# docs_fts_content

c1: EFTA00018128
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018128.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Subject: Call with FCA (Epstein)
Date: Tue, 03 Dec 2019 18:33:10 +0000
Importance: Normal
Attachments: unnamed
EFTA00018128


c1: EFTA00018549
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018549.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Jimenez 302
Date: Fri, 30 Aug 2019 16:53:33 +0000
Attachments: Jimenez_302.pdf
Finalized 302 Jimenez (Inmate)
Special Agent
FBI New York Field Office
Violent Crimes Task Force
Desk:
Cell:
EFTA00018549


c1: EFTA00017849
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017849.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Re:
)
- Epstein
Date: Sat, 04 Sep 2021 01:50:24 +0000
Good for me
On Sep 3, 2021, at 6:31 PM,
)
wrote:
This works for me and I'd be inclined to book it, but let me know if this doesn't work for you.
is free
then.
Begin forwarded message:
From:
o
Date: September 1, 2021 at 10:06:37 PM PDT
To:
)"
Subject: Re:
)
- Epstein
Hi
,
Hope your travel this week goes well. I spoke with
and it looks like we are both available 9/30 - 10/1. Let me
know if that works on your end. If not, we can look at dates in October.
Thanks,
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
<image001.png>
From:
Date: Friday, August 27, 2021 at 10:49 AM
To:
)
Subject: Re:
)
- Epstein
I'm free most of the day, feel free to call my cell at your convenience
EFTA00017849

=== Page 2 ===
Sent from my iPhone
J
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
e
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 27, 2021, at 10:47 AM,
)
wrote:
Hi
I am going to be traveling for work next week, so my schedule is a little up in the air, but I'm free today if you have
time to talk. If not, I can touch base next week when my schedule settles a bit. Thanks!
From:
Nascimento
Sent: Friday, August 27, 2021 10:44 AM
To:
Subject: Re:
- Epstein
Good morning
,
I am hoping you have 5 min for a call in the next few days. Nothing urgent. Please let me know what works
for you.
Thanks,
Sent from my iPhone
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
2
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 9, 2019, at 9:47 PM,
)
wrote:
EFTA00017850

=== Page 3 ===
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,
wrote:
Yes, we will be there.
Sent from my iPhone
Joseph
, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 5:32 PM,
)
wrote:
Hi
Thanks for letting us know. Let's plan to meet on Tuesday. Would 11:30 work?
Thanks,
From:
Nascimento
Sent: Wednesday, September 4, 2019 10:13 AM
To:
Cc:
>;
Subject: Re:
- Epstein
Good morning,
Yes, we had to hunker down for 2 days but were spared. Thanks. For next week, the 10th, 11th or 13th
work best for me. Look forward to hearing from you.
EFTA00017851

=== Page 4 ===
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
Hope the storm missed you this week, and that you and your client are doing okay.
Our team is working out some scheduling issues today, and we should know more by this afternoon.
I'll plan to reach out then to discuss scheduling, if that's okay.
Thanks,
Sent from my iPhone
On Aug 30, 2019, at 9:52 AM,
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
EFTA00017852

=== Page 5 ===
On Aug 21, 2019, at 2:40 PM,
)
wrote:
Hi
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:
Nascimento
Sent: Monday, August 19, 2019 6:37 PM
To:
Cc:
)
is
)
Subject: Re:
)
- Epstein
Hi
,
Both the time and date work for us. Let me know the location when you have it confirmed.
Thanks,
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:
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,
EFTA00017853

=== Page 6 ===
From:
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,
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:
Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
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:
Nascimento
Sent: Thursday, August 1, 2019 8:10 PM
EFTA00017854

=== Page 7 ===
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.
Thanks,
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:
Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
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,
EFTA00017855

=== Page 8 ===
From:
Nascimento
Sent: Wednesday, July 17, 2019 6:25 PM
To:
Cc:
is
)
Subject: Re:
- - Epstein
Hi
,
That works for me. Please call me on my cell
(
). Thanks.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 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
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:
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,
EFTA00017856

=== Page 9 ===
As always, feel free to contact me at any time if we can be of further assistance. Look forward to
meeting again.
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:
Nascimento
Cc:
)"
,
)"
Subject: RE:
)
- Epstein
Hi
We will be at the Hilton in West Palm Beach, at
Please call me when you are
here, and we will meet you in the lobby.
Thanks,
From:
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,
Sent from my iPhone
EFTA00017857

=== Page 10 ===
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,
Nascimento
<mailto:
wrote:
Of course
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. B<x-apple-data-detectors://2/0>rd<x-apple-data-
detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors.//2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com/>
On Jul 10, 2019, at 11:34 AM,
<mailto:
wrote:
EFTA00017858

=== Page 11 ===
Would it be possible to meet earlier, perhaps at noon on Friday? Thank you.
Sent from my iPhone
On Jul 9, 2019, at 10:51 PM,
Nascimento
<mailto:
<mailto:
wrote:
,
Can we meet Friday, early afternoon (around 1-1:30)? Please send me your proffer letter.
Thanks,
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors:.//2/0>2250 S.W. B<x-apple-data-detectors:/2/0>rd<x-apple-data-
detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors.//2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
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:
We ended up slotting in a few things in the interim, but we're still good for 6:30 for sure.
thanks,
From:
Nascimento
<mailto:
<mailto:
Sent: Tuesday, July 09, 2019 16:43
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
)
<mailto:
<mailto:
Subject: Re:
)
- Epstein
EFTA00017859

=== Page 12 ===
Hi
,
I got done a little earlier today - do you want to bump up our call time?
Sent from my iPhone
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. <x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0> Avenue<x-apple-
data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com><http://www.crimlawfirm.com/
On Jul 9, 2019, at 10:02 AM,
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:
Nascimento
<mailto:
<mailto:
Cc:
)"
<mailto:
<mailto:
)"
<mailto:
<mailto:
Subject: RE:
)
- Epstein
Sure, thanks - and yes, quite the weekend. If it's alright with you, let's do 10:00 a.m. on
EFTA00017860

=== Page 13 ===
Tuesday - you can reach us at
,
or we can also call you then if that's easier,
whatever you prefer.
thanks,
From:
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,
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. <x-apple-data-detectors:/2/0>rd<x-apple-data-detectors://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:
,
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.
EFTA00017861

=== Page 14 ===
thank you,
Assistant U.S. Attorney
Southern District of New York
From:
Nascimento
<mailto:
<mailto:
Sent: Saturday, July 06, 2019 22:55
To:
<mailto:
<mailto:
Subject:
)
- Epstein
Begin forwarded message:
From:
<mailto:
<mailto:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
mailto:
Subject:
)
- Epstein
Mr.
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,
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2
x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0> Avenue<x-apple-
data-detectors://2/0>
EFTA00017862

=== Page 15 ===
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/
EFTA00017863


c1: EFTA00017898
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017898.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein victim call
Date: Wed, 10 Mar 2021 21:12:55 +0000
Just FYI, got another call from Ms.
this afternoon, looking for
follow-up. We did not discuss anything
substantive, and I said I would pass along that she had called.
From:
-
Sent: Thursday, February 25, 2021 12:46
To:
(
Cc:
Subject: Epstein victim call
Team, I just received
call on my desk line from
woman named
who identified herself as
former
client of
and said she was
former victim of Jeffrey Epstein. I asked if her attorney had been in touch with
either the prosecutors or the case agents, since we had previously contacted him, and she said she believed he had not
been. She said she had been in touch with an NYPD detective but had not heard back in some time. She said
represented her for purposes of the Victim Fund, but was not currently representing her. She provided her cell phone as
She did not provide any substantive information on the call, and I did not ask for any. I advised that
someone would follow up with her, hopefully in the next week or so. The call lasted less than three minutes.
For context, we were in touch with Mr.
several times in 2020 when he claimed to represent at least nine Epstein
victims, all of which he said were unwilling to speak with us. He subsequently said one victim might be willing to speak
with us, but then stopped responding to our requests for the complaints he had purportedly filed (but which we couldn't
find online). I believe the last communication we had with him was the attached.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00017898


c1: EFTA00018598
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018598.pdf
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=== Page 1 ===
From:
(IMD) (FBI)"
To:
)"
Cc:
)"
(NY) (FBI)"
"Byrne, Paul (NYPD)"
(USANYS)"
Subject: RE: Epstein investigation
Date: Mon, 26 Oct 2020 19:57:14 +0000
Good afternoon AUSA
My apologies for the delay. I'm looking into this matter. Waiting for a response from the FOIA team that process media. I
should have a response shortly.
Thanks,
Unit Chief
Litigation Support Unit/RIDS
(work)
(cell)
Confidentiality Statement: This message is transmitted to you by the Litigation Support Unit of the FBI's
Information Management Division. This message, along with any attachments, may be confidential, law
enforcement sensitive, and legally privileged. If you are not the intended recipient of this message, please
destroy it without further retention or dissemination (unless otherwise required by law). Please notify the
sender of the error by separate e-mail or by calling
From:
Sent: Monday, October 26, 2020 3:41 PM
To:
(IMD) (FBI)
Cc:
);
(NY) (FBI) ; Byrne, Paul (NYPD) ;
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Epstein investigation
Hi
Just following up on this, thanks. Any information you could provide would be very helpful.
Thanks,
From:
Sent: Monday, October 19, 2020 6:34 PM
To:
(IMD) (FBI)
Cc:
is
(NY) (FBI)
>; ; BYRNE, PAUL
is
(USANYS)
Subject: RE: Epstein investigation
Hi
Hope you're doing well. As our team is reviewing these materials in connection with discovery, we wanted to follow up
with you about this project. In particular, we were hoping you could tell us how your office approached CDs that were in
the boxes of materials from Florida. We noticed in the scans we received some documents that looked like the attached
file - which looks like a photocopy of the CD. Were those materials downloaded by your office? If not, no worries at all,
we have them from the primary file, but we wanted to check with you to make sure we had the complete set of materials
you sent.
Thanks very much,
From:
)
Sent: Wednesday, February 13, 2019 9:53 AM
To:
(IMD) (FBI)
EFTA00018598

=== Page 2 ===
Cc:
is
(USANYS)
>;
(NY) (FBI)
>; BYRNE, PAUL
Subject: RE: Epstein investigation
Hi
Wanted to quickly check in to follow up on our conversations last week and earlier this week - I think you were able to
transmit the scanned records to
but I'm not sure whether that was just the 16,000 pages you mentioned when we
last spoke, or if you were able to get all 29,000 to her? And we're also hoping to confirm for sure that all the materials you
received were definitely scanned in, and to get an index or catalog of those materials (including what media was
included).
Another person on our team,
who's copied, is jumping in to coordinate on this, so if it's easier to chat via
phone her number is
and please let us know if anything would be helpful on our end.
thanks again!
From:
Sent: Wednesday, January 30, 2019 17:19
To:
(IMD) (FBI)
Cc:
is
(USANYS)
>;
(NY) (FBI)
>; BYRNE, PAUL
Subject: RE: Epstein investigation
Following up on our conversation from yesterday, wanted to send a quick email as promised so you have my full contact
info - I'm reachable at this email address or by phone at
Please don't
hesitate to reach out anytime day or night if we can provide any useful info, or if you have any questions at all, and we
appreciate you talking with us about the records information. Let us know if it makes sense to set up another call for
Friday or early next week to check in on the questions we had, and thanks very much for your help.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00018599


c1: EFTA00019929
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019929.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Robert Glassman
To:
Cc:
Subject: Re: bail application
Date: Wed, 02 Dec 2020 23:32:10 +0000
Thanks for the update
Robert S. Glassman
Panish Shea & Boyle
psblaw.com
On Dec 2, 2020, at 2:54 PM,
wrote:
Robert,
We wanted to let you know that Ghislaine Maxwell's attorneys intend to file a new bail application. The application has
not yet been filed, and we don't have a specific briefing schedule or hearing date. We will make sure to keep you
updated, but we wanted to touch base in advance to make sure you were aware. As always, please feel free to give us a
call if you have any questions or if you'd like to discuss this.
Thank you,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00019929


c1: EFTA00020137
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020137.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
ORIGINAL
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
Doc#2 In the Matter of the Search of
#2
UNITED STATES DISTRICT COURT
Be
for the
Southern District of New York
)
1 9MAG 6572
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case No.
See Attachment A
)
)
)
SEARCH AND SEIZURE WARRANT
To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Southern
District of
New York
(identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before
July 7, 2019
(not to exceed 14 days)
in the daytime 6:00 a.m. to 10 p.m.
at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USMJ Initials
I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box)
for
days (not to exceed 30).
until, the facts justifying, the later specific date of
Date and time
issued: 7.7.19 2:03a.m:
Bobelles Judge signature
City and state:
New York, NY
Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and title
EFTA00020137

=== Page 2 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Case No.:
Date and time warrant executed:
Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
EFTA00020138

=== Page 3 ===
ATTACHMENT A
I. Premises to be Searched-Subject Premises
1.
The premises to be searched (the "Subject Premises") are described as a multi-story
single-family residence located at
New York, New York, and include all locked
and closed containers found therein. A photograph of the front entrance to the Subject Premises
is included below:
Google
II. Items to Be Seized
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses
This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of
violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors) and 371
(sex trafficking conspiracy) (the "Subject Offenses") described as follows:
i. Any and all taxidermied dogs.
ii. Any and all massage tables and massage paraphernalia.
iii. Any and all busts or three-dimensional representations of female human
torsos.
iv. Any and all photos or representations depicting nude or partially nude
women located in the Massage Room, as defined herein.
V. Any and all sex toys and sex paraphernalia located in the Massage
Room, as defined herein.
2017.08.02
EFTA00020139

=== Page 4 ===
vi. A binder labeled "PB Girls" and any other documents or
communications with or regarding victims or potential victims of the
Subject Offenses.
2
2017.08.02
EFTA00020140


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=== Page 1 ===
STATE OF NEW MEXICO
OFFICE OF THE ATTORNEY GENERAL
STATE
SEAL GREAT of THE MEDICINE OFNEW
1912
HECTOR H. BALDERAS
ATTORNEY GENERAL
September 17, 2019
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Via email & U.S. Mail
Re:
Continued investigation into possible collaborators of Jeffrey Epstein
Dear Ms.
Thank you for speaking with myself and others from the New Mexico Office of the Attorney
General last week. Pursuant to our telephone conversation, this Office is providing the enclosed
materials related to the criminal investigation and potential prosecution of Jeffrey Epstein's
co-conspirators. The enclosed documents include police reports, recorded witness interviews,
correspondence amongst New Mexico State agencies, and documents related to Epstein's leasing
of New Mexico public lands.
As previously discussed, all conduct described in our investigation occurred prior to 2008, the
year New Mexico enacted its human-trafficking statute. See NMSA 1978, Sections 30-52-1 to
-2.1. Should you have any questions, require any law-enforcement assistance in New Mexico, or
become aware of any criminal charges implicating New Mexico law not barred by New
Mexico's statute of limitations, NMSA 1978, Section 30-1-8, I ask that you do not hesitate to
contact me directly.
Should further investigation reveal additional survivors of crimes occurring in New Mexico,
know that this Office intends to work in union with the United States Attorney for the District of
New Mexico to ensure that these brave survivors have the opportunity to see that justice is
achieved in a court of law. Again, please contact me personally if your investigation reveals
survivors of crimes occurring in New Mexico not mentioned in the provided investigative
materials.
TOLL FREE 1-844-255-9210 TELEPHONE: (505)490-4060 FAX: (505)490-4883 www.nmag.gov
MAILING ADDRESS: P.O. DRAWER 1508 - SANTA FE, NEW MEXICO 87504-1508
STREET ADDRESS: 408 GALISTEO STREET - SANTA FE, NEW MEXICO 87501
EFTA00017781

=== Page 2 ===
Epstein's death should not be the end of this criminal inquiry. I thus thank you for continuing to
give this serious matter the attention it deserves. This Office will continue to update you in a
timely manner should we become aware of any new information that could be assistive to you.
Respectfully,
Claim
Clara Moran
Chief Deputy Attorney General
EFTA00017782


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=== Page 1 ===
From:
(USANYS)"
To:
, Montell Figgins
Cc:
(USANYS)"
i
,
(USANYS)"
Subject: US V. Noel and Thomas - Letter
Date: Sat, 14 Mar 2020 12:53:55 +0000
Attachments: 2019.12.19_letter_to_KMK_re_MCC_tape.pdf;
2020.01.09_letter_to_KMK_re_MCC_tape_(final).pdf;
2020.03.14_Response_to_Defense_Discovery_Requests.pdf
Counsel,
Please see the attached response to your prior discovery requests, along with two attachments. We are available to
discuss any further if you have questions.
Thanks,
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00018947


