of its sides.
e.
A second larger structure ("Residence Two) is set between the Main Residence and
the coastline.
f.
Four smaller single story structures (the "Four Cabanas") are next to the Main
Residence and a large pool. All four smaller structures have blue roofs.
g.
A third large structure ("Residence Three") set off from the four smaller structures
and next to the coast line is painted white and has a blue roof. Residence Three appears to have
two levels throughout and also appears to be at a lower elevation than the Main Residence,
Residence Two, and the Four Cabanas.
h.
Behind Residence Three and along the coastline is a small roofed structure at the
end of a wooden dock (the "Dock House").
3
2017.08.02
EFTA00020143

=== Page 4 ===
i.
There are two single story sheds ("Shed One" and "Shed Two") that are located just
southwest of the Main Residence. Shed One and Shed Two appear to have a metal-like exterior
that is a green-blue color.
j.
Next to Shed One and Shed Two is a four wall structure that appears to have several
sally port type doors ("Maintenance One"). A second structure ("Maintenance Two") is next to
Maintenance One and has a white exterior with four sets of white double doors and three single
white doors.
k.
Near the center of the island is a single story structure ("Residence Four") that has a
stone exterior and blue roof. The front of "Residence Four" has three dark double doors.
1.
Next to the helicopter landing pad are two small blue roof structures ("Helipad
Buildings").
m.
On the west side of the Subject Premises on the coast is an approximately two-level
structure ("Residence Five") with a blue roof.
4.
As detailed further herein, at least through his death on August 10, 2019, the Subject
Premises was believed to be owned, possessed, and controlled by JEFFREY EPSTEIN.
C. The Target Subject and the Subject Offenses
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, Sections 1591 (sex trafficking of minors), and 371 (sex trafficking conspiracy) (the
"Subject Offenses") The Target Subjects of this investigation are known and unknown co-
conspirators of JEFFREY EPSTEIN, including but not limited to
4
2017.08.02
EFTA00020144

=== Page 5 ===
II. Probable Cause and the Initial Search Warrants
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 Southern District of New York
returned an Indictment charging JEFFREY EPSTEIN with violations of Title 18, United States
Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code, Section 371 (sex
trafficking conspiracy). A copy of the Indictment is attached hereto as Exhibit A and is
incorporated by reference. EPSTEIN was arrested pursuant to the Indictment on or about July 6,
2019, and had been detained pending trial at the Metropolitan Correctional Center ("MCC") in
New York, New York.
7.
On or about August 10, 2019, the Bureau of Prisons confirmed that JEFFREY
EPSTEIN had been found unresponsive in his cell at the MCC that morning, and was pronounced
dead shortly thereafter.
8.
Notwithstanding EPSTEIN's death, the sex trafficking investigation that led to his
indictment remains ongoing. In particular, Count One of the Indictment alleged that EPSTEIN
conspired with others to traffic minors, and further identified three individuals who worked for
EPSTEIN (identified in Exhibit A as "Employee-1", "Employee-2," and "Employee-3") and
facilitated EPSTEIN's abuse of minor girls by, among other things, arranging victims' encounters
with EPSTEIN and paying victims after these encounters. The individual identified in Exhibit A
as "Employee-2" is
a target subject of this investigation.
9.
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 Manhattan, New
York; West Palm Beach, Florida; and elsewhere. During that time and continuing to the present,
5
2017.08.02
EFTA00020145

=== Page 6 ===
EPSTEIN possessed and controlled a residence, which is described in Exhibit A as "the New York
Residence."
10.
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 New York Residence. In particular, and as alleged in the Indictment, when a victim
arrived at the New York Residence, she would be escorted to a room inside the New York
Residence 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
EPSTEIN typically
would also
Following each
encounter, EPSTEIN or one of his employees or associates paid the victim in cash.
11.
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.
12.
One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of
the FBI's investigation of EPSTEIN, I have participated in interviews with Victim-1, along with
6
2017.08.02
EFTA00020146