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=== Page 1 ===
From:
)"
To:
Cc:
)"
(USANYS)"
)"
,
i
(NY) (FBI)"
Subject: SDNY Trial Subpoena
Date: Tue, 13 Jul 2021 20:04:19 +0000
Attachments: 2021.07.13_Court_Subpoena_
Sergeant
Thank you so much for meeting with us by video-conference today. As discussed, attached please find a trial subpoena
for the case in SDNY. We will reach back out in early November 2021 to prep via video. At that point, we will be able to
give you a better estimate of when you will likely be called to testify, and we can make arrangements for your travel and
hotel for trial.
In the meantime, please feel free to reach out if you have any questions or if any issues come up.
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00019871


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=== Page 1 ===
From:
To:
Subject: travel
Date: Tue, 18 Feb 2020 15:24:06 +0000
,
Just as a reminder, I'll be out of the office tomorrow and Wednesday
and I are traveling to Pensacola to interview
Epstein's houseman from the 1990s through 2002.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019062


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=== Page 1 ===
From:
To:
Subject:
Date: Fri, 12 Jul 2019 20:39:27 +0000
Importance: Normal
Attachments: 2019-07-12_JE_response_to_bail_release_request_draft_5_-_CLEAN.docx
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00018185


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=== Page 1 ===
From:
To:
Subject: [EXTERNAL]
(External Case No. 20 Cr. 330)
Date: Wed, 10 Nov 2021 16:49:21 +0000
Attachments: CRIM1153768_Response.xlsx
amazon
This is an official communication from Amazon.
Attached please find Amazon's response to the above-referenced request. For privacy and other legal reasons, we have redacted the titles of
expressive materials. Amazon reserves any and all objections that Amazon may have with respect to this law enforcement request,
including that the information and/or records requested are unusually voluminous in nature and that compliance with such order otherwise
would cause an undue burden on Amazon.
Sincerely,
Law Enforcement Response Team
Amazon.com, Inc.
NOTICE: This communication might contain privileged and/or confidential information. If you are not the intended recipient or you
believe that you have received this communication in error, please delete this message and do not print, share, or otherwise use this
message or its contents in any way. Please also indicate by reply email that you have received this communication in error and that you
have deleted it.
EFTA00017889


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
)"
Subject: Re: Epstein FOIA Atty Visit Logs and Count Slips
Date: Sat, 09 Jan 2021 17:51:51 +0000
Yes that's our reading of it.
Deputy Chief, White Plains Division
O:
C:
On Jan 9, 2021, at 12:27,
,
(USANYS)
wrote:
Am I correct that the documents appear to fall under paragraph 2 of the Protective Order?
From:
(USANYS)
Sent: Saturday, January 09, 2021 9:13 AM
To:
(USANYS)
Cc:
(USANYS)
is
Subject: Epstein FOIA Atty Visit Logs and Count Slips
Hi
Defense counsel in Tartaglione has requested to see the attorney visit logs and count slips that have Tartaglione's name
on them. Those documents may be covered by the attached protective order, and so we have asked
who is firewall counsel in Tartaglione, to receive the documents from you for potential production to defense counsel
(so that
and I do not see them).
is going to review the protective order first and determine whether
she needs Judge Karas to modify the order to allow her to receive the documents, so please don't send them to
until she reaches out. Thanks for helping with this - we know it is a pain.
Deputy Chief, White Plains Division
United States Attorney's Office
Southern District of New York
300 Quarropas Street
White Plains, New York 10601
Tel:
Cell:
EFTA00018558


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=== Page 1 ===
From:
Cc:
Subject: CNN - Epstein
Date: Fri, 16 Aug 2019 20:11:06 +0000
Importance: High
Hey guys,
CNN is pursuing a story about how
and
came to our Office in
2015/2016 to raise questions about the Epstein plea deal in Florida. Apparently through (with?) their attorney, they
talked to a sex trafficking or human trafficking AUSA (no name yet) about the issue. The reporter believes that it
was not raised to senior leadership at the time and it went nowhere.
CNN doesn't plan to run something immediately but knows that another reporter has similar information, so
if they feel their competition will go with the story, they will, too.
Any guidance or thoughts are welcome.
Public Affairs
U.S. Attorney's Office for the Southern District of New York
212-637-2600 (office)
212-637-2445 (direct)
Email:
Website: www.justice.gov/usao-sdny.
Facebook: https://www.facebook.com/usaosdny.
Follow us on Twitter: @SDNYnews
EFTA00019240


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
(USANYS)"
Subject: RE: Scanning
Date: Wed, 28 Aug 2019 17:24:23 +0000
The former, along with the date it was received and the location on the shared, if possible. Thank you!
From:
(USANYS) [Contractor]
Sent: Wednesday, August 28, 2019 1:21 PM
To:
(USANYS)
is
(USANYS)
Subject: RE: Scanning
The subpoena log is now updated. For the outstanding requests log would you like me to mark that something has been
received or just to delete it entirely from the spreadsheet?
From:
(USANYS)
Sent: Tuesday, August 27, 2019 6:45 PM
To:
(USANYS) [Contractor]
i
(USANYS)
Subject: RE: Scanning
Hey Will,
Could you please update the outstanding requests log and the subpoena log tomorrow? Thank you!
From:
(USANYS)
Sent: Tuesday, August 27, 2019 5:00 PM
To:
(USANYS) [Contractor]
i
(USANYS)
Subject: RE: Scanning
Awesome, thank you!
From:
(USANYS) [Contractor]
Sent: Tuesday, August 27, 2019 4:51 PM
To:
(USANYS)
is
(USANYS)
Subject: Scanning
The beast has been slayed.
I organized the files out of the jumble that they were brought to us in. A few things that will probably be helpful to know:
1. There were some commissary receipts/finance documents pertaining to Epstein's activity inside of prison. I didn't
know where to put this so I left it outside of the folders but still inside MCC Recs
2. In the MCC Regs folder, I put a few things:
a. One file had inventory and then at the end some documents pertaining to daily key counts. I wasn't sure
if these were different so I created a separate file for the key counts just in case (while also keeping them
in the inventory file)
b. The MCC training 06-06-19 & information file was confusing to me. It was massive and I couldn't tell
whether or not I needed to separate anything out.
EFTA00018872

=== Page 2 ===
Everything else should be pretty straightforward as to where it is located. Let me know if you need me to clarify anything
or help any further.
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=== Page 1 ===
From:
To:
Cc:
Subject: FW: Inside Edition Request
Date: Tue, 09 Jul 2019 19:21:43 +0000
Importance: Normal
I think this is officially the dumbest Epstein question so far.
From:
Sent: Tuesday, July 9, 2019 3:18 PM
To:
Subject: Inside Edition Request
Hello,
Inside Edition is asking if Anthony Weiner is expected to testify against Jeffrey Epstein?
Or if Mr. Weiner has cooperated in any way prior to Mr. Epstein's arrest?
Happy to answer any questions you may have.
Thanks,
Matt Sutherland
Sr. Booking Producer
Il
Inside Edition
EFTA00018400


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=== Page 1 ===
Event: Tentative: Epstein/Maxwell FOIA
Start Date: 2021-03-10 22:00:00 +0000
End Date: 2021-03-10 22:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2021-03-10 22:57:26 +0000
Date Modified: 2021-03-10 22:57:26 +0000
Priority: 5
DTSTAMP: 2021-03-10 20:20:34 +0000
Attendee:
(USANYS)
EFTA00017900


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
20 Cr. 330 (AJN)
V.
:
:
GHISLAINE MAXWELL,
:
:
Defendant.
:
:
X
REPLY MEMORANDUM OF GHISLAINE MAXWELL
IN SUPPORT OF HER RENEWED MOTION FOR BAIL
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone: 212-243-1100
Attorneys for Ghislaine Maxwell
EFTA00019291

=== Page 2 ===
TABLE OF CONTENTS
Page
PRELIMINARY STATEMENT
1
ARGUMENT
2
I.
The Government Concedes that Its Case Relies Almost Exclusively on the
Testimony of Three Witnesses
2
II.
The Government Has Not Carried Its Burden
4
A.
The Government Asks the Court to Ignore Ms. Maxwell's Substantial
Ties to the United States, Including Her Spouse
4
B.
Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All
of Her and Her Spouse's Assets in Support of Her Bond
5
C.
The Government's Assertion that Ms. Maxwell Is "Adept" at Hiding and
Therefore a Flight Risk Is Specious
7
D.
Extradition from France or the United Kingdom Is Highly Unlikely
8
E.
The Recent COVID Surge at MDC Further Justifies Bail
10
CONCLUSION
10
i
EFTA00019292

=== Page 3 ===
TABLE OF AUTHORITIES
Page(s)
Cases
United States V. Chen,
820 F. Supp. 1205 (N.D. Cal. 1992)
10
United States V. Orta,
760 F.2d 887 (8th Cir. 1985)
1
EFTA00019293

=== Page 4 ===
TABLE OF EXHIBITS
Exhibit A.
Julié Addendum Opinion (France)
Exhibit B.
Perry Addendum Opinion (U.K.)
EFTA00019294

=== Page 5 ===
PRELIMINARY STATEMENT
The only issue before the Court is whether conditions exist that can reasonably assure
Ms. Maxwell's appearance during this case. On this renewed application, Ms. Maxwell has put
before the Court a significant bail package, supported by detailed submissions, which warrant
her release on strict conditions. She and her spouse have committed to signing a bond in the full
amount of their net worth, regardless of the ownership of the underlying assets. She has
proffered seven additional sureties, consisting of her family and close friends, many of whom are
U.S. citizens and long-time residents, who have come forward at great personal risk and have
pledged meaningful assets. The government does not challenge the good faith and bona fides of
these proposed sureties. She has provided a detailed report from a respected accounting firm,
which was further reviewed by a former IRS special agent, setting forth a statement of her
financial condition, supported by voluminous documentation. The government does not
challenge the report's findings, nor its underlying documentation. She has agreed, in writing, to
give up any right she has or could have to contest extradition and submit to all other standard
travel restrictions. And she has noted that a key representation made by the government at the
initial bail hearing as to the strength of its evidence is simply not accurate -
and there is no "significant contemporaneous documentary
evidence" that corroborates its case.
With regard to any other defendant, this record would readily support release on strict
bail conditions, perhaps even on consent. But this is Ghislaine Maxwell, the apparent substitute
for Jeffrey Epstein. So, instead, in its response the government urges the Court to disregard the
significant additional evidence proffered to the Court and further argues that a defendant cannot
be eligible for bail (apparently on any conditions), unless she can provide an absolute guarantee
against all risks. But this is not the legal standard. United States V. Orta, 760 F.2d 887, 888 n.4,
EFTA00019295

=== Page 6 ===
892-93 (8th Cir. 1985) ("The legal standard required by the [Bail Reform] Act is one of reasonable
assurances, not absolute guarantees."). Under, the Bail Reform Act, a defendant must be released
unless there are "no conditions" that would reasonably assure her presence. Here, the proposed
package satisfies the actual governing standard, and the Court should grant bail.
ARGUMENT
I.
The Government Concedes that Its Case Relies Almost Exclusively on the
Testimony of Three Witnesses
In evaluating the strength of the government's case in its prior ruling, the Court relied on
the government's proffer that the testimony of the three accusers would be corroborated by
"significant contemporaneous documentary evidence." (Tr. 82 (emphasis added)). The
government now expressly retreats from this position. It is abundantly clear from the
government's response that it has no "significant contemporaneous documentary evidence"-in
fact, it has virtually no documentary corroboration at all-and that its case against Ms. Maxwell
is based almost exclusively on the recollections of the three accusers, who remain unidentified,
concerning events that took place over 25 years ago. Moreover, the government offers no
specificity about when within the four-year period of the charged conspiracy the alleged
incidents of abuse took place. This, alone, is grounds for the Court to reconsider its prior ruling.
The few examples of documentary corroboration referenced by the government-which
are the same examples that the government touted at the initial bail hearing-pertain to Epstein,
not Ms. Maxwell. The government concedes that
(Gov. Mem. at 11 (emphasis added)). The
government further states that
(Id.
(emphasis added)). The strength of the government's case against Jeffrey Epstein is not at issue
2
EFTA00019296

=== Page 7 ===
here. Whether or not the accusers' recollections as to Epstein are corroborated is irrelevant to
the strength of the evidence against Ms. Maxwell.
The only purported corroboration that pertains in any way to Ms. Maxwell is of marginal
value. The government references
(Id. at 11). But even the government concedes that, at best,
I
It is clear that the only evidence that Ms. Maxwell allegedly "groomed" the accusers or
knowingly facilitated or participated in Epstein's sexual abuse of minors will come solely from
the testimony of the three accusers. The government's case against Ms. Maxwell therefore rests
entirely on the credibility and reliability of these three witnesses. 2 Moreover, the substantive
counts (Counts Two and Four) are based on the testimony of only one witness, Minor Victim-1.
It is also telling that the government does not even attempt to rebut the defense's assertion that it
did not begin issuing subpoenas for documents related to Ms. Maxwell until just after the death
of Jeffrey Epstein. This confirms that the case against Ms. Maxwell was assembled after the fact
I The government also proffers that they will have "additional witnesses." (Gov. Mem. at 11). But these are not
"outcry" witnesses who will corroborate a contemporaneous account of abuse from one or more of the accusers.
Instead, they will testify only that "both [Ms. Maxwell] and Epstein knew and interacted with certain minor victims
when those victims were minors." (Id.). Again, the fact that Ms. Maxwell may have "met and interacted with"
someone when they were a minor proves absolutely nothing.
2 One of the witnesses has submitted a letter to the Court. While the CVRA permits the right to be heard, the letter
should be given no legal weight in the Court's bail analysis. See United States V. Turner, 367 F. Supp. 2d 319, 331-
32 (E.D.N.Y. 2005)
3
EFTA00019297

=== Page 8 ===
as a substitute for its prosecution of Epstein. 3 The government's case is not what it represented
to the Court at the initial bail hearing, which should weigh heavily in favor of granting bail. 4
II.
The Government Has Not Carried Its Burden
A.
The Government Asks the Court to Ignore Ms. Maxwell's Substantial
Ties to the United States, Including Her Spouse
The government incorrectly argues that the renewed bail application offers no new
information and that the Court was "already aware of" the defendant's friends and family in
the United States. (Gov. Mem. at 13). The government ignores that, since the initial bail
hearing, Ms. Maxwell's spouse has come forward as a co-signor and has submitted a
detailed letter describing his committed relationship with Ms. Maxwell for over four years
and the important role she has played, and continues to play,
It also ignores that several of Ms. Maxwell's closest friends and family, many of
whom are U.S. citizens and residents, have also come forward, at considerable personal risk,
to support her bond with pledges of assets or letters of support. This information, which
was not available to the Court at the time of the initial hearing, demonstrates Ms. Maxwell's
strong ties to this country and weighs heavily in favor of bail.
Rather than address the merits, the government attempts to dismiss the significance
of Ms. Maxwell's relationship with her spouse, noting that Ms. Maxwell told Pretrial
Services that she was in the process of getting a divorce and that her spouse did not step
forward as a co-signer at the initial bail hearing. (Id. at 13-14). The government is entirely
3 Moreover, the government failure to request
regardless of whether it was legally obligated to
do so, shows that the government has accepted the accusers' accounts without serious scrutiny. Given the
government's ongoing Brady obligations, it is unsettling that the government would simply accept
4 Contrary to the government's assertion, the defense has not abandoned our legal challenges to the indictment.
(Gov. Mem. at 10 n.1). We believe we have strong arguments that have only gotten stronger with the production of
discovery. We will be making those arguments to the Court in our pretrial motions to be filed next month.
4
EFTA00019298

=== Page 9 ===
mistaken. Prior to her arrest, Ms. Maxwell and her spouse had discussed the idea of getting
a divorce as an additional way to create distance between Ms. Maxwell and her spouse to
protect him
from the terrible consequences of being associated with her.
Nevertheless, in the weeks following the initial bail hearing,
She and her spouse therefore had no reason to continue
discussing divorce, which neither of them wanted in the first place. Nor was there any
reason for her spouse to refrain from stepping forward as a co-signer. In sum, the
government has offered nothing but unsupported innuendo to suggest that Ms. Maxwell's
relationship with her spouse
is not a powerful tie to this country.
The government's assertion that Ms. Maxwell must not have a close relationship
with
is particularly callous
and belied by the facts. (Gov. Mem. at 14). As her spouse explains,
(Ex. A 1 12).
B.
Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All of
Her and Her Spouse's Assets in Support of Her Bond
The government's attempts to rebut the financial condition report are unavailing.
Significantly, the government does not contest the accuracy of the report, nor the
voluminous supporting documentation. In fact, the government has proffered nothing that
calls into question the report's detailed account of Ms. Maxwell and her spouse's assets for
the last five years, which addresses one of the Court's principal reasons for denying bail.
Rather than question the report itself, the government attempts to argue that Ms.
Maxwell deceived the Court and Pretrial Services about her assets. (Gov. Mem. at 22-23).
5
EFTA00019299

=== Page 10 ===
The report shows nothing of the sort. Ms. Maxwell, who was sitting in a jail cell at the time,
was asked by Pretrial Services to estimate her assets. Accordingly, she gave her best
estimate of the assets she held in her own name, which the government concedes she did
with remarkable accuracy considering that she had not reviewed her financial statements. 5
The government's arguments further confirm that it has lost all objectivity and will
view at any fact involving Ms. Maxwell in the worst possible light. For example, the
government asserts that Ms. Maxwell has demonstrated "sophistication in hiding her assets"
and characterizes her transfers to a trust as "funneling" assets to her spouse to "hide her true
wealth." (Id. at 24). There is nothing unusual, let alone nefarious or even particularly
sophisticated about transferring assets into a trust or a spouse. Indeed, Ms. Maxwell fully
disclosed these transactions on her joint tax returns. More importantly, all of the assets
disclosed in the financial report, whether they are owned by Ms. Maxwell or her spouse, are
included in the bond amount and are subject to forfeiture if she flees.
The government further argues that the financial condition report shows that Ms.
Maxwell has access to millions of dollars of "unrestrained funds" that she could use to flee
the country and reimburse any of her sureties for the loss of their security. (Id. at 23). That
characterization is simply untrue. First, as disclosed in the financial report, Ms. Maxwell
has procured significant loans on the basis of a negative pledge over her London property.
Second, the $4 million controlled by her spouse
could only be liquidated with considerable difficulty.
The government also faults Ms. Maxwell for not including a valuation of future
contingent assets and income that may never materialize. (Id. at 23-24). For example,
5 Moreover, for the reasons discussed in our initial memorandum, Ms. Maxwell was reluctant to discuss anything
about her spouse and clearly expressed her reluctance to Pretrial Services early on in the interview.
6
EFTA00019300

=== Page 11 ===
Similarly, the financial report does not include
a future income stream for Ms. Maxwell or her spouse because it presents only historical
and current assets. Even so, Ms. Maxwell has no certain future income stream. Her spouse
and has had to liquidate his existing investments to help Ms. Maxwell. Finally, the
reference to
is gratuitous. Ms. Maxwell had no knowledge of
But the larger point is this: Ms. Maxwell has proposed a substantial bail package
with multiple co-signers and significant security. She and her spouse have pledged all of
their assets in support of the bond. Ms. Maxwell's wealth is not a reason to deny her bail. It
is a reason to set appropriately strict conditions that will result in significant financial
consequences to Ms. Maxwell and her friends and family if she leaves the country. The
proposed bail package does exactly that. 6
C.
The Government's Assertion that Ms. Maxwell Is "Adept" at Hiding and
Therefore a Flight Risk Is Specious
The government continues to assert the sinister narrative that Ms. Maxwell had "an
expertise at remaining hidden," and that it would therefore be easy for her to become a fugitive.
6 The government's argument that her spouse's moral suasion is diminished because Ms. Maxwell brought the
majority of assets to the relationship is nonsensical. (Id. at 24-25). Regardless of whose money it was to begin with,
all of the assets of Ms. Maxwell and her spouse will be forfeited if she flees and her spouse
will be
left with nothing. Furthermore, the government's assertion that they could not verify the spouse's financial
information because Ms. Maxwell did not provide his current banking information is false. (Id. at 24 n.9). The
defense provided the spouse's current banking records and only redacted the name of the bank.
7
EFTA00019301

=== Page 12 ===
(Gov. Mem. at 20). The government suggests that purchasing a home using a trust and providing
a pseudonym to a real estate broker are indicative of her willingness and ability to live in hiding
and somehow forecast Ms. Maxwell's intention to flee. (Id.). These arguments are just further
evidence that the government will frame every fact about Ms. Maxwell in the worst possible
light. As the defense has already argued extensively in its initial brief, these steps were borne
out of necessity to protect Ms. Maxwell and her family from harassment and physical threats.
Moreover, they are not predictive of flight. There is simply no basis to conclude, based on the
measures that Ms. Maxwell was forced to take to protect herself and her family, that she would
then willingly abandon that family to become a fugitive from justice. To the contrary, she
remained in the country precisely to remain close to them and to defend her case.
D.
Extradition from France or the United Kingdom Is Highly Unlikely
The government dismisses Ms. Maxwell's willingness to waive her extradition rights as
to France and the United Kingdom as "meaningless" because Ms. Maxwell cannot guarantee
with absolute certainty that either country will enforce the waiver. (Gov. Mem. at 14). The
government misses the point: Ms. Maxwell's willingness to do everything she can to eliminate
her ability to refuse extradition to the fullest extent possible demonstrates her firm commitment
to remain in this country to face the charges against her and, as Ms. Maxwell's French and U.K.
experts confirm, there is every reason to believe that both authorities would consider the waiver
as part of any extradition request.
In an attempt to counter William Julié's expert report stating it is "highly unlikely" that
the French government would refuse to extradite Ms. Maxwell (Def. Mem., Ex. V at 2), the
government attaches a letter from the French Ministry of Justice ("MOJ") that references neither
Mr. Julié's report nor Ms. Maxwell, but states generally that the French Code of Criminal
Procedure "absolutely prohibits" the extradition of a French national. (Gov. Mem., Ex. B). But
8
EFTA00019302

=== Page 13 ===
as Mr. Julié's accompanying rebuttal report explains (see Ex. A), the MOJ letter ignores that the
extradition provisions in French Code of Criminal Procedure apply only in the absence of an
international agreement providing otherwise. (Id. at 1). This rule is necessitated by the French
Constitution, which requires that international agreements prevail over national legislation. (Id.).
Thus, extradition of a French national to the United States is legally permissible if the extradition
treaty between the United States and France provides for it-which it does. (Id. at 3).
The government's reliance on a 2006 case-in which France refused to extradite a
French national who was also a U.S. citizen-provides no precedent as to how a French court
would rule on an extradition request regarding Ms. Maxwell because, as Mr. Julié notes, the
United States did not challenge the refusal in the French courts. (Id. at 2-3). Nor does it
undermine Mr. Julié's opinion that, in the unusual circumstance where a citizen of both countries
has executed an extradition waiver and then fled to France in violation of bail conditions set by a
U.S. court, it is "highly unlikely" that an extradition decree would not be issued. (Id. at 3).
The government offers no rebuttal to the opinion of Ms. Maxwell's U.K. extradition
expert, David Perry. Nor does it dispute Mr. Perry's opinion that Ms. Maxwell would be "highly
unlikely" to successfully resist extradition from the United Kingdom, that her waiver would be
admissible in any extradition proceeding, and that-contrary to the government's representation
at the initial bail hearing (Tr. 27)-bail would be "extremely unlikely." (See Def. Mem. Ex. U at
1 39). Mr. Perry's addendum opinion (attached as Ex. B) reiterates these points, opining that the
waiver would be "a highly relevant factor" in the U.K. proceeding, both to the likelihood of
extradition and to the likelihood of bail while the proceeding is pending. (Id.
7 Nor, as the government suggests, does the Secretary of State have general "discretion to deny extradition" after a
court has entered a final extradition order. (See Gov. Mem. at 19). That discretion is limited to a handful of
exceptional circumstances that would likely be inapplicable to Ms. Maxwell's case. (Id. " 4-5).
9
EFTA00019303

=== Page 14 ===
Finally, the government's argument that Ms. Maxwell could always flee to some country
other than the United Kingdom and France holds her-and any defendant-to an impossible
standard, which is not the standard under the Bail Reform Act. (See Gov. Mem. at 19). By the
government's reasoning, no defendant with financial means to travel could be granted bail,
because there would always be a possibility that they could flee to another country (even if they
had no ties there), and there could never be an assurance that any extradition waiver would be
enforced. However, "Section 3142 does not seek ironclad guarantees." United States V. Chen,
820 F. Supp. 1205, 1208 (N.D. Cal. 1992). To the extent that Ms. Maxwell's ties to France and
the United Kingdom-where she has not lived for nearly 30 years-create a flight risk, her
extradition waivers along with the substantial bail package proposed reasonably cure it.8
E.
The Recent COVID Surge at MDC Further Justifies Bail
The government suggests that the Court ignore COVID concerns because Ms. Maxwell,
though quarantined because of contact with an officer who tested positive, did not become
infected. This ignores the daily (sometimes multiple) inspections of Ms. Maxwell's mouth,
which heightens her risk of contracting the deadly virus, which has now surged to 113 positive
cases in the MDC. Further, Deputy Captain B. Houtz recently issued a memo stating that "[i]t
has not been determined whether legal calls and legal visits will continue." As the Court is well
aware, legal visits with Ms. Maxwell already have been suspended. Should legal calls also be
discontinued, her constitutional right to effective assistance of counsel will be further eroded.
CONCLUSION
For the foregoing reasons, Ms. Maxwell respectfully requests that the Court order her
release on bail pursuant to the strict conditions she has proposed.
8 Any incentive Ms. Maxwell might have to flee to France has been greatly diminished by the recent arrest in France
of Jean-Luc Brunel, who reportedly is under investigation for alleged sexual assaults by Jeffrey Epstein. See, e.g.,
France Details Modeling Agent in Jeffrey Epstein Inquiry, https://www.theguardian.com/world/2020/dec/17/france-
detains-modelling-agent-jean-luc-brunel-in-jefrey-epstein-inquiry.
10
EFTA00019304

=== Page 15 ===
Dated: December 18, 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
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone: 212-243-1100
Attorneys for Ghislaine Maxwell
11
EFTA00019305


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
(USANYS)"
Bec: "USAHUB-USAJournal111"
Subject: RE: laptop for MDC
Date: Wed, 28 Oct 2020 18:57:39 +0000
Embedded: RE:_laptop_for_MDC.msg
Sender:
Subject: RE: laptop for MDC
Message-Id:
<BN3P110MB029280C7991ED22808BA90B384170@BN3P110MB0292.NAMP110.PROD.OUTLOOK.COM
>
To:
Cc:
Cc:
EFTA00018252


c1: EFTA00019860
c2: DataSet 8
c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: US V Epstein
Date: Mon, 12 Aug 2019 19:00:59 +0000
We are in receipt of the below email and your email of yesterday afternoon at approximately 3:55 p.m. Without
conceding any obligations in connection of any of your requests, I expect that we will be in touch regarding your requests
and inquiries when we are able to fully respond, in the coming days. In terms of immediate steps, we do not expect that a
nolle will be submitted today.
thank you,
From:
Sent: Monday, August 12, 2019 08:55
To:
Cc:
Subject: US V Epstein
first if the emails regarding Mr. Epstein's death and our preservation/production requests on behalf of his family
should be sent to another prosecutor
had the name of
but not the full name) please advise. We
would ask you to confirm the request sent to you yesterday has been forwarded. We also request that DNA be lifted from
the ligatures and/or bed stripping found in Mr Epstein's MCC cell on August 10, 2019.
Separately, since the attorney client privilege survives death, we are still requesting a taint review in the event any review
at all of his emails from the seizures at Teterboro on Aug 6 or from his NYC residence are to be undertaken. If you provide
me with the name of the taint attorney when selected, I will provide a list of attorneys.
Lastly, is it the Government's intention to move to dismiss the Indictment against Mr. Epstein and if so will that occur
today?
Thanks, Marty
Martin G. Weinberg, Esq.
Boston, MA 02116
- Office
- Cell
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.
EFTA00019860


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=== Page 1 ===
From:
(USANYS)"
To:
(NY) (FBI)"
@fbi.gov>
Subject: Re: Time to chat?
Date: Thu, 05 Dec 2019 18:44:41 +0000
Sure - would 430 work?
Sent from my iPhone
On Dec 5, 2019, at 1:37 PM, Osborn, Michael A. (NY) (FBI) <maosborn@fbi.gov> wrote:
Hi Ted,
Any time this afternoon for a quick status call on Epstein?
-
On Nov 25, 2019 3:29 PM, "
(USANYS)"
wrote:
Let me know if you have a few minutes to connect later today or tomorrow. Thanks
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00018145


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=== Page 1 ===
From:
To:
)"
Subject: Transcript Request-19CR00490
Date: Tue, 27 Aug 2019 18:30:31 +0000
Attachments: J8RpEPSf.pdf
Hello:
Attached you will find a copy of Case No. 19-CR-490 as requested. Please confirm delivery.
Thank You,
EFTA00020126


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=== Page 1 ===
From:
)"
To: Joe Nascimento
Cc:
)"
)"
Subject: Re:
)
- Epstein
Date: Thu, 08 Aug 2019 01:20:57 +0000
Hi Joe,
That's no problem at all. In fact, our schedule for next week is in flux right now, so we will be in touch over the
next days to either confirm that new time or to discuss rescheduling. Apologies for the uncertainty, and thanks
for being flexible.
Sent from my iPhone
On Aug 7, 2019, at 4:54 PM, Joe Nascimento
wrote:
Hi
,
I just wanted to follow up re the August 14th meeting. Is it possible to schedule for early afternoon (anytime after 1)? I
have proactive cooperation ongoing in another case involving multiple jurisdictions, and they are looking to meet the
morning of 8/14. I understand if your schedule is already set, and will work around it.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
"
)"
Date: Friday, August 2, 2019 at 3:34 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Joe,
EFTA00019938

=== Page 2 ===
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.
Regarding the passport, thanks for flagging the issue, and we appreciate the effort to be transparent.
is free
to obtain a passport and travel as she wishes-there are no restrictions on her travel from our perspective, although we
very much appreciate the advance notice.
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.
,
now a U.S. citizen, does not have a U.S. passport. Occasionally, she has to travel for work and she is concerned
about having to travel to visit her parents in the event of a family emergency. She also has some travel plans over the
holidays (she cancelled a recent trip due to the current circumstances). She asked me to discuss with you whether it was
appropriate to apply for a passport, as she wants to be fully transparent with the Government. She understands the
likely need to postpone/cancel any personal travel plans for the time being.
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,
EFTA00019939

=== Page 3 ===
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
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
EFTA00019940

=== Page 4 ===
Good afternoon,
It was a pleasure to meet you yesterday. In light of the recent filing and media reports,
wanted me to clarify
her compensation with you. Aside from her regular salary, she did receive payments from Epstein in 2004 (to cover
gym membership and English classes), as well as a lump sum payment of cash during 2005 (less than $10k). Epstein
also paid for meals, salon appointments, clothing, etc. while she was working for him in 2005. You will not find any
lump sum payments made once she terminated her employment.
As always, feel free to contact me at any time if we can be of further assistance. Look forward to meeting again.
-Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, July 11, 2019 at 9:07 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Hi Joe,
We will be at the Hilton in West Palm Beach, at 600 Okeechobee Blvd. Please call me when you are here, and we will
meet you in the lobby.
Thanks,
From: Joe Nascimento
Sent: Thursday, July 11, 2019 9:02 PM
To:
Cc:
is
)
Subject: Re:
- Epstein
Good evening,
Have you set a location for our meeting tomorrow?
Thanks,
Joe
EFTA00019941

=== Page 5 ===
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 10, 2019, at 12:03 PM,
)
wrote:
Thank you, we will plan to see you then in West Palm Beach. We are still coordinating logistics, and we will
let you know that morning the address where we should meet.
Since we will be traveling, please feel free to call my cell if you need to reach us for any reason:
Thanks,
Sent from my iPhone
On Jul 10, 2019, at 11:39 AM, Joe Nascimento
<mailto:
wrote:
Of course
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 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,
EFTA00019942

=== Page 6 ===
Would it be possible to meet earlier, perhaps at noon on Friday? Thank you.
Sent from my iPhone
On Jul 9, 2019, at 10:51 PM, Joe Nascimento
<mailto:
<mailto:
wrote:
,
Can we meet Friday, early afternoon (around 1-1:30)? Please send me your proffer letter.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0>
<x-apple-data-detectors.//2/0> Avenue<x-apple-data-detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com-http/www.crimlawfirm.com/
On Jul 9, 2019, at 4:56 PM,
)
<mailto:
<mailto:
wrote:
Joe,
We ended up slotting in a few things in the interim, but we're still good for 6:30 for sure.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
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?
EFTA00019943

=== Page 7 ===
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. B<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.
thanks,
EFTA00019944

=== Page 8 ===
From: Joe Nascimento
<mailto:
<mailto:
Sent: Sunday, July 07, 2019 18:51
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
)
<mailto:
mailto:
Subject: Re:
)
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you. Let's set a time for
Tuesday morning (the earlier the better for me). Let me know what works for you.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. <x-apple-data-detectors://2/0>rd<x-apple-data-detectors./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.
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00019945