=== Page 7 ===
other law enforcement officers.¹ Based on my participation in those interviews and my
conversations with other law enforcement officers, I know 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 New York Residence. 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 New York
Residence and numerous individual rooms within the New York Residence. Victim-1 has
provided detailed descriptions of certain aspects of the interior of the Subject Premises, including
Victim-1's memory of specific details regarding the layout, furnishings, decorations, and floor
pattern of various areas within the Subject Premises. Among other details, Victim-1 recalled that
EPSTEIN typically abused her in a room she described as a "massage room," (the "Massage
Room"), which contained a massage table, and was decorated with artwork depicting naked
women, hung on walls that appeared to be adorned with fabric. In describing the sexual abuse that
occurred in the Massage Room, Victim-1 has stated that EPSTEIN would often
The July 6, 2019 Search Warrant of the Subject Premises
1 In meetings with the Government, Victim-1 has disclosed that,
She
has also disclosed
Victim-1 has also disclosed having
worked fo
Victim-1 is
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.
7
2017.08.02
EFTA00020147

=== Page 8 ===
13.
On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate
Judge, signed a search warrant authorizing a search of the New York Residence. The search
warrant is attached as Exhibit B and incorporated by reference herein.
14.
At approximately 6 p.m. on or about July 6, 2019, law enforcement officers (the
"Search Team") commenced executing the search warrant at the New York Residence. JEFFREY
EPSTEIN had been arrested on the charges contained in the Indictment shortly before the
execution of the search warrant. Based on the Search Team's observations during an initial search
of the New York Residence, at approximately 7 p.m., the Search Team stopped the search and
froze the scene in order to seek a new search warrant. On or about July 7, 2019, the Honorable
Barbara Moses, United States Magistrate Judge, signed a search warrant authorizing a search of
the New York Residence (the "Second Warrant"). The Second Warrant is attached as Exhibit C,
and incorporated by reference herein. At approximately 2:30 a.m., the Search Team resumed the
search, and commenced searching pursuant to the Second Warrant. Later on July 7, 2019, the
Honorable Barbara Moses, United States Magistrate Judge, signed a third search warrant to search
and seize certain electronic media stored on discs seized during the execution of the Second
Warrant (the "Compact Disc Search Warrant"). The search warrant is attached as Exhibit D, and
incorporated by reference herein.
15.
During the execution of the warrants described above on the New York Residence,
the Search Team located evidence of the Subject Offenses. In particular, the Search Team located
the following, among other items:
c.
Inside the Subject Premises, I observed a room that, based on my participation in
interviews of 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 appeared to be a massage table. The
8
2017.08.02
EFTA00020148

=== Page 9 ===
room also contained several vibrating sex toys. The walls appeared 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. Thus, it appears that the Massage Room was in
substantially the same condition as Victim-1 observed the room more than 18 years ago.
d. Inside a safe in a closet on the third floor, the Search team discovered and seized,
among other items, several binders containing sleeves of compact discs, most of which are labeled
with handwriting. In total, the binders contain dozens of compact discs. Some discs contain the
word "Zorro" or "LSJ." Based on my conversations with law enforcement agents who have
participated in this investigation, I believe the name "Zorro" refers to Zorro Ranch, EPSTEIN's
property in New Mexico, and the name LSJ refers to Little Saint James, i.e., the Subject Premises.
The majority of the discs contain titles that include female names. Some of the discs in the binders
seized by the Search Team have titles that appear to refer to trips or vacations.
e. In the drawer of a dresser in a room on the Fifth floor of the New York Residence,
the Search team discovered and seized, among other items, a shoebox (the "Shoebox") containing
numerous compact discs. The majority of the discs are labeled, in handwriting, with female names.
One disc is marked "Thai Massage." Another disc is marked "Blonde Girl Photo Shoot." Yet
another disc is marked "Misc. Girls Nude/Dinner--Scientists." The discs in the Shoebox were
seized by the Search Team. In another drawer of that same dresser, the Search Team discovered
loose polaroid photographs depicting young, nude females who, based on the training and
experience of law enforcement officers who observed them, appear to be teenagers.
f. In a closet on the Fifth Floor of the Epstein Residence, the Search Team discovered,
among other items, a box marked "women/old photos." The box contained, among other items,
9
2017.08.02
EFTA00020149