=== Page 9 ===
From: Joe Nascimento
<mailto:
<mailto:
Sent: Saturday, July 06, 2019 22:55
To:
<mailto:
<mailto:
Subject:
)
- Epstein
Begin forwarded message:
From:
<mailto:
<mailto:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
<mailto:
mailto:
<mailto:
<mailto:
N
<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 I 4th Floor
2250 S.W. <x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0> Avenue<x-apple-data-
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Miami Florida 33129<x-apple-data-detectors://2/0>
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From:
To:
Cc:
Subject: indictment review
Date: Thu, 25 Jun 2020 18:59:07 +0000
Hi
Hope you're doing well! We are presenting an indictment in the Epstein case to the White Plains grand jury on Monday
morning, and although the brass are still doing a final review, we hope to be able to send the indictment to you later
today for your review. The defendant is Ghislaine Maxwell. Apologies for not giving you more lead time to review - this
has moved more quickly than we expected, and the indictment has gone through several rounds of edits.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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From:
)"
To: john diaz
Cc:
)"
(USANYS)"
)"
Subject:
- trial subpoena
Date: Tue, 13 Jul 2021 19:41:34 +0000
Attachments: 2021.07.13_Court_Subpoena -
pdf
Hi John,
We've had multiple helpful prep sessions with
this summer, and we are planning to call him as a witness at
trial. Attached please find a subpoena requiring his testimony at the trial scheduled to begin on November 29, 2021.
Our team will let you and
know closer to trial what date he will be needed to testify. I expect he will testify
sometime in the second or third week of trial in December. We will reach out in early November 2021 to schedule
additional prep by VTC and to make travel and hotel arrangements for
In the meantime, if you or
have any questions, please feel free to reach out to our team.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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From:
To:
Subject:
outline
Date: Wed, 17 Nov 2021 15:19:00 +0000
Attachments:
outline.docx
Hey
Here's an outline for our conversation with
today. Of course you're in jury selection - it'd be great to get your
thoughts before the call, but I think we can also just do it and talk after, or you can read as
and I go through the
introductory stuff.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
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EXHIBIT 1

=== Page 2 ===
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case
UNITED STATES DISTRICT COURT
for the
Southern District of New York
United States of America
)
Ghislaine V Maxwell
)
)
Case No. 20CR330 (AJN)
)
Defendant
)
SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR
OBJECTS IN A CRIMINAL CASE
To: Jordana Feldman
(Name of person to whom this subpoena is directed)
YOU ARE COMMANDED to produce at the time, date, and place set forth below the following books, papers,
documents, data, or other objects:
See Attachment A
Place: United States District Court
Date and Time:
11/29/2021 8:30 am
Southern District of New York, Courtroom 318
40 Foley Square, New York, NY 10007
Certain provisions of Fed. R. Crim. P. 17 are attached, including Rule 17(c)(2), relating to your ability to file a
motion to quash or modify the subpoena; Rule 17(d) and (e), which govern service of subpoenas; and Rule 17(g),
relating to your duty to respond to this subpoena and the potential consequences of not doing so.
(SEAL)
Date:
CLERK OF COURT
Signature of Clerk or Deputy Clerk
The name, address, e-mail, and telephone number of the attorney representing (name of party)
Ghislaine Maxwell
, who requests this subpoena, are:
Jeffrey S. Pagliuca, Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203,
Notice to those who use this form to request a subpoena
Before requesting and serving a subpoena pursuant to Fed. R. Crim. P. 17(c), the party seeking the subpoena is advised to
consult the rules of practice of the court in which the criminal proceeding is pending to determine whether any local rules
or orders establish requirements in connection with the issuance of such a subpoena. If no local rules or orders govern
practice under Rule 17(c), counsel should ask the assigned judge whether the court regulates practice under Rule 17(c) to
1) require prior judicial approval for the issuance of the subpoena, either on notice or ex parte; 2) specify where the
documents must be returned (e.g., to the court clerk, the chambers of the assigned judge, or counsel's office); and 3)
require that counsel who receives produced documents provide them to opposing counsel absent a disclosure obligation
under Fed. R. Crim. P. 16.
Please note that Rule 17(c) (attached) provides that a subpoena for the production of certain information about a victim
may not be issued unless first approved by separate court order.
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AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 2)
Case No. 20CR330 (AJN)
PROOF OF SERVICE
This subpoena for (name of individual and title, if any)
was received by me on (date)
-
I served the subpoena by delivering a copy to the named person as follows:
on (date)
: or
I returned the subpoena unexecuted because:
Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of
$
My fees are $
for travel and $
for services, for a total of $
0.00
I declare under penalty of perjury that this information is true.
Date:
Server's signature
Printed name and title
Server's address
Additional information regarding attempted service, etc.:
Print
Save As...
Add Attachment
Reset
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AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 3)
Federal Rule of Criminal Procedure 17 (c), (d), (e), and (g) (Effective 12/1/08)
(c) Producing Documents and Objects.
(1) In General. A subpoena may order the witness to produce any books, papers, documents, data, or other objects the subpoena
designates. The court may direct the witness to produce the designated items in court before trial or before they are to be offered in
evidence. When the items arrive, the court may permit the parties and their attorneys to inspect all or part of them.
(2) Quashing or Modifying the Subpoena. On motion made promptly, the court may quash or modify the subpoena if compliance
would be unreasonable or oppressive.
(3) Subpoena for Personal or Confidential Information About a Victim. After a complaint, indictment, or information is filed, a
subpoena requiring the production of personal or confidential information about a victim may be served on a third party only by court
order. Before entering the order and unless there are exceptional circumstances, the court must require giving notice to the victim so that
the victim can move to quash or modify the subpoena or otherwise object.
(d) Service. A marshal, a deputy marshal, or any nonparty who is at least 18 years old may serve a subpoena. The server must deliver a copy
of the subpoena to the witness and must tender to the witness one day's witness-attendance fee and the legal mileage allowance. The server
need not tender the attendance fee or mileage allowance when the United States, a federal officer, or a federal agency has requested the
subpoena.
(e) Place of Service.
(1) In the United States. A subpoena requiring a witness to attend a hearing or trial may be served at any place within the United
States.
(2) In a Foreign Country. If the witness is in a foreign country, 28 U.S.C. $ 1783 governs the subpoena's service.
(g) Contempt. The court (other than a magistrate judge) may hold in contempt a witness who, without adequate excuse, disobeys a subpoena
issued by a federal court in that district. A magistrate judge may hold in contempt a witness who, without adequate excuse, disobeys a
subpoena issued by that magistrate judge as provided in 28 U.S.C. $ 636(e).
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ATTACHMENT A
DEFINITIONS
1. "You" or "Your" means any owner, shareholder, partner or employee of the Epstein Victim's
Compensation Program ("EVCP"), and any former owner, shareholder, partner or employee
of the EVCP.
2. "Accusers" or "Accuser" means
and
3. Attorneys means legal counsel for any Accuser or the EVCP.
4. "Communication" means all forms of correspondence, including regular mail, email, text
message, memorandum, or other written communication of information of any kind.
5. "EVCP Material" refers to any submission to the Epstein Victim's Compensation Program
made by an Accuser, including any claims on behalf of persons who have accused Jeffrey
Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their
Attorneys, and any compensation received by an Accuser.
INSTRUCTIONS
1. Production of documents and items requested herein shall be made in person to United States
District Court, Southern District of New York, 40 Foley Square, New York, NY 10007,
Courtroom 318.
2. This Request calls for the production of all responsive Documents in Your possession,
custody or control without regard to the physical location of such documents.
3. If any Document was in your possession or control, but is no longer, state what disposition
was made of said Document, the reason for the disposition, and the date of such disposition.
4. In producing Documents, if the original of any Document cannot be located, a copy shall be
produced in lieu thereof, and shall be legible and bound or stapled in the same manner as the
original.
5. Any copy of a Document that is not identical shall be considered a separate document.
6. All Documents shall be produced in the same order as they are kept or maintained by You in
the ordinary course of business.
7. Responsive electronically stored information (ESI) shall be produced in its native form; that
is, in the form in which the information was customarily created, used and stored by the
native application employed by the producing party in the ordinary course of business.
8. Defendant does not seek and does not require the production of multiple copies of identical
Documents.
9. This Request is deemed to be continuing. If, after producing these Documents, you obtain or
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become aware of any further information, Documents, things, or information responsive to
this Request, you are required to so state by supplementing your responses and producing
such additional Documents to Defendant.
DOCUMENTS OR THINGS TO BE PRODUCED
1. Any and all EVCP Material submitted by each Accuser, not limited to Claim Forms and
supporting submissions made by each Accuser;
2. Communications between the EVCP to each of the Accusers and/ or their Attorneys;
3. Copies of any payments to the Accusers and their Attorneys;
4. Any and All Releases executed by the Accusers.
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EXHIBIT 1

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Independent
Epstein Victims' Compensation Program
PROTOCOL
May 29, 2020
I.
PURPOSE AND OVERVIEW
The Epstein Victims' Compensation Program (the "Program") is a voluntary, independent Program that
has been established to compensate and resolve the claims of victims-survivors of sexual abuse by
Jeffrey Epstein ("Epstein").
The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims
administration experts Kenneth R. Feinberg, Camille S. Biros and Jordana H. Feldman to design the
Program. Ms. Feldman will also serve as the Administrator of the Program (the "Administrator"). This
Protocol reflects input from victims-survivors, their lawyers, other potentially interested parties, and
representatives of the Estate.
Through the Program, the Estate wishes to acknowledge the wrongs endured by victims-survivors and
offer them an opportunity to voluntarily resolve their individual claims for such sexual abuse.
The Program is governed by the following non-exclusive guiding principles:
The Program is purely voluntary. It does not affect any rights a Claimant may have
unless and until the Claimant accepts the offered compensation and executes a
Release. A Claimant may reject the offer of compensation and may stop
participating in the Program and withdraw the claim at any time prior to execution
of the Release.
The Program is independent and will in no way be administered, controlled or
overseen by the Estate. The Administrator is responsible for all decisions relating to
the review, processing and evaluation of individual claims submitted to the
Program. The Administrator will have final, binding and exclusive authority to
determine Claimant eligibility and the valuation of each eligible individual claim.
Decisions of the Administrator made pursuant to this Protocol are not subject to
review or modification in any way by the Estate or any other party or entity.
There is no cap or limitation on the aggregate amount of funds available to
compensate all eligible Claimants or on the amount of compensation to be made to
each individual Claimant. Each individual claim will be evaluated separately by the
Administrator. The Administrator will determine, in her sole and exclusive
discretion, issues of eligibility and the amount of compensation and the Estate will
pay all eligible claims based on the Administrator's determination.
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All Claimants will be treated with respect, dignity and fairness without regard to
race, color, sexual orientation, national origin, religion, gender or disability. To
ensure claims will be adjudicated fairly, the Administrator will manage the process
so that all Claimants can equally access the Program's claim process. Individuals
with disabilities will be given the opportunity to effectively communicate their
claims and to request special process accommodations.
The Program is available to all victims-survivors regardless of where they were harmed, when they were
harmed, whether the claim is time-barred by the applicable statute of limitations, and whether they
have previously filed a lawsuit against or settled with Epstein and/or the Estate.
The exclusive claims period for filing a claim pursuant to this Protocol shall commence on the to-be-
determined Effective Date and shall conclude nine (9) months after that date ("Filing Deadline"). All
individual claims filed with the Program must be filed within this period.
To complement the Program's resources, the Administrator will, at her discretion and with the consent
of the Claimant, consult with Professor Marci A. Hamilton, a nationally recognized sexual abuse expert,
leading legal academic and advocate of victims' rights. Ms. Hamilton's role will be to further inform the
Administrator and her staff about the dynamics of sexual abuse, common responses to sexual abuse,
and the impact of sexual abuse on victims; to serve as a resource for the Administrator in developing or
updating policies and procedures; to advise the Administrator regarding sensitivities involved in
interactions with victims; and to serve as a referral source for the Administrator in providing post-
determination information to claimants who seek guidance, counseling or other services. The
Administrator may, at her discretion and with the Claimant's prior written consent, request that Ms.
Hamilton review an individual claimant file. The Administrator will determine on a case-by-case basis, in
her discretion, the need to anonymize individual claimants' files before sharing them with Ms. Hamilton.
As set forth above, the Administrator is solely responsible for all decisions relating to the administration
of the Program, including the review, processing, evaluation, and determination of individual claims
submitted to the Program.
During the term of the Program, Ms. Hamilton will not meet or speak with a Claimant or her
representatives concerning any aspect of the Program without the Administrator present. Ms. Hamilton
will maintain in strict confidence and will not disclose outside the Program any information she obtains
through her participation in the Program, including individual Claimants' submissions.
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II.
ELIGIBILITY REQUIREMENTS
A. Eligibility Criteria
The persons eligible to participate in this Program are individuals who allege they were sexually abused
by Epstein. In addition, the following criteria apply:
The claim of sexual abuse must be directed against Epstein.
An individual whose claim is time-barred by the applicable statute of limitations may
participate in the Program provided that other eligibility criteria are met.
An individual who previously entered into a settlement agreement resolving a claim of sexual
abuse against Epstein may participate in the Program provided that other eligibility criteria are
met.
An individual who allegedly assisted Epstein in procuring other victims-survivors may
participate in the Program where there is a credible basis to determine that the individual
acted under duress as a result of her own sexual abuse by Epstein, provided that other
eligibility criteria are met.
If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with
prejudice any existing lawsuits, legal actions or claims filed against the Estate or related entities
and/or related individuals. The Claimant must provide proof of such dismissal along with or
prior to the signed acceptance of the compensation determination offer letter and executed
Release in order to receive payment.
B. Legal Representatives of Claimants
An individual may file a claim on a victim's behalf where that individual has been granted legal authority
to act in a representative capacity pursuant to appropriate law. The "Legal Representative" of an
individual Claimant shall mean: (1) in the case of a Claimant who is currently a minor, a parent or legal
guardian authorized by law to serve as the minor's legal representative; (2) in the case of an
incompetent or legally incapacitated Claimant, a person who has been duly appointed as the Claimant's
legal representative in accordance with applicable law; (3) in the case of a deceased Claimant, a person
who has been duly appointed to act as the personal representative of the Claimant's estate by a court of
competent jurisdiction and is authorized to file and compromise a claim; or (4) an attorney authorized to
represent the Claimant for purposes of pursuing a claim through this Program.
Legal Representatives must provide proper documentation demonstrating representative capacity. Such
proof may include a power of attorney; documentation showing the individual's appointment as
guardian or guardian ad litem; documentation showing the individual's appointment as personal
representative of the Claimant's estate (such as letters of administration); a copy of a retainer
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agreement showing legal representation signed by both the Claimant and the attorney or a signed
statement by an adult Claimant and the attorney that a licensed/admitted attorney is acting on her
behalf.
III.
CLAIMS ADMINISTRATION - SUBMISSION, EVALUATION AND DETERMINATION
A. Claims Submission Process
Individuals who have filed a lawsuit, legal action or claim against Epstein and/or the Estate or have
otherwise been identified as a victim of Epstein by their attorney to the Administrator on or before the
Effective Date will be sent a Claim Form and other relevant Program information, including Instructions
for completion and submission of the Claim Form and a copy of this Protocol. Individuals who have filed
a lawsuit need not agree to a stay of litigation or make any other concession in any pending litigation to
be eligible to participate in the Program. Likewise, individuals who have not yet filed a lawsuit remain
free to file a lawsuit and engage in litigation concurrently with participation in the Program. Individuals
must, however, dismiss with prejudice any and all existing lawsuits, legal actions and claims prior to or at
the time of acceptance of a compensation determination offer in order to receive payment.
Individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the Estate or have
not otherwise been identified as a victim of Epstein by their attorney to the Administrator on or before
the Effective Date may register to participate in this Program on the Program's website at
www.EpsteinVCP.com. To register, such individuals must complete a questionnaire setting forth their
name, contact information, a summary description of the nature of the claim and other requested
information. Upon registration, the Administrator will perform a preliminary review to consider if the
individual is eligible to participate in the Program. If the Administrator deems that the individual is
eligible to participate in the Program, she will then send that individual a Claim Form and other relevant
Program information.
Note: The fact that an individual is sent a Claim Form and other relevant Program information indicates
that the Administrator has determined that such individual is eligible to participate in the Program. It
does not indicate that the Administrator has determined that such individual is eligible to receive
compensation. That determination is made only after a Claim Form and all required documentation has
been submitted and evaluated by the Administrator.
Registrations for individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the
Estate or have not otherwise been identified as a victim of Jeffrey Epstein by their attorney to the
Administrator on or before the Effective Date will be accepted by the Administrator from the Effective
Date through a date that is 45 days prior to the Filing Deadline ("Registration Deadline"). It is important
to note that the Registration Deadline is separate from, and precedes, the Filing Deadline. As explained
above, all claims must be filed by the Filing Deadline.
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All Claim Forms must be completed to the best of a Claimant's ability and filed no later than the Filing
Deadline. Claim Forms should be uploaded to the Program website at www.EpsteinVCP.com, or mailed
via overnight courier (a pre-paid courier voucher will be included with each packet) to the Administrator
at the following address:
Epstein Victims' Compensation Program
Attn: Jordana H. Feldman, Administrator
Claimants are invited to provide documentation identified in the Claim Form, and any other
corroborating or supporting information sufficient to substantiate the claim, satisfy eligibility
requirements, and allow the Administrator to review, process and evaluate the claim. If the claim is
being presented by a Legal Representative, then the Legal Representative will be responsible for
submitting the necessary documentation relating to the represented Claimant.
Additional documentation may be requested at the discretion of the Administrator. Both the Claimant
and the Estate will be afforded the opportunity to submit to the Administrator any information deemed
relevant to the Administrator's evaluation and determination of the claim before the Administrator's
final disposition of the claim.
If a Claimant submits an incomplete or deficient claim, the Administrator will notify the Claimant,
explain the additional information that is needed, and work with the Claimant or the Claimant's Legal
Representative (where applicable) to assist in submitting a complete claim.
B. Claims Evaluation and Determination
Claims will be evaluated in the order in which they are received, with the Administrator evaluating each
submitted individual claim in a prompt and fair manner. Claims will only be determined once all
required documentation has been submitted to the Administrator, with due consideration granted to
Claimant's good faith explanations for delays and/or absence of documentation.
1. Factors Considered in Evaluating Claims
As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
information available, whether the allegations of sexual abuse are credible. The Administrator will
consider appropriate factors and corroborative support, including but not limited to:
The level of documentation, corroboration or other circumstantial evidence regarding the
nature and extent of the abuse, the frequency, location and other details of the abuse, and the
age of the victim at the time of the abuse. Non-exhaustive examples of such evidence include
(i) medical or psychiatric counseling/therapy records relevant to the abuse, and
(ii) contemporaneous written notification or other correspondence (e.g., letters, emails) of the
abuse by the Claimant to law enforcement authorities, parents, friends or others. The
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Administrator acknowledges that some Claimants may not be able to provide any
documentation to corroborate their Claim based on the nature and circumstances of Epstein's
conduct. If a Claimant's written and oral presentation is deemed to be credible by the
Administrator, the Claimant may still be eligible for compensation under the Program.
Whether there exists any information and/or pertinent findings offered by the appropriate
Office of the District Attorney, United States Attorney's Office, or other law enforcement
agency.
Whether the Administrator finds the claims of the individual to be credible after complete
review of all relevant documentation and other evidence provided by the Claimant and the
Estate.
As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
information available, the amount of compensation that should be offered to each eligible Claimant.
The Administrator will consider appropriate factors and corroborative support, including but not limited
to:
The nature, duration and extent of the sexual abuse suffered by the Claimant.
The age of the Claimant at the time of the sexual abuse.
The nature and extent of the Claimant's physical or psychological damage resulting from the
sexual abuse, and the effect of the sexual abuse on the Claimant.
The credibility of the claim based upon all of the facts and circumstances, supporting
documentation and corroborating evidence.
Whether the Claimant previously entered into a settlement agreement with Epstein and
received a payment pursuant to such agreement.
The Administrator will confidentially send the Claimant a compensation determination offer letter
including the following: (1) the Administrator's eligibility decision regarding the claim; (2) the amount of
compensation offered; (3) a Release to be signed by the Claimant if the Claimant accepts the offered
compensation; and (4) a Payment Option Form. The Administrator's offer shall be valid for 60 days from
the date of the compensation determination offer letter.
The Administrator's determinations in this Program will not be binding on any potential criminal
investigation involving Claimant's claims.
2. Opportunities to be Heard
The Claimant will be afforded an opportunity to be heard, either before or after the Administrator
renders her determination. Upon request by the Claimant, the Administrator will be available to meet in
person (as practicable in light of the COVID-19 pandemic), by video conference, or by teleconference to
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further discuss the claim. These meetings are completely optional and voluntary. Requests to meet
with the Administrator should be sent by email to ClaimantServices@EpsteinVCP.com and will be
scheduled at a mutually convenient time and location. The Administrator may also request a meeting
with a Claimant or her Legal Representative at a reasonable mutually convenient time and location,
though the Claimant is not obligated to attend any such meeting.
3. Release
By submitting a claim to the Program, a Claimant is seeking to resolve all claims relating to allegations
of sexual abuse against Epstein and/or the Estate, and related entities and individuals as set forth in the
Release. If a Claimant chooses to accept the offer of compensation pursuant to the Program, the
Claimant will be required to sign and execute a full Release, in a form satisfactory to the Estate, of all
past and future claims (including lis pendens, writs of attachment, etc.) relating to such allegations of
sexual abuse against the Estate, related entities and/or related individuals. A Claimant may reject the
offer of compensation and may stop participating in the Program and withdraw the claim at any time
prior to the execution of the Release.
The Release will waive any rights the Claimant and her heirs, descendants, legatees or beneficiaries
may have to assert any claims relating to allegations of sexual abuse against the Estate, related
entities and/or related individuals, to file an individual legal action relating to such allegations, or to
participate in any civil legal action associated with such allegations, except as a witness. However,
the Release will not operate to preclude or limit the Claimant's ability to report and discuss
allegations of sexual abuse with law enforcement officials or anyone else. In other words, the
Release will not impose any rules of confidentiality on claimants, who are expressly permitted to
discuss their allegations without restriction, should they choose.
Before signing a Release, the Claimant must consult with an attorney selected by the Claimant. If the
Claimant is not represented by an attorney, the Program will provide an attorney to provide free legal
counseling to the Claimant for the sole purpose of advising the Claimant concerning the language and
binding nature of the Release.
No one affiliated with the Program will provide tax or legal advice to those receiving payments under
the Program. Claimants are urged to consult with a tax advisor concerning any questions regarding
tax liability for payments pursuant to the Program.
4. Payments
Upon the Claimant's acceptance of the Administrator's determination, the Administrator's receipt of
the Claimant's executed Release and, where applicable, dismissal with prejudice of any existing
lawsuit, legal actions or claims against the Estate or related entities and/or related individuals, the
Administrator will initiate payment by check or electronic funds transfer to each eligible Claimant as
directed by the Claimant. Checks will be sent to Claimants via overnight courier service. All
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payments made under the Program shall be for a Claimant's physical injuries, physical sickness and
resulting emotional distress within the meaning of Section 104(a) of the Internal Revenue Code.
C. Program Integrity
For the purpose of protecting both the integrity of the Program and financial resources for eligible
Claimants, the Administrator will institute all necessary measures to prevent payment of fraudulent
claims, including taking steps to verify claims and analyze submissions for inconsistencies,
irregularities or duplication.
Each Claimant who signs the Claim Form at the time of submission certifies that the information
provided in the Claim Form is true and accurate to the best of the Claimant's knowledge, and that the
Claimant understands that false statements or claims made in connection with such submission may
result in fines, imprisonment and/or any other remedy available by law. Claims that appear to be
potentially fraudulent or to contain information known by the Claimant to be false when made will be
forwarded to federal, state or local law enforcement agencies and/or the appropriate Office of the
District Attorney and/or United States Attorney's Office for possible investigation and prosecution.
D. Confidentiality/Privacy
The Program is confidential.¹ By filing a claim with the Program, the Claimant or her Legal
Representative (where applicable) agrees that information submitted by the Claimant pursuant to
the Program will be used and/or disclosed by the Administrator and her designees only for the
following purposes:
1) Processing and evaluating the Claimant's claim;
2) Administering the Program and other Program-related work; and
3) Reports to law enforcement where appropriate, related to potentially fraudulent claims.
When documents or other information maintained or submitted by the Estate become part of a
Claimant's file for purposes of the Program, such materials will be reviewed by the Administrator to
assist in processing and evaluating the claim, but will otherwise remain confidential. No information
provided by Claimants will be provided to the Estate except for the Claimant's name and the date(s)
and location(s) of the alleged abuse, for the sole purpose of processing and evaluating the claim and,
for purposes of the Release, the names of any other individual(s) to whom or by whom the Claimant
alleges she was trafficked or sexually abused. The Estate has agreed that no information obtained
solely through the Program will be disclosed publicly or used by the Estate in defending itself from any
claim, regardless of forum. The Program's files are not available for inspection, review or copying by
the Estate or the Claimant or her representatives during or after the Program, and all pertinent
1 All parties agree that they are using the services of a third-party administrator to help reach a resolution of individual claims
of sexual abuse, and that this Program is entitled to confidentiality, privileges (mediation, settlement and all other pertinent
privileges), and protection from disclosure under applicable law.
8 I Page
EFTA00018207