=== Page 10 ===
approximately seven compact discs, which are labeled with hand-written titles. One disc is marked
"nudes 00-24." Another is labeled "Photographer--
'03" The remaining discs contain titles
that include female names. All of the foregoing discs were seized by the Search Team.
g. In that same closet, the Search Team discovered numerous black binders containing
what appear to be print outs of digital photographs (with file names underneath) and compact discs.
The binders appeared to contain, among other photographs, photographs of nude or partially nude
young girls, some of which are in sexually suggestive poses. Based on the training and experience
of law enforcement officers who observed them, some of the young girls appear to be teenagers,
some of whom appear to be under the age of 18.
16.
Based on my conversations with law enforcement agents who have conducted an
initial review (the "Reviewing Agents") of the compact discs seized at the New York Residence
as described in paragraphs 15(b)-(e) above (the "Seized Discs"), I have learned that the discs
contain approximately thousands of nude or partially nude photographs of girls or young women,
many of which are in sexually suggestive poses. Based on my conversations with the Reviewing
Agents, who have particular training and experience relating to child erotica and visual depictions
of children in child exploitation cases, I have learned that the Reviewing Agents believe that many
of the nude or partially nude images they have reviewed appear to depict girls under the age of 18.
Certain of these images appear to have been taken at a tropical location, and/or were labeled "LSJ"
either in the image file name, or on the compact disc that contained the image. Based on the
foregoing, I believe that a portion of the foregoing photographs appear to have been taken at the
Subject Premises. In addition, I have learned that some of the file names are marked
which
are the initials of
As set forth below, I have interviewed an individual who has
10
2017.08.02
EFTA00020150

=== Page 11 ===
reported that
photographed her at the Subject Premises. Accordingly, I believe
that a portion of these photos may have been taken by
17.
On or about November 28, 2018, the Miami Herald began publishing a series of
articles relating to the defendant, his sexual misconduct with minors, and a previous investigation
into his conduct in Florida from in or about 2005 through 2008. The article included information
about
's role in EPSTEIN's sexual abuse of minors. Based on my participation
in this investigation, I have learned that bank records obtained by the Government appear to show
that just days later, on or about December 3, 2018, the defendant wired $250,000 from a trust
account to
This course of action, and in particular its timing, suggests that EPSTEIN
was attempting to influence
who might provide information against him in light of the
recently re-emerging allegations.
B. Probable Cause Regarding the Subject Premises
18.
Based on my review of property records, I believe that JEFFREY EPSTEIN has
been the owner of the Subject Premises since at least the time of the Subject Offenses. In
particular, it appears that an entity named "L.S.J., LLC" held title to the Subject Premises from in
or about 1998. In or about 2011, L.S.J., LLC transferred title to the Subject Premises to an entity
named "Nautilus, Inc.," for $10. On the transfer paperwork, EPSTEIN signed as the "sole
member" of L.S.J., LLC and as the "president and sole beneficial owner" of Nautilus, Inc.
19.
In addition, I believe that up until recently, the Subject Premises was JEFFREY
EPSTEIN's principal residence. In particular, I have reviewed sex offender registration data, and
have learned that, on or about June 17, 2019, EPSTEIN listed the Subject Premises as his primary
residence. At the time of EPSTEIN's arrest on or about July 6, 2019, I and other law enforcement
officers conducted an inventory search of EPSTEIN's personal effects, and observed that
11
2017.08.02
EFTA00020151

=== Page 12 ===
EPSTEIN was carrying a driver's license that listed the Subject Premises as EPSTEIN's home
address.
20.
As discussed herein, I believe that evidence of the Subject Offenses will be found at
the Subject Premises. In particular, based on my conversations with law enforcement agents who
have conducted an initial review of the Seized Discs, I have learned the following:
a. Many of the photographs appear to be labeled with file names that include "LSJ,"
which I believe stands for Little St. James.
b. As discussed above, photographs seized from the New York Residence appear to
depict nude or partially nude young girls, and a portion of those photos appear to have been taken
at the Subject Premises, based on the fact that (i) some of the photos appear to have been taken in
a tropical location, and (ii) some of the file names of the photographs and/or the labels on the discs
containing the files of nude or partially nude young girls in a tropical location are marked "LSJ,"
i.e., the Subject Premises.
c. Among the photographs seized from the New York Residence, the Reviewing
Agents identified partially-nude photographs of a young girl, labeled with the name of a particular
individual ("Individual-1"). The photographs appear to depict Individual-1 on a beach in what
appears to be a tropical location.
21.
In or about July 2019, I participated in an interview of Individual-1, with her
counsel present. Based on my personal observations, I believe that the photographs described in
Paragraph 17(c) depict Individual-1. During the course of the interview, Individual-1 stated that
she met EPSTEIN in 2003 when she was approximately 17, and that she travelled to EPSTEIN's
properties in New Mexico, Florida, and the U.S. Virgin Islands, i.e., the Subject Premises, before
12
2017.08.02
EFTA00020152

=== Page 13 ===
she turned 18. EPSTEIN paid for the trips, and would give Individual-1 money and gifts while
she traveled with him.
22.
During these trips, EPSTEIN sexually abused and assaulted her on approximately
four different occasions, all of which occurred before she turned 18. Individual-1 reported that
EPSTEIN raped her during two of these incidents. Indivdual-1 recalled that one or more of these
instances of sexual abuse occurred on the Subject Premises. Individual-1 further reported that,
when she was approximately 17,
asked to photograph her, and did in fact
photograph Individual-1 at the Subject Premises.
23.
In or about August 2019, I and another law enforcement officer interviewed an
individual ("Individual-2") who regularly performed work for JEFFREY EPSTEIN as a contractor
at the Subject Premises from approximately 1999 to 2005 or 2006. Individual-2 reported that, on
several occasions, Individual-2 observed photographs of what appeared to be nude or partially
nude young girls in several locations throughout the main residence of the Subject
Premises. Individual-2 recalled a photograph depicting
and two of girls, all of
three whom were topless; Individual-2 estimated that the two girls in the photograph appeared to
be approximately 15 or 16 years old. Individual-2 knew
to be EPSTEIN's assistant at
that time.
24.
Based on my review of flight logs from a private jet owned by JEFFREY EPSTEIN,
I have learned that
traveled to the U.S. Virgin Islands at least approximately
once a month between October 2001 and November of 2005. These records do not include any
travel
may have taken on commercial airlines.
25.
For all of these reasons, I am aware that
has spent significant
time at the Subject Premises and that evidence of her involvement, and potentially the involvement
13
2017.08.02
EFTA00020153

=== Page 14 ===
of other co-conspirators, may be located at the Subject Premises. In particular, flight logs from
EPSTEIN's private jet reflect that the individual identified in the Indictment as "Employee-3"
traveled to the U.S. Virgin Islands on approximately nine separate occasions. These records do not
include any travel Employee-3 may have taken on commercial airlines. As set forth in the
Indictment, Employee-3 scheduled victims' encounters with EPSTEIN.
26.
Based on my training, experience, and participation in this investigation, I believe
that there is probable cause that evidence of the Subject Offenses, such as photographs of
EPSTEIN's victims and co-conspirators, will be found at the Subject Premises. In particular,
information provided by Individual-1, with whom EPSTEIN engaged in sex acts at the Subject
Premises while Individual-1 was a minor, confirms that EPSTEIN engaged in conduct relevant to
the Subject Offenses at the Subject Premises. In addition, photographs on the Seized Discs
recovered during the search of the New York Residence depict other young and partially nude girls
photographed at the Subject Premises, which suggests that EPSTEIN brought those girls to the
Subject Premises and that, consistent with the accounts provided by Individual-1, Victim-1 and
other victims identified in the Indictment, EPSTEIN likely sexually abused them at the Subject
Premises as well. Evidence of co-conspirators' presence at the Subject Premises at times when
victims were abused, including photographs, may also be found at the Subject Premises. Indeed,
as noted above, Individual-2 has observed a photograph of
partially-nude young girls at
the Subject Premises.
27.
Moreover, while the sexual abuse described above occurred principally between
approximately 2002 and 2005, as evidence recovered from the New York Residence including the
Seized Discs makes clear, EPSTEIN continued to maintain substantial evidence of the Subject
Offenses up until the time he was arrested in 2019. Indeed, as described above, in addition to the
14
2017.08.02
EFTA00020154