=== Page 16 ===
mediation privileges, settlement privileges and other privileges apply.
To protect the privacy of Claimants participating in the Program, all personal information provided by
the Claimant during this process will be returned or destroyed within one year after the conclusion of
the Program.
Individual Claimants are not bound through the Program by any rules of confidentiality. Claimants may,
at their sole and voluntary option, disclose information in their possession regarding their claim, their
compensation and their experience with the Program.
All confidentiality requirements are subject to law, regulation and judicial process.
E. Reporting
The Administrator shall, on a monthly basis, confidentially provide reports regarding the number and
total value of claims paid each month to the Probate Court of the United States Virgin Islands and the
Attorney General of the United States Virgin Islands. Such reports will report on an aggregate level
only. No individual Claimant information will be published or disclosed in a way that compromises
Claimant confidentiality.
9 I Page
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From:
(USANYS)"
To:
(OPR)"
Subject: RE: OPR Matter
Date: Thu, 06 Aug 2020 19:31:08 +0000
Many thanks.
From:
(OPR)
Sent: Thursday, August 6, 2020 2:49 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: OPR Matter
Acting United States Attorney
for the Southern District of New York
New York, New York
Dear
--
Please find attached a letter from OPR Director
regarding OPR's draft report regarding the handling of the
Jeffrey Epstein matter by the U.S. Attorney's Office for the Southern District of Florida in 2006-2008. A copy of the draft
report, for your review, is also attached.
With regards,
Counsel
Office of Professional Responsibility
U.S. Department of Justice
950 Pennsylvania Avenue, N.W. - Room 3266
Washington, D.C. 20530
CC:
AUSA
EFTA00017797


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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
Cc:
(USANYS)"
Subject: RE: Epstein Associates
Date: Sat, 17 Aug 2019 20:59:47 +0000
Attachments: Epstein_universe.xlsx; 2019-08-15_-_SDNY_Production_Index.xlsx
That's an extremely expansive question. As one example, just from our research into his trafficking-related cases, we
identified more than 30 attorneys who have represented him (in connection with at least 20 cases in federal court alone).
Similarly, e.g., at just Deutsche Bank he had more than 60 separate accounts. From his AmEx records, he paid for nearly
5,000 flights for individuals (many repeating, obviously, but still) in the past ten years. Etc.
As a threshold reference, see the attached spreadsheet, particularly the "Witnesses and CCs" and "Epstein attys" tabs. On
bank accounts, see the attached Deutsche Bank index spreadsheet with 2,000 rows of account (and relevant individuals)
information. On associated individuals, a useful reference may be AmEx records, particularly the "AIRLINE" tab; that
document is much too large to send via email, but I've put a copy in the following folder that Nick you have access to:
In terms of people who would (or would potentially be able to) send money on his behalf, I think the likeliest individuals
would be Darren Indyke, Jeffrey Schantz, and/or
Obviously please let us know if you intend to contact or interview anyone in his world, and of course let us know if any
additional information would be helpful.
thanks,
From:
(USANYS)
Sent: Saturday, August 17, 2019 16:34
To:
is
-
Cc:
(USANYS)
Subject: Epstein Associates
Hi,
Do you folks have a list of current known associates of Epstein? Anyone, including an attorney or some other agent, who
he might communicate with, or who would send money on his behalf? Names, phone numbers, or bank accounts would
be helpful. Thanks!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00018951

=== Page 2 ===
New York, New York 10007
Tel:
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=== Page 1 ===
800 Third Avenue
COHEN & GRESSER LLP
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
Mark S. Cohen
Christian R. Everdell
November 25, 2020
TO BE FILED UNDER SEAL
VIA EMAIL (SUBMITTED PURSUANT TO SECTION 2(B)
OF JUDGE NATHAN'S INDIVIDUAL PRACTICES IN CRIMINAL CASES)
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, New York 10007
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
On behalf of our client, Ghislaine Maxwell, we plan to file a Renewed Motion for
Release on Bail (the "Motion") and respectfully request an in camera conference, with all
counsel present, to address the appropriate procedures for the filing and consideration of the
Motion. For the reasons explained below, we intend to request, pursuant to Fed. R. Crim. P.
49.1(d), that the Court permit the filing of portions of the Motion and certain supporting
materials under seal and require that any responsive materials be filed under seal. We believe an
in camera conference would be the most efficient form to address these issues and other
confidentiality concerns related to the Motion. We intend to provide a full set of materials to the
government, Pretrial Services, and the Court when the Motion is filed. We are merely requesting
that sensitive contents of the submission be accorded confidentiality protections similar to those
that the government routinely requires in protective orders, including the one in this case.
In the four months since this Court denied Ms. Maxwell's request for bail and granted the
government's motion for detention, Ms. Maxwell and her counsel have assembled substantial
information that was not available to present at the initial hearing, as well as a comprehensive
bail package co-signed by sureties who were unable to come forward at that time. Accordingly,
Ms. Maxwell now seeks to renew her request for bail pursuant to 18 U.S.C. § 3142(f).
Ms. Maxwell's renewed application will rely on sensitive and private information that, if
made public, would be highly damaging to both Ms. Maxwell and third parties, including:
Letters from Ms. Maxwell's family members and close friends, who have agreed to
serve as sureties to support Ms. Maxwell's renewed bail application. The letters
contain personal details that, if made public, would invite identification and
EFTA00017823

=== Page 2 ===
The Honorable Alison J. Nathan
November 25, 2020
Page 2
harassment of the sureties and other third parties, including minor children. They are
legitimately afraid that if their identities become public, they will be subjected to the
same relentless media scrutiny and threats that Ms. Maxwell has experienced for
more than a year, like the following sample of social media posts:
"they need to get this bitch n string her up by her neck
f*cking monster
#GhislaineMaxwell."
"I hope someone finds her and kills her. That would be justice. Obviously her
lawyers know's where she is, someone should stick them up to batteries untill we
find out where she is."
"SHE'S HERE in #Massachusetts ?! The bitch #GhislaineMaxwell who
#SexTrafficked young girls for #Epstein ?!?! Why the hell isn't she being brought in
for questioning @ManchesterMAPD ?! WE DO NOT WANT HER HERE!
#SleezyLeach She is CLOSE ENOUGH to me, I could grab her myself!"
A financial report, prepared by the accounting firm Macalvins Limited, that provides
a summary of Ms. Maxwell's financial condition from 2015-2020 and discloses all of
her assets, all assets held in trust, and assets held by other family members.
A discussion and analysis of certain materials produced by the government in
discovery marked "Confidential" and their impact on the government's case against
Ms. Maxwell, which must be filed under seal pursuant to the terms of the Protective
Order in this case (Dkt. 36).
Fed. R. Crim. P. 49.1(d) provides that "a court may order that a filing be made under seal
without redaction. The court may later unseal the filing or order the person who made the filing
to file a redacted version for the public record." While the Second Circuit has recognized a
presumption of access under both common law and the First Amendment, it is appropriate to
permit the filing of documents under seal if "countervailing factors" in the common law
framework or "higher values" in the First Amendment framework so demand. Lugosch V.
Pyramid Co. of Onandaga, 435 F.3d 110, 124 (2d Cir. 2006); see also Unites States V. Wey, 256
F. Supp. 3d 355, 411 (S.D.N.Y. 2017) (Nathan, J.) (granting motion to seal evidentiary exhibits
and finding that privacy interests "outweigh any public interest in disclosure, whether derived
from the First Amendment or the common-law right of access").
Moreover, a lower presumption of public access applies to documents submitted in
connection with powers that are "ancillary to the court's core role in adjudicating a case" than to
"material introduced at trial, or in connection with dispositive motions." Brown V. Maxwell, 929
F.3d 41, 49-50 (2d Cir. 2019) (applying lower presumption to documents submitted in
connection with discovery and evidentiary motions than to summary judgment filings). Thus, a
lower presumption of public access attaches the parties' pretrial bail submissions than to exhibits
introduced at trial or in connection with a motion to dismiss.
EFTA00017824