=== Page 15 ===
Seized Discs, Epstein continued to maintain a "massage room" complete with a massage table and
various sex toys that remained similar in makeup and appearance to descriptions of the same room
provided by Victim-1 based on Victim-1's encounters with EPSTEIN in 2004.
28.
In addition, I believe that evidence of the Subject Offenses, including but not
limited to photographs/evidence created at the Subject Premises, may be located not only at the
New York Residence but also at the Subject Premises because (i) the Subject Premises was the
location of multiple photo shoots of young girls; (ii) the Subject Premises appears to have been,
for the last several years and up until the time of his arrest, EPSTEIN's primary residence; and (iii)
given its location, the Subject Premises is JEFFREY EPSTEIN's most private residence.
Therefore, given that EPSTEIN has maintained evidence of the Subject Offenses, he is likely to
have maintained some of that evidence in or on the Subject Premises. Moreover, given that there
is probable cause to believe that JEFFREY EPSTEIN and others, including
conspired to commit the Subject Offenses, evidence of EPSTEIN's involvement in trafficking
minors would also be relevant to the investigation of, and any future charges against, other
members of the conspiracy, such as
29.
According to international flight records that I have reviewed, a private jet owned
and utilized by Epstein has traveled to or from the U.S. Virgin Islands at least on or about April
14, 2019; May 5, 2019; May 18, 2019; and June 11, 2019. Accordingly, there is probable cause
to believe that EPSTEIN recently has been present at the Subject Premises.
30.
Based on my training and experience in investigating individuals who engage in sex
trafficking of minors, and who sexually exploit minors, such individuals often maintain
photographs of their victims, and/or other erotic images of minors, at their residences. Individuals
15
2017.08.02
EFTA00020155

=== Page 16 ===
who engage in such offenses often hoard such images in the privacy of their residences. In
particular, data related to their illegal activity is often stored on their computers.
31.
In my training and experience, individuals who store nude and/or sexually
suggestive photographs of minors on compact discs or other external storage devices typically
access those images from computers and other electronic devices in order to view those images,
and individuals who store such materials on compact discs typically store similar files on other
computing devices and storage devices.
32.
Based on my training and experience, I also know that, where computers are used in
furtherance of criminal activity, evidence of the criminal activity can often be found months or
even years after it occurred. This is typically true because:
Electronic files can be stored on a hard drive for years at little or no cost and users thus
have little incentive to delete data that may be useful to consult in the future.
Even when a user does choose to delete data, the data can often be recovered months or
years later with the appropriate forensic tools. When a file is "deleted" on a home
computer, the data contained in the file does not actually disappear, but instead remains
on the hard drive, in "slack space," until it is overwritten by new data that cannot be
stored elsewhere on the computer. Similarly, files that have been viewed on the Internet
are generally downloaded into a temporary Internet directory or "cache," which is only
overwritten as the "cache" fills up and is replaced with more recently viewed Internet
pages. Thus, the ability to retrieve from a hard drive or other electronic storage media
depends less on when the file was created or viewed than on a particular user's
operating
system,
storage
capacity,
and
computer
habits.
In the event that a user changes computers, the user will typically transfer files from the
old computer to the new computer, so as not to lose data. In addition, users often keep
backups of their data on electronic storage media such as thumb drives, flash memory
cards, CD-ROMs, or portable hard drives.
C. Return of ESI
33.
If the Government determines that the electronic devices are no longer necessary to
retrieve and preserve the data, and the devices themselves are not subject to seizure pursuant to
Federal Rule of Criminal Procedure 41(c), the Government will return these items, upon request.
16
2017.08.02
EFTA00020156

=== Page 17 ===
Computer data that is encrypted or unreadable will not be returned unless law enforcement
personnel have determined that the data is not (i) an instrumentality of the offense, (ii) a fruit of
the criminal activity, (iii) contraband, (iv) otherwise unlawfully possessed, or (v) evidence of the
Subject Offenses.
III. Conclusion and Ancillary Provisions
34.
Based on the foregoing, I respectfully submit there is probable cause to believe that
evidence of the Subject Offenses, and in particular the items described in Attachment A, 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
August , 2019
THE HONORABLE RUTH MILLER
UNITED STATES MAGISTRATE JUDGE
17
2017.08.02
EFTA00020157