=== Page 3 ===
The Honorable Alison J. Nathan
November 25, 2020
Page 3
Here, that lower presumption is far outweighed by the significant privacy interests
implicated by the materials at issue. See United States V. Amodeo, 71 F.3d 1044, 1050 (2d Cir.
1995) ("[t]he privacy interests of innocent third parties should weigh heavily in a court's
balancing equation"). If Ms. Maxwell's sureties are publicly identified, they will be harassed
simply for their association with and support of her. Indeed, some of Ms. Maxwell's closest
friends and family have already suffered significant consequences. For example,
The sureties are legitimately scared that they and their children will suffer the same
consequences, and may not be able to come forward at all, if the Court does not allow their
letters and their identities to be sealed. See id. at 1051 ("[C]ourts have the power to insure that
their records are not used to gratify private spite or promote public scandal[.]"). These
individuals are entitled to the same privacy as Ms. Maxwell's accusers, no longer minors, who
have been permitted to remain anonymous even though many have revealed their identities.
The presumption of public access is also outweighed by Ms. Maxwell's privacy interest
in details regarding her financial condition, as well as the privacy interests of third parties that
would be implicated if Ms. Maxwell's assets were publicly disclosed. See id. (personal financial
records traditionally considered private, not public).
Similar privacy interests led the court to permit the redaction of bail submission materials
in United States V. Nejad ("Sadr"), Case 1:18-cr-00224-AJN (S.D.N.Y.). Like this case, Sadr
involved a defendant with meaningful assets and a bail package with numerous co-signers. At
the initial bail hearing, Judge Carter ordered both defense counsel and the government to redact
attachments to their submissions because they contained "sensitive private information with
respect to a whole series of individuals." (Id., Dkt. 21 at 25.) The privacy interests at stake here
are significantly higher, given the documented threats against Ms. Maxwell and harassment of
her family and friends.
For the reasons set forth above, we believe that portions of the Motion, and certain
materials submitted in support thereof and in opposition thereto, should be filed under seal. We
respectfully request an in camera conference to address these issues and other confidentiality
concerns related to the Motion. We have consulted with the government, which consents to the
redaction and sealed filing of (1) the names and identifying information of any proposed
cosigners, (2) any discovery materials designated confidential under the Protective Order in this
case, and (3) any information derived from confidential discovery materials in this case. The
government does not consent to the in camera conference.
EFTA00017825

=== Page 4 ===
The Honorable Alison J. Nathan
November 25, 2020
Page 4
Respectfully submitted
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York. New York 10022
cc: All counsel of record (via email)
The Court sees no basis for the sealing of
this letter. On or before December 2, 2020,
Defendant shall justify why this letter
should be sealed (or redacted).
Alternatively, the Defendant may file the
so ORDERED. 11/25/20
letter on the public docket by that date.
The Court will take no action on the
Alim D. Nitto
request pending resolution of the initial
sealing question. The Defendant's letter
and this memorandum endorsement will
Alison J. Nathan, U.S.D.J.
be temporarily sealed pending resolution
of the sealing request.
so ORDERED.
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From:
(USANYS)"
To:
)"
)"
Subject: Emailing:
20200701101236004_DRAFT.pdf
Date: Wed, 01 Jul 2020 14:13:53 +0000
Attachments:
20200701101236004_DRAFT.pdf
This is the draft with the FBI paragraph.
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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: WBTW/Epstein
Date: Mon, 13 Jul 2020 17:33:50 +0000
Hi
Just wanted to say that I know you've done a ton of work on both of these cases, and I know everyone on both teams
really appreciates your hard work. Thanks so much, and hope you're doing well!
Best,
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-58 United States of America V. Maxwell "Attorney TERMINATED"
Date: Tue, 27 Apr 2021 15:27:37 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 04/27/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Docket Text:
ATTORNEY, Christian R. Everdell, for Ghislaine Maxwell, TERMINATED.[3087477] [21-58, 21-770]
Notice will be electronically mailed to:
Notice will be stored in the notice cart for:
Quality Control 1
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 1 of 18
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA
:
SUPERSEDING INDICTMENT
:
- V. -
:
S1 20 Cr. 330 (AJN)
:
GHISLAINE MAXWELL,
:
:
Defendant.
:
:
X
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
OVERVIEW
1.
The charges set forth herein stem from the role
of GHISLAINE MAXWELL, the defendant, in the sexual exploitation
and abuse of multiple minor girls by Jeffrey Epstein. In
particular, from at least in or about 1994, up to and including
at least in or about 1997, MAXWELL assisted, facilitated, and
contributed to Jeffrey Epstein's abuse of minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were as young as 14 years old when they were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 18.
2. As a part and in furtherance of their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
EFTA00018407

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 2 of 18
Epstein's residences in different states, which MAXWELL knew and
intended would result in their grooming for and subjection to
sexual abuse. Moreover, in an effort to conceal her crimes,
MAXWELL repeatedly lied when questioned about her conduct,
including in relation to some of the minor victims described
herein, when providing testimony under oath in 2016.
FACTUAL BACKGROUND
3.
During the time periods charged in this
Indictment, GHISLAINE MAXWELL, the defendant, had a personal and
professional relationship with Jeffrey Epstein and was among his
closest associates. In particular, between in or about 1994 and
in or about 1997, MAXWELL was in an intimate relationship with
Epstein and also was paid by Epstein to manage his various
properties. Over the course of their relationship, MAXWELL and
Epstein were photographed together on multiple occasions,
including in the below image:
2
EFTA00018408

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 3 of 18
4.
Beginning in at least 1994, GHISLAINE MAXWELL,
the defendant, enticed and groomed multiple minor girls to
engage in sex acts with Jeffrey Epstein, through a variety of
means and methods, including but not limited to the following:
a.
MAXWELL first attempted to befriend some of
Epstein's minor victims prior to their abuse, including by
asking the victims about their lives, their schools, and their
families. MAXWELL and Epstein would spend time building
friendships with minor victims by, for example, taking minor
victims to the movies or shopping. Some of these outings would
involve MAXWELL and Epstein spending time together with a minor
victim, while some would involve MAXWELL or Epstein spending
time alone with a minor victim.
b. Having developed a rapport with a victim,
MAXWELL would try to normalize sexual abuse for a minor victim
by, among other things, discussing sexual topics, undressing in
front of the victim, being present when a minor victim was
undressed, and/or being present for sex acts involving the minor
victim and Epstein.
C.
MAXWELL'S presence during minor victims'
interactions with Epstein, including interactions where the
minor victim was undressed or that involved sex acts with
Epstein, helped put the victims at ease because an adult woman
was present. For example, in some instances, MAXWELL would
3
EFTA00018409

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 4 of 18
massage Epstein in front of a minor victim. In other instances,
MAXWELL encouraged minor victims to provide massages to Epstein,
including sexualized massages during which a minor victim would
be fully or partially nude. Many of those massages resulted in
Epstein sexually abusing the minor victims.
d. In addition, Epstein offered to help some
minor victims by paying for travel and/or educational
opportunities, and MAXWELL encouraged certain victims to accept
Epstein's assistance. As a result, victims were made to feel
indebted and believed that MAXWELL and Epstein were trying to
help them.
e.
Through this process, MAXWELL and Epstein
enticed victims to engage in sexual activity with Epstein. In
some instances, MAXWELL was present for and participated in the
sexual abuse of minor victims. Some such incidents occurred in
the context of massages, which developed into sexual encounters.
5. GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims knowing that he had a
sexual preference for underage girls and that he intended to
engage in sexual activity with those victims. Epstein's
resulting abuse of minor victims included, among other things,
touching a victim's breast, touching a victim's genitals,
placing a sex toy such as a vibrator on a victim's genitals,
4
EFTA00018410

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 5 of 18
directing a victim to touch Epstein while he masturbated, and
directing a victim to touch Epstein's genitals.
MAXWELL AND EPSTEIN'S VICTIMS
6.
Between approximately in or about 1994 and in or
about 1997, GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims by, among other
things, inducing and enticing, and aiding and abetting the
inducement and enticement of, multiple minor victims. Victims
were groomed and/or abused at multiple locations, including the
following:
a.
A a multi-story private residence on the
Upper East Side of Manhattan, New York owned by Epstein (the
"New York Residence"), which is depicted in the following
photograph:
5
EFTA00018411

=== Page 6 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 6 of 18
b.
An estate in Palm Beach, Florida owned by
Epstein (the "Palm Beach Residence"), which is depicted in the
following photograph:
C.
A ranch in Santa Fe, New Mexico owned by
Epstein (the "New Mexico Residence"), which is depicted in the
following photograph:
6
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=== Page 7 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 7 of 18
d.
MAXWELL's personal residence in London,
England.
7.
Among the victims induced or enticed by GHISLAINE
MAXWELL, the defendant, were minor victims identified herein as
Minor Victim-1, Minor Victim-2, and Minor Victim-3. In
particular, and during time periods relevant to this Indictment,
MAXWELL engaged in the following acts, among others, with
respect to minor victims:
a.
MAXWELL met Minor Victim-1 when Minor
Victim-1 was approximately 14 years old. MAXWELL subsequently
interacted with Minor Victim-1 on multiple occasions at
Epstein's residences, knowing that Minor Victim-1 was under the
age of 18 at the time. During these interactions, which took
place between approximately 1994 and 1997, MAXWELL groomed Minor
Victim-1 to engage in sexual acts with Epstein through multiple
means. First, MAXWELL and Epstein attempted to befriend Minor
Victim-1, taking her to the movies and on shopping trips.
MAXWELL also asked Minor Victim-1 about school, her classes, her
family, and other aspects of her life. MAXWELL then sought to
normalize inappropriate and abusive conduct by, among other
things, undressing in front of Minor Victim-1 and being present
when Minor Victim-1 undressed in front of Epstein. Within the
first year after MAXWELL and Epstein met Minor Victim-1, Epstein
began sexually abusing Minor Victim-1. MAXWELL was present for
7
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=== Page 8 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 8 of 18
and involved in some of this abuse. In particular, MAXWELL
involved Minor Victim-1 in group sexualized massages of Epstein.
During those group sexualized massages, MAXWELL and/or Minor
Victim-1 would engage in sex acts with Epstein. Epstein and
MAXWELL both encouraged Minor Victim-1 to travel to Epstein's
residences in both New York and Florida. As a result, Minor
Victim-1 was sexually abused by Epstein in both New York and
Florida. Minor Victim-1 was enticed to travel across state
lines for the purpose of sexual encounters with Epstein, and
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-1 after Minor-Victim-1 traveled to Epstein's
properties, including in the context of a sexualized massage.
b. MAXWELL interacted with Minor Victim-2 on at
least one occasion in or about 1996 at Epstein's residence in
New Mexico when Minor Victim-2 was under the age of 18. Minor
Victim-2 had flown into New Mexico from out of state at
Epstein's invitation for the purpose of being groomed for and/or
subjected to acts of sexual abuse. MAXWELL knew that Minor
Victim-2 was under the age of 18 at the time. While in New
Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and
MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed
Minor Victim-2's school, classes, and family with Minor Victim-
2. In New Mexico, MAXWELL began her efforts to groom Minor
Victim-2 for abuse by Epstein by, among other things, providing
8
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=== Page 9 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 9 of 18
an unsolicited massage to Minor Victim-2, during which Minor
Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to
massage Epstein.
C. MAXWELL groomed and befriended Minor
Victim-3 in London, England between approximately 1994 and 1995,
including during a period of time in which MAXWELL knew that
Minor Victim-3 was under the age of 18. Among other things,
MAXWELL discussed Minor Victim-3's life and family with Minor
Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and
arranged for multiple interactions between Minor Victim-3 and
Epstein. During those interactions, MAXWELL encouraged Minor
Victim-3 to massage Epstein, knowing that Epstein would engage
in sex acts with Minor Victim-3 during those massages. Minor
Victim-3 provided Epstein with the requested massages, and
during those massages, Epstein sexually abused Minor Victim-3.
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-3 on multiple occasions, including at times when
Minor Victim-3 was under the age of 18, including in the context
of a sexualized massage.
MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT
8. In or around 2016, in the context of a deposition
as part of civil litigation, GHISLAINE MAXWELL, the defendant,
repeatedly provided false and perjurious statements, under oath,
regarding, among other subjects, her role in facilitating the
9
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=== Page 10 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 10 of 18
abuse of minor victims by Jeffrey Epstein, including some of the
specific events and acts of abuse detailed above.
STATUTORY ALLEGATIONS
9.
From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, enticement, in violation of Title 18, United States Code,
Section 2422.
10. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did knowingly persuade, induce,
entice, and coerce one and more individuals to travel in
interstate and foreign commerce, to engage in sexual activity
for which a person can be charged with a criminal offense, in
violation of Title 18, United States Code, Section 2422.
Overt Acts
11. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
10
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=== Page 11 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 11 of 18
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with Epstein
and Minor Victim-1 in New York and Florida.
b. In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
New York Residence, in violation of New York Penal Law, Section
130.55.
C. In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d. Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Enticement of a Minor to Travel to Engage in Illegal Sex Acts)
The Grand Jury further charges:
12. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
11
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=== Page 12 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 12 of 18
13. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
persuade, induce, entice, and coerce an individual to travel in
interstate and foreign commerce to engage in sexual activity for
which a person can be charged with a criminal offense, and
attempted to do the same, and aided and abetted the same, to
wit, MAXWELL persuaded, induced, enticed, and coerced Minor
Victim-1 to travel from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2422 and 2.)
COUNT THREE
(Conspiracy to Transport Minors with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
14. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
15. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
12
EFTA00018418

=== Page 13 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 13 of 18
wit, transportation of minors, in violation of Title 18, United
States Code, Section 2423 (a).
16. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did, knowingly transport an
individual who had not attained the age of 18 in interstate and
foreign commerce, with intent that the individual engage in
sexual activity for which a person can be charged with a
criminal offense, in violation of Title 18, United States Code,
Section 2423 (a).
Overt Acts
17. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with EPSTEIN
and Minor Victim-1 in New York and Florida.
b. In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
13
EFTA00018419

=== Page 14 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 14 of 18
New York Residence, in violation of New York Penal Law, Section
130.55.
C.
In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d. Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT FOUR
(Transportation of a Minor with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
18. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
19. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
transport an individual who had not attained the age of 18 in
interstate and foreign commerce, with the intent that the
individual engage in sexual activity for which a person can be
charged with a criminal offense, and attempted to do so, and
14
EFTA00018420

=== Page 15 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 15 of 18
aided and abetted the same, to wit, MAXWELL arranged for Minor
Victim-1 to be transported from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2423 (a) and 2.)
COUNT FIVE
(Perjury)
The Grand Jury further charges:
20. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
21. On or about April 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7433, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q.
Did Jeffrey Epstein have a scheme to recruit
underage girls for sexual massages? If you know.
A.
I don't know what you're talking about.
15
EFTA00018421

=== Page 16 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 16 of 18
Q.
List all the people under the age of 18 that you
interacted with at any of Jeffrey's properties?
A.
I'm not aware of anybody that I interacted with,
other than obviously [the plaintiff] who was 17
at this point.
(Title 18, United States Code, Section 1623.)
COUNT SIX
(Perjury)
The Grand Jury further charges:
22. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
23. On or about July 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7433, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q:
Were you aware of the presence of sex toys or
devices used in sexual activities in Mr.
Epstein's Palm Beach house?
A:
No, not that I recall.
Q.
Do you know whether Mr. Epstein possessed sex
toys or devices used in sexual activities?
A.
No.
16
EFTA00018422

=== Page 17 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 17 of 18
Q.
Other than yourself and the blond and brunette
that you have identified as having been involved
in three-way sexual activities, with whom did Mr.
Epstein have sexual activities?
A.
I wasn't aware that he was having sexual
activities with anyone when I was with him other
than myself.
Q.
I want to be sure that I'm clear. Is it your
testimony that in the 1990s and 2000s, you were
not aware that Mr. Epstein was having sexual
activities with anyone other than yourself and
the blond and brunette on those few occasions
when they were involved with you?
A.
That is my testimony, that is correct.
Q.
Is it your testimony that you' ve never given
anybody a massage?
A.
I have not given anyone a massage.
Q.
You never gave Mr. Epstein a massage, is that
your testimony?
A.
That is my testimony.
Q.
You never gave [Minor Victim-2] a massage is your
testimony?
A.
I never gave [Minor Victim-2] a massage.
(Title 18, United States Code, Section 1623.)
FOREPERSON
Jan
Acting Attorney
AUDREY Audrey United STRAUSS Strais States
17
EFTA00018423

=== Page 18 ===
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 18 of 18
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
GHISLAINE MAXWELL,
Defendant.
SUPERSEDING INDICTMENT
S1 20 Cr. 330 (AJN)
(18 U.S.C. $$ 371, 1623, 2422, 2423 (a),
and 2)
AUDREY STRAUSS
Acting United States Attorney
The
Foreperson
18
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=== Page 1 ===
From:
)"
To:
)"
,
Subject: Fwd: Transcript Request-19CR00490
Date: Tue, 27 Aug 2019 20:33:01 +0000
Attachments: J8RpEPSf.pdf; ATT00001.htm
Begin forwarded message:
From:
Date: August 27, 2019 at 2:30:31 PM EDT
To:
"
)"
Subject: Transcript Request-19CR00490
Hello:
Attached you will find a copy of Case No. 19-CR-490 as requested. Please confirm delivery.
Thank You,
EFTA00019992


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Book1.xlsx US V. Epstein
Date: Thu, 31 Oct 2019 15:03:45 +0000
Actually, that's probably because some people are in here more than once, right?
From:
(USANYS)
Sent: Thursday, October 31, 2019 11:02 AM
To:
(USANYS)
Subject: RE: Book1.xlsx US V. Epstein
Thanks very much. Looks like there are "43" under notify, but you said 39 were notified of the hearing - do you know
which of the 4 were not notified?
From:
(USANYS)
Sent: Thursday, October 31, 2019 10:59 AM
To:
(USANYS)
Subject: Book1.xlsx US V. Epstein
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=== Page 1 ===
From:
To:
Subject: Accepted: Meet re: Epstein Investigation
Date: Wed, 05 Dec 2018 00:37:27 +0000
Importance: Normal
Attachments: unnamed
EFTA00019531


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=== Page 1 ===
From:
To:
Subject: Cover letter
Date: Thu, 04 Nov 2021 03:33:26 +0000
Attachments: 2021-11-03_RTC_and_Verdict_sheet_cover_letter.docx
Would you mind taking a quick look at this too?
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00018371


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=== Page 1 ===
From:
To:
Reynolds
Subject:
- meeting tomorrow
Date: Tue, 13 Jul 2021 19:46:59 +0000
Attachments: 2021.07.13_Court_Subpoena_
pdf
Looking forward to meeting with you and
at your office tomorrow at 9:30am. As we've previously discussed,
I'm attaching a trial subpoena requiring
to testify at our trial, which is scheduled to begin on November 29,
2021. I expect we will call
to testify sometime in early December 2021 during that trial.
After our prep tomorrow, I do not think we will need to meet with
again until we get closer to trial. I'll plan to
reach back out in early November to arrange for a VTC on which we can conduct a refresher prep session and to arrange
for
travel and hotel for trial.
Thanks and see you tomorrow.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: Application for Amended SW
Date: Thu, 22 Oct 2020 17:22:55 +0000
Embedded: RE:_Application_for_Amended_SW.msg
Sender
Subject: RE: Application for Amended SW
Message-Id:
<BN3P110MB0292973BBB07D36155B72943841D0@BN3P110MB0292.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
To:
Cc:
EFTA00017799


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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From:
Date: July 19, 2021
Re:
United States V. Ghislaine Maxwell
Court Docket No:
20 Cr. 330 (AJN)
USAO No:
2018R01618
Witness Name:
Witness DOB:
(Name/DOB as printed here will be forwarded to travel agency and then to TSA and must
exactly match the witness's driver's license or other travel ID or TSA will not permit the
witness to fly.)
Witness Address:
Witness TelNos (mobile):
Witness e-mail:
Witness Needed to Appear in SDNY on
Date:
Time: 1 p.m.
Witness Needed to Appear for:
Trial ( )
Date:
Grand Jury ( )
Date:
Trial/GJ Prep (X)
Date:
at 1 p.m.
Estimated Dates Witness will Arrive:
Depart:
Is the person a Fact Witness and not an Expert Witness?
(Yes/No): Yes
Current Federal Civilian or Military Employee?
(Yes/No): No
Is the Witness Facing Criminal Charges?
(Yes/No): No
Does the Witness Reside Outside the Continental United States?
(Yes/No): No
Is this Witness a Victim-Witness?
(Yes/No): No
Hotel Required?
(Yes/No): Yes
Has the Witness advised you of any unusual travel expenses?
(Yes/No): No
Unusual expenses of fact witnesses can include
special travel arrangements
care for dependent child or incapacitated family member left at home
rev. 2019.11.19
EFTA00019654

=== Page 2 ===
kennel fees for pets
necessary travel companion
extra baggage (more than one bag)
Please describe the unusual expense:
For Victim-Witness Coordinator:
1. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW
is apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should
be used.
For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to
court/GJ testimony.
Witnesses may only be brought in under the FEWS appropriation for grand jury testimony that
has been scheduled and where the witness is expected to testify before the grand jury; court
testimony; or preparation for same. Any other witness travel, e.g., for investigative interviews,
must be covered by the investigating component from litigative funds. See Ed Tyrrell.
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
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=== Page 1 ===
From:
To:
Subject: RE:
Brass Meeting
Date: Mon, 20 Jul 2020 23:57:07 +0000
Attachments: 2020-04-15, prosecution_memo,
_with_attachments.pdf
Thanks, l'Il email her right now, just because we need to set up another meeting, too.
And yes, there is plenty to read on
Attached is the team's latest memo along with the latest
submission.
From:
Sent: Monday, July 20, 2020 7:24 PM
To:
Subject: RE:
Meeting
Yes, all of them work for me. Happy to email
back assuming they work for you.
Is there a
pros memo or memo that I could use to get up to speed?
From:
Sent: Monday, July 20, 2020 7:13 PM
To:
Subject: RE:
Brass Meeting
Any of these not work for you?
From:
Sent: Monday, July 20, 2020 5:03 PM
To:
Cc:
Subject:
Brass Meeting
Hey guys,
Could you please let us know which of the following windows next week works for a brass meeting? Monday 11-2:30,
Tuesday 1-2:30, Thursday 11-2. Thanks very much.
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
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=== Page 1 ===
From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:10:43 +0000
Inline-Images: image001.png
Thanks man! Really appreciate it
From
Sent: Thursday, July 02, 2020 13:52
To
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Well done sir
From
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO UNITED VILLING
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
EFTA00019543

=== Page 2 ===
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00019544

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
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=== Page 1 ===
From:
To:
Cc:
Subject: Re: bail application
Date: Thu, 03 Dec 2020 01:41:20 +0000
Thank you for letting me know.
will want to strenuously oppose bail.
Sent by Boxer
On December 2, 2020 at 8:37:24 PM EST,
wrote:
We wanted to let you know that Ghislaine Maxwell's attorneys intend to file a new bail application. The
application has not yet been filed, and we don't have a specific briefing schedule or hearing date. We will
make sure to keep you updated, but we wanted to touch base in advance to make sure you were aware. As
always, please feel free to give us a call if you have any questions or if you'd like to discuss this.
Thank you,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
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From:
To: "Weinstein, Marc A."
,
"Tomback, Andrew"
Cc:
Subject: RE: Epstein estate subpoenas
Date: Fri, 01 Nov 2019 21:20:00 +0000
Marc, Andrew,
As promised we wanted to send the full contact information for our team, with apologies for the delay-we're all
reachable anytime at these email addresses, or by phone at:
We look forward to seeing you at our office this Wednesday at 9:30, and please don't hesitate to reach out in the interim
(including over the weekend) if that would be helpful.
thank you,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
Case 1:15-cv-07433-LAP Document 1100 Filed 08/10/20 Page 1 of 3
Haddon, Morgan and Foreman, P.C
Laura A. Menninger
HADDON
Denver, Colorado 80203
MORGAN
FOREMAN
www.hmflaw.com
August 10, 2020
Honorable Loretta A. Preska
United States District Court
Southern District of New York
New York, NY 10007
Re: August 3, 2020 Order (Doc. 1096)
V. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP)
Dear Judge Preska:
I write in response to the Court's Order of August 3, 2020 (Doc. 1069), the Order and
Protocol for Unsealing Decided Motions (Doc. 1044) ("Protocol"), and to raise with the Court
the legal effect of new information that came to the attention of counsel for Ms. Maxwell on
Friday, August 7, 2020.
New information: On Friday, August 7, 2020, counsel for Ms. Maxwell learned of
critical new information that impacts both this action and U.S. V. Maxwell, 20 Cr. 330 (AJN)
(the "Criminal Action"). The information implicates Ms. Maxwell's right to due process and
fairness in this civil action and affects the Second Circuit's review of the Court's unsealing
order of July 23, 2020. Additionally, the information implicates her rights as a criminal
defendant guaranteed under the Fourth, Fifth and Sixth Amendments.
Counsel makes the representations about implications of the new information as an
officer of this Court. At this time, counsel is not at liberty to disclose the information because
it is subject to a protective order in the Criminal Action, which forbids its use "for any civil
proceeding or any purpose other than the defense" of the criminal action absent "further order
of the Court." Protective Order, 20 Cr. 330 (AJN) at I 1(a), 18 (Exhibit A). As required by
that Protective Order and Judge Nathan's Individual Practices in Criminal Cases, counsel
initiated a conferral with the U.S. Attorney's Office over the weekend concerning a
modification of the Protective Order to share the information with this Court and the Second
Circuit. Barring agreement, Ms. Maxwell intends to seek modification of the Protective Order
in the Criminal Action from Judge Nathan forthwith to permit sharing the information with
this Court, ex parte and in camera if necessary, and with the Second Circuit (likewise under
seal if necessary).
EFTA00018580

=== Page 2 ===
Case 1:15-cv-07433-LAP Document 1100 Filed 08/10/20 Page 2 of 3
Honorable Loretta A. Preska
August 10, 2020
Page 2
Ms. Maxwell requests a temporary stay of the unsealing process for approximately
three weeks until the conclusion of (a) the conferral with the U.S. Attorney's Office to a
modification of the Protective Order in the Criminal Action and, if necessary, an application
and ruling by Judge Nathan on the issue, to permit the use of the information in this Court and
before the Second Circuit (under seal in both courts, if necessary), (b) an application to this
Court containing the new information in support of a request to stay the unsealing process
until the conclusion of the Criminal Action, and (c) a ruling by this Court on the motion for
stay.
Streamlining of Unsealing Process: As directed by the Court, counsel for Ms. Maxwell
conferred with plaintiff's counsel concerning various proposals to streamline the unsealing
process. Subject to Ms. Maxwell's request to temporarily pause the process as described
above, defense counsel has agreed to several potential modifications of the Protocol which we
hope will ease the burden on the parties and the Court going forward, should the unsealing
move ahead. Of note, and as Plaintiff will explain to the Court, the parties have agreed to
notify all of the Non-Parties at once so that we can understand which Non-Parties object to the
unsealing before deciding how to proceed with future redactions. Although this will give the
Court and the Original Parties more information about the scope of objectors, there are
limitations to the extent to which it will expedite the process. As counsel has made clear in
the past, it will take significant effort by the Original Parties and their staff to put together the
excerpts for any Non-Party who requests them because each Non-Party will be entitled to see
his or her own information (but not that of other Non-Parties). After receiving a request from
a Non-Party, we anticipate it will take up to a week per Non-Party to agree to the excerpts to
send to them for review. But on balance we agree that having a sense of the number of
participating Non-Parties will aid the Court in conducting future proceedings, we have agreed
to Plaintiff's suggestion on that front. The parties can submit a proposed modification of the
Protocol and Notice to the Court to reflect this agreement.
We also have agreed, as the Court suggested, to shorten the time period for the
Original Parties to object and to respond from 14 to 7 days. This would impact paragraphs
2(d), 2(e) and 2(f) of the Protocol. The parties can also submit a proposed modification of the
Protocol to the Court. The parties also agreed to leave the time for Non-Parties to object at 14
days given some practical considerations applicable to them.
Although the parties were able to reach some agreement, we cannot agree to all of
Plaintiff's proposals and write separately to explain the basis for our disagreements.
First, we carefully considered the Court's suggestion to reduce the number of pages of
briefing to ten pages per side. Id. Our initial Objection (DE 1057) was 14 pages long;
Plaintiff's Response was 19 pages. The Court concluded that our Objection was, in many
respects, not specific enough. We would ask leave to at least have 15 pages to object to the
five motions proposed below, with any response limited to the same. We will endeavor to
keep it shorter than that, but also allow for more space to provide specifics to the Court.
Second, we have obtained new contact information for Doe 1 from a separate civil
suit. We believe that Doe 1 retains a right to notification and participation. We suggest
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=== Page 3 ===
Case 1:15-cv-07433-LAP Document 1100 Filed 08/10/20 Page 3 of 3
Honorable Loretta A. Preska
August 10, 2020
Page 3
providing the Notice to Doe 1 at the new address for any future pleadings that implicate his or
her deposition, which is currently subject to the Second Circuit's stay.
Third, to prevent against some of the errors that occurred during the last round of
unsealings, we request that the Protocol be amended to require the Responding Original Party
who proposes unsealing to supply with their Response a proposed unredacted set of the
pleadings at issue, for the Court's consideration and for the Objecting Original Party or Non-
Party to have the right of reply. Preparing those redactions after the fact allows much
ambiguity into the Court's ruling and we believe the Court's ruling should specify which
redactions it is accepting or rejecting at the time of ruling.
Finally, we request that the Court allow for the any objecting Non-Party or Original
Party be given 7 days following any unseal order to apply for relief in the Second Circuit from
the order prior to the documents being released.
Proposed Next Set of Docket Entries for Review:
Given the Second Circuit's stay concerning Ms. Maxwell and Doe 1's deposition
transcripts and materials that quote from them, we propose that the Court deviate from the
Doe 1 and 2 chronology (given that Doe 1's deposition is sprinkled throughout those motions)
and instead take the following five decided motions and their related pleadings. This list
represents the first five chronological decided motions that (a) have sealed or redacted
materials and (b) do not have attached or quote from documents subject to the stay. They are:
75 - Defendant's Motion to Compel Responses to Defendant's First Set of
Discovery Responses to Plaintiff
139 - Plaintiff's Brief in Support of the Privilege Claimed for In Camera
Submission
155 - Defendant's Motion to Compel Non-Privileged Documents
215 - Sharon Churcher Motion to Quash Subpoena
231 - Defendant's Motion to Reopen Deposition of Plaintiff
Counsel for Ms. Maxwell is available for a telephone conference to discuss any of the
foregoing, should the Court desire.
Respectfully submitted,
Jam
Laura A. Menninger
CC: Counsel of Record via ECF
EFTA00018582


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=== Page 1 ===
From:
To:
Subject: To read on train
Date: Fri, 17 Sep 2021 15:18:53 +0000
Attachments: 2019-09-28,
interview_302.pdf; 2019-09-
28
interview_notes.pdf;
2020.07.14_Maxwell_arraignment_initial_conference_bail_hearing
ndf; 2020-05-
09,
interview_notes_(no_302).pdf;,2006-11-28,
302.pdf;
2019-08-27,
conference.pdf
Assistant United States Attorney
Southern District of New York
New York, New York 10007
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=== Page 1 ===
From: Robert Glassman
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
Date: Mon, 08 Jun 2020 19:08:25 +0000
Importance: High
Attachments: 6_8_20_Ltr_re_Jane_Doe_Touhy_request.pdf
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
11111 Santa Monica Boulevard, Suite 700
Los Angeles, CA 90025
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.
EFTA00019467


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=== Page 1 ===
2020 Fee Schedule*
BREAK THE CHAIN
Dr. Kimberly Mehlman-Orozco, Ph.D.
Criminal Case Remote Research, Review, and Consultation
$350 per hour
Criminal Case In-person Deposition and/or Trial
$500 per hour
Travel/Expenses
Non-working travel time is billed at half of the hourly deposition/trial rate, from portal to portal. There is a one-hour
minimum travel charge. The client is responsible for all reasonable and customary travel expenses, which include
but are not limited to: flight/train, hotel, and taxi/rental car. Automobile mileage is billed at the GSA rate².
Cancellation Fees
A flat rate of $1,500 is incurred when scheduled meetings, depositions, and/or trial dates are cancelled within
seven calendar days prior to the event.
Billing
Retainer will be applied to final invoice. Payment is due within 30 days of invoice receipt.
Payable to Break the Chain LLC, Federal Tax I.D.
1 Reasonableness of expenses will be determined by conformity with GSA schedule.
2 As of January 1, 2020: 57.5 cents per mile.
*All rates subject to review on an annual basis.
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=== Page 1 ===
From:
To:
Subject: RE: inmate interviews
Date: Wed, 04 Dec 2019 17:40:31 +0000
Embedded: Hammad_Memo
msg; Hammad_Memo_
Hammad_Memo - Epstein_Death_Investigation.msg
In most cases, we had the agents interview the inmates without counsel after doing a Hammad memo. I've attached a
few examples. Where the inmate is a cooperator, we worked through the attorney. There were also two instances where
an inmate was not a cooperator but we worked through the attorney because of the nature of the defendant (both were
EDNY death eligible inmates).
From:
Sent: Wednesday, December 4, 2019 12:24 PM
To:
Subject: inmate interviews
I'm working on a Rikers investigation, and
suggested I check with you to ask: for the MCC case, were you ever
present for an uncounseled inmate interview, or did you guys just have agents do those interviews? He wasn't sure what
the practice was. Thanks.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00018130


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=== Page 1 ===
THE SCHOOL DISTRICT OF
DAWN PUMPHREY
DEEPAK AGARWAL
THE SCHOOL DISTRICT
PALM BEACH COUNTY, FLORIDA
DIRECTOR
CHIEF INFORMATION Officer
IT ENTERPRISE APPLICATIONS
3300 FOREST HILL BOULEVARD, SUITE B-241
WEST PALM BEACH, FL 33406
PALM BEACH FOR COUNTY
PHONE: 561-434-8029
FAX: 561-434-8660
www.palmbeachschools.org
July, 2021
RE: RELEASE OF STUDENT RECORDS
Dear Sir or Madam,
As per your subpoena / records request, we are enclosing the student's
records.
If we can be of further assistance, please contac
at
or
Sincerely
02/19/2021
Attachment
The School District of Palm Beach County, Florida
A Top-Rated District by the Florida Department of Education Since 2005
An Equal Education Opportunity Provider and Employer
EFTA00018697