=== Page 18 ===
EXHIBIT A
18
2017.08.02
EFTA00020158

=== Page 19 ===
EXHIBIT B
19
2017.08.02
EFTA00020159

=== Page 20 ===
EXHIBIT C
20
2017.08.02
EFTA00020160

=== Page 21 ===
EXHIBIT D
21
2017.08.02
EFTA00020161

=== Page 22 ===
ATTACHMENT A
I. Premises to be Searched-Subject Premises
The Subject Premises are particularly described as a private island in the U.S. Virgin
Islands, known as Little Saint James, any buildings or other structures contained thereon, and any
closed containers/items contained therein. Little Saint James is an approximately 75 acre island
located approximately four miles off the southeast coast of St. Thomas Island. The Subject
Premises is depicted in the following photograph:
Little
James Island
Ledges of
The Subject Premises contains multiple structures, including but not limited to:
a.
On the northeast end of the Subject Premises, there is a single story structure next to
a pool.
b.
On the southwest end of the Subject Premises, there is a single-story, four-wall
structure. The walls are painted with blue and white stripes. The structure has large double doors
as its main entrance and large windows on the three remaining walls.
c.
On the north east end of the Subject Premises, there are multiple structures. The
main structure is a single story residence (the "Main Residence") with a stone exterior, a blue roof,
and a white detailed exterior that includes white columns.
d.
A separate structure ("Residence One") with a blue roof and stone exterior is at the
back of the Main Residence, located at the end of the northeast tip of the island and surrounded by
coastline on two of its sides.
2017.08.02
EFTA00020162

=== Page 23 ===
e.
A second larger structure ("Residence Two) is set between the Main Residence and
the coastline.
f.
Four smaller single story structures (the "Four Cabanas") are next to the Main
Residence and a large pool. All four smaller structures have blue roofs.
g.
A third large structure ("Residence Three") set off from the four smaller structures
and next to the coast line is painted white and has a blue roof. Residence Three appears to have
two levels throughout and also appears to be at a lower elevation than the Main Residence,
Residence Two, and the Four Cabanas.
h.
Behind Residence Three and along the coastline is a small roofed structure at the
end of a wooden dock (the "Dock House").
i.
There are two single story sheds ("Shed One" and "Shed Two") that are located just
southwest of the Main Residence. Shed One and Shed Two appear to have a metal-like exterior
that is a green-blue color.
j.
Next to Shed One and Shed Two is a four wall structure that appears to have several
sally port type doors ("Maintenance One"). A second structure ("Maintenance Two") is next to
Maintenance One and has a white exterior with four sets of white double doors and three single
white doors.
k.
Near the center of the island is a single story structure ("Residence Four") that has a
stone exterior and blue roof. The front of Residence Four has three dark double doors.
1.
Next to the helicopter landing pad are two small structures with blue roofs
("Helipad Buildings").
m.
On the west side of the Subject Premises on the coast is an approximately two-level
structure with a blue roof ("Residence Five").
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:
1.
Any documents or communications with or regarding victims or potential victims
of the Subject Offenses or between EPSTEIN and co-conspirators to the Subject Offenses;
2.
Any photographs of victims or potential victims of the Subject Offenses, or co-
conspirators to the Subject Offenses.
2
2017.08.02
EFTA00020163

=== Page 24 ===
3.
Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger.
4.
Any documents evidencing the presence of co-conspirators at the Subject Premises.
5.
Records or other items that evidence ownership, control, or use of, or access to
devices, storage media, and related electronic equipment used to access, transmit, or store
information relating to the Subject Offenses, including, but not limited to, sales receipts,
warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved
usernames and passwords, user profiles, e-mail contacts, and photographs.
6.
Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. $ 2256(8).
7.
Any computer devices and storage media believed to be owned or used by
JEFFREY EPSTEIN including, but not limited to, desktop and laptop computers, disk drives,
modems, thumb drives, personal digital assistants, smart phones, digital cameras, scanners,
routers, modems, and network equipment used to connect to the Internet. In lieu of seizing any
such computer devices or storage media, this warrant also authorizes, in the alternative, the
copying of such devices or media for later review.
8.
Any items or records needed to access the data stored on any seized or copied
computer devices or storage media, including but not limited to any physical keys, encryption
devices, or records of login credentials, passwords, private encryption keys, or similar information.
9.
Any items or records that may facilitate a forensic examination of the computer
devices or storage media, including any hardware or software manuals or other information
concerning the configuration of the seized or copied computer devices or storage media.
10.
Any evidence concerning the identities or locations of those persons with access to,
control over, or ownership of the seized or copied computer devices or storage media.
11.
Any evidence concerning the ownership of the Subject Premises, and any maps or
other geographical guides to the Subject Premises.
3
2017.08.02
EFTA00020164