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From:
To:
Subject: 2019-08-27, nolle conference.pdf
Date: Tue, 03 Sep 2019 16:05:40 +0000
Importance: Normal
Attachments: 2019-08-27,_nolle_conference.pdf
Catching up on work, going through emails and digging out of from a pile of snail mail. But reading this transcript, the
victim statements, has been a great welcome back to the office. So I thought I would share.
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=== Page 1 ===
From:
To:
Bcc:
Subject:
Date: Fri, 30 Aug 2019 14:41:42 +0000
Talking to
lawyer on Thursday
Talking to
on Thursday (second proffer)
Friday at 230 talking to
lawyer
attorney next week
Sent from my iPhone
EFTA00018551


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=== Page 1 ===
From: "Berman, Geoffrey (USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: Fwd: Epstein Ranch
Date: Thu, 21 Nov 2019 21:00:10 +0000
We should subpoena the estate and executors for all videos and pictures from surveillance cameras from his
estates.
Begin forwarded message:
From:
"
(USANYS)"
Date: November 21, 2019 at 10:15:05 AM EST
To:
(USANYS)"
(USANYS)"
"Berman, Geoffrey (USANYS)"
Cc:
(USANYS)
Subject: Epstein Ranch
Sending a link so you can see the photos. https://www.dailymail.co.uk/news/article-7703257/New-photos-Jefrey-
Epsteins-New-Mexico-ranch-pedophiles-eight-person-party-shower.html
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I
Press Office: (212) 637-1020
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 250 Filed 04/26/21 Page 1 of 3
USDC SDNY
DOCUMENT
UNITED STATES DISTRICT COURT
ELECTRONICALLY FILED
SOUTHERN DISTRICT OF NEW YORK
DOC #:
DATE FILED: 4/26/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
The Court is in receipt of the parties' proposed schedules for pretrial disclosures and
pretrial motions practice. Dkt. Nos. 229, 230. Having considered the parties' respective
positions, the Court hereby sets the schedule below, which it deems reasonable and fair. For
purposes of this scheduling order, the trial commencement date shall mean the date that the
Court will request from the Clerk's Office as the trial commencement date. It does not include
any period involving the issuance of a jury questionnaire that may predate that trial
commencement date. As explained at the April 23, 2021 conference, the Court is considering the
Defendant's request for a continuance, but until such a request is resolved the parties shall
presume that the Court will request July 12, 2021 as the trial commencement date. See also Dkt.
No. 221. With that in mind, the Court hereby sets the following schedule:
Government expert witness disclosure are due April 23, 2021 (agreement of the
parties)
Supplemental Pretrial Motions that pertain only to the new charges raised in the S2
indictment (agreement of the parties):
Defense supplemental motions are due May 7, 2021
Government's response is due May 21, 2021
EFTA00020295

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 250 Filed 04/26/21 Page 2 of 3
Defense replies are due May 28, 2021
Disclosure of the alleged victims referenced in the S2 Indictment: May 17, 2021
(agreement of the parties)
Jencks Act/3500 materials, Rule 404(b) notice, Giglio materials, the Government's
witness list, and co-conspirator statements are due seven weeks before the trial
commencement date
The Government's exhibit lists and marked exhibits are due five weeks before the
trial commencement date
Defense Expert Witness disclosure is due four weeks before the trial
commencement date
The Defendant's Rule 16(b)(1)(A) and 16(b)(1)(B) disclosures and witness list are
due three weeks before the trial commencement date
Motions in limine are due four weeks before the trial commencement date
(agreement of the parties)
Responses to motions in limine are due two weeks before the trial
commencement date (agreement of the parties)
Requests to Charge, Verdict Sheet, and Proposed Voir Dire are due three weeks
before the trial commencement date (agreement of the parties)
The Court will address a process and schedule for the parties' proposals regarding a jury
questionnaire by separate order.
Finally, the parties are ORDERED to meet and confer on the Government's proposal that
the Defendant submit witness statements pursuant to Federal Rule of Criminal Procedure 26.2 at
EFTA00020296

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 250 Filed 04/26/21 Page 3 of 3
least four weeks in advance of trial. The parties are further ORDERED to submit a joint letter
laying out their respective positions and proposals within one week of this Order.
so ORDERED.
Dated: April 26, 2021
New York, New York
Alim D. Netto
ALISON J. NATHAN
United States District Judge
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=== Page 1 ===
From:
To:
Subject: FW: WASHINGTON POST; Jeffrey Epstein's scandal of secrecy points to a creeping rot in the
American justice system
Date: Tue, 18 Jun 2019 20:34:15 +0000
Importance: Normal
Just FYI.
From:
Sent: Tuesday, June 18, 2019 4:34 PM
To:
Subject: WASHINGTON POST; Jeffrey Epstein's scandal of secrecy points to a creeping rot in the American justice system
Jeffrey Epstein's scandal of
secrecy points to a creeping rot
in the American justice system
When rich people are credibly accused of crimes, does the public have a right to
know? Should multimillionaires be allowed to silence their accusers with cash?
According to superlawyer David Boies, "dozens" of women who could give
testimony about being sexually assaulted as girls by mysterious financier Jeffrey
Epstein are silenced by settlements they reached with their alleged assailant. The
exact number is yet another secret in this least transparent of criminal cases.
"Three dozen or eight dozen, I don't know, but there are dozens," Boies told me
recently. He himself represents two alleged Epstein victims bound by "non-
disclosure agreements" (NDAs).
Because Epstein can afford to buy silence, he may succeed in shuttering the
window of accountability pried open in a South Florida court back in February.
U.S. District Judge Kenneth A. Marra ruled that federal prosecutors - led by the
EFTA00019249

=== Page 2 ===
current labor secretary, Alexander Acosta - broke the law by entering a secret
sweetheart deal to allow Epstein to serve a cushy sentence without facing evidence
that he assaulted more than 30 underage girls in Palm Beach.
That ruling may prove hollow, however, if the alleged victims are now gagged by
their settlements with Epstein. What a galling next chapter that would be in this
appalling story.
Epstein, whose enormous and unexplained wealth attracted a circle of friends that
included Bill Clinton, Donald Trump, actor Kevin Spacey and Britain's Prince
Andrew, travels from mansion to mansion while poor men accused of lesser
crimes rot in prison.
This scandal of secrecy points to a creeping rot in the American justice system.
Too many cases involving potential felonies are resolved through civil settlements
that include ironclad NDAs. Once the money changes hands, witnesses can no
longer testify to crimes; indeed, penalties for telling the truth after a settlement
often run to the millions of dollars - ruinous for most crime victims. It's a short
step removed from silencing witnesses with cement shoes.
"It is a classic case of rich man's justice," said Boies. Add the fact that wealthy
predators often target victims in financial need. That was allegedly Epstein's M.O.
as he sent recruiters into working-class neighborhoods in search of teenagers to
give him "massages." The rich exploit the poverty of their victims to extract
promises of silence - backed by the force of law because the NDAs are binding
contracts.
What's needed is a simple change to the law, Boies contends: "Simply say that
agreements to conceal evidence of a crime are not enforceable."
The Epstein case is particularly creepy but not unique. The #MeToo movement
has revealed the pernicious misuse of NDAs to enable crime. Powerful men such
as producer Harvey Weinstein and television executive Leslie Moonves reportedly
made use of the agreements to hide evidence of sexual assault or harassment. This
secrecy in turn allowed offenders to target additional victims.
That's where the public interest comes in. Crime is not just a matter between an
offender and a victim; crime is also an offense against the public order. The public
EFTA00019250

=== Page 3 ===
has an important stake in punishing past crimes and preventing future offenses.
Purchased secrecy interferes with those aims.
Some attorneys say NDAs are the only protection the rich and famous have
against unfounded accusations. But that doesn't bear much scrutiny. A person
who might falsely claim to be a victim has more to fear from sunlight than from
secrecy. And anyone who pays hush money to cover up false allegations is only
encouraging more extortion.
I am beginning to worry that the fresh breeze of openness that appeared to be
blowing through the stink of the Epstein case might be smothered by secrecy.
Attorneys for Epstein's Palm Beach accusers are losing confidence that their
clients will ever tell their stories in court.
Meanwhile, a panel of appeals court judges in New York has gone silent in a
related matter. British socialite Ghislaine Maxwell, an Epstein friend and
confidante, is battling to keep details of her settlement with an Epstein accuser
sealed from public view. In a March hearing at the U.S. Court of Appeals for the
2nd Circuit, Judge José A. Cabranes openly scoffed at Maxwell's attorney as he
argued for secrecy. Yet here we are on the cusp of summer, and the court has not
been heard from. When will a ray of sunshine pierce the cloud of money?
If anything good can come out of this miserable case, maybe this is it: Lawmakers
can seize this outrageous moment to outlaw the silencing of witnesses through
NDAs. The agreements have their place in civil matters, but not to mask evidence
of crimes. The legal system, meanwhile, can do the right thing. Open the Maxwell
files. Then launch a full-fledged investigation of Epstein's conduct in New York,
New Mexico and the Virgin Islands: places where the tainted South Florida
agreement cannot protect him.
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 260 Filed 04/30/21 Page 1 of 2
COHEN & GRESSER LLP
www.cohengresser.com
Christian R. Everdell
April 30, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write to respectfully request the Court to issue an order to the MDC directing it to
accept two hard drives from defense counsel that contain the non-Highly Confidential discovery in
this case for Ms. Maxwell's use at the MDC.
In an effort to facilitate Ms. Maxwell's review of the discovery, defense counsel have
created a master set of two hard drives that contain a complete set of the discovery produced by
the government so far, excluding the materials marked Highly Confidential, which Ms. Maxwell is
not permitted to possess in the MDC pursuant to the terms of the Protective Order. The master
drives are easier to use than her existing hard drives because they collect all of the material in one
place and organize the documents in a more user-friendly format. For example, the November 18,
2020 production containing roughly 2.2 million pages was produced in load file format, which
contains images of individual pages of documents in native file format, image file format, and
other formats. The hard drives organize these files by document, as opposed to by page, and
eliminate duplicative file formats so that Ms. Maxwell will not have to add countless hours to her
review.
Defense counsel would like to send these hard drives to Ms. Maxwell for her to use in the
MDC. We were informed by the MDC Legal Department that they are only permitted to accept
hard drives that are loaded and certified by the U.S. Attorney's Office. We have conferred with
the government, which has advised that it does not object to the defense making an application to
the Court to issue an order directing the MDC to accept the hard drives. The government
requested, however, that the Court allow MDC legal counsel the opportunity to note their
objections to the Court.
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=== Page 2 ===
Case 1:20-cr-00330-AJN Document 260 Filed 04/30/21 Page 2 of 2
The Honorable Alison J. Nathan
April 30, 2021
Page 2
Accordingly, we respectfully request that the Court issue an order directing the MDC to
accept the master hard drives either from defense counsel or from the government. We will send a
copy of this letter to the MDC Legal Department so that they can note any objections they may
have.
Thank you for your attention to this matter.
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
New York, New York 10022
cc:
All Counsel of Record (By ECF)
MDC Legal Department
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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
)"
,
)"
Subject: Epstein Pros Memo
Date: Wed, 14 Aug 2019 17:14:45 +0000
Can you send it to me?
Assistant United States Attorney
Southern District of New York
Tel:
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From:
(USANYS)"
To:
)"
Subject: RE: Citecheck
Date: Wed, 27 Oct 2021 21:38:11 +0000
Attachments: Govt_Reply_v2_MH.docx
Hi
Unfortunately, I have class starting here in a few minutes, and grabbing those files from the docket took longer than I
would have liked.
Attached is where I was able to get to so far (I got through the bottom of page 5). I hope at least this was helpful. I have
class until 9:10 tonight, so probably cannot circle back on this until tomorrow morning. Let me know if that would be
helpful or if you need to get this done sooner.
Sorry again for not being able to get through more of this.
Best,
From:
)
Sent: Wednesday, October 27, 2021 3:51 PM
To:
(USANYS)
Subject: Citecheck
Hey
Thanks for hopping on this! Here's a portion of a brief we need citechecked. If there are cites you can't check because
you don't have the documents, just highlight them and I'll check them.
Thanks, and let me know if you have any questions!
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00017887


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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein
Date: Tue, 04 Feb 2020 04:05:10 +0000
Importance: Normal
Attachments: unnamed
EFTA00018220


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=== Page 1 ===
From: kathryn milofsky
To:
Subject: BRITISH TV REQUEST Important
Date: Mon, 08 Jun 2020 19:32:20 +0000
Dear Mr Berman
I am Kathryn Milofsky a producer for ITV News based in NY.We are the largest commercial channel in the
UK similar in style stature to NBC.
We would be honored to do an interview with you today via Skype for about 10 minutes about your
request to interview Prince Andrew re the investigation into Jeffrey Epstein. The recent MLA request.
The interview would air on our flagship News at Ten Broadcast which is watched by millions.
ITV News is made by ITN, which has a global reputation as a provider of independent, objective broadcast
news. We are known for delivering powerful, authoritative coverage which is free from any political ownership.
ITV News has the biggest reach of any commercial news provider in the UK and broadcasts to 8 million
viewers each day. We are the main commercial competition to the BBC. Our recent interview with Meghan
Markle had 44million views and millions watched the interview on tv.
We are proud to be the network that best reaches the non-metropolitan elite in the UK. Online, the ITV
News Facebook and Twitter pages are now at 1.8m followers each and growing, with Facebook views pulling
in an average of 55m average per month, with 5m monthly video views on Twitter. The ITV News website
has an average of 30m page views each month.
I so hope you can do an interview with us.
Kind Regards
Kathryn Milofsky
Producer ITV News
EFTA00018556


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=== Page 1 ===
Subject: update
Date: Mon, 09 Dec 2019 23:49:07 +0000
Hi
We wanted to share the good news that we spoke with
lawyer late this afternoon, and he told us that his
client is on board with cooperating with our office's investigation and possible prosecution of Ghislaine Maxwell. Our next
step will be to meet with
for an interview to cover several topics that were previously off-limits during our
meetings with her. We hope to have that meeting
or the week thereafter, depending on her
schedule.
Best,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00018924


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=== Page 1 ===
From: Christian Everdell
To:
Cc:
(USANYS)"
,
)"
Jeff Pagliuca
"Laura Menninger"
>, , 'BOBBI C
STERNHEIM'
Subject: Letter to Judge Nathan
Date: Fri, 30 Apr 2021 21:56:35 +0000
Attachments: 2021.04.30_Letter_to_Judge_Nathan_re_Hard_Drives.pdf
Inline-Images: image005.jpg; image006.jpg
-
Please see the attached letter to Judge Nathan, which was just filed on the docket.
Regards,
COHEN & GRESSER LLP
New York, NY 10022
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00020243


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=== Page 1 ===
J78repsc
1
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
2
X
3
UNITED STATES OF AMERICA
4
V.
19 CR 490 (RMB)
5
JEFFREY EPSTEIN,
Conference
6
Defendant.
7
X
New York, N.Y.
8
July 8, 2019
2:00 p.m.
9
Before:
10
HON. RICHARD M. BERMAN
11
District Judge
12
13
APPEARANCES
14
15
GEOFFREY S. BERMAN
United States Attorney for the
16
Southern District of New York
17
18
Assistant United States Attorneys
19
REID H. WEINGARTEN
20
MARTIN G. WEINBERG
MARC FERNICH
21
Attorneys for Defendant
22
Also Present:
23
- Special Agent FBI
24
- NYPD
- Probation Officer
25
- Probation Officer
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020185

=== Page 2 ===
J78repsc
2
1
(Case called)
2
THE COURT: Good afternoon.
3
I think I'm pretty much up to speed as to where you
4
are in the sense that I am aware that you have been before
5
Magistrate Judge Pitman earlier this morning and up to some few
6
minutes ago for purposes of presentment, arraignment, and some
7
preliminary discussion of bail. Is that accurate?
8
MR.
:
That's correct, your Honor. I don't
9
want to speak for defense counsel, but my understanding is they
10
expect to put in some sort of written submission and return to
11
argue the rest of the bail hearing on Thursday before Judge
12
Pitman at 2:00. That is, if your Honor refers the bail hearing
13
to Judge Pitman on that basis as well.
14
THE COURT: I might just take that bail application
15
before me. We'll figure out a time when that would be
16
comfortable for all of you. How is that?
17
MR. WEINGARTEN: That's fine with the government, your
18
Honor.
19
THE COURT: I have a few items on my list. I want to
20
make mention, I'm sure Magistrate Judge Pitman did, of our
21
presumption of innocence. Even though in some of these
22
discussions, and probably more so when we get to bail, it may
23
sound like we are talking about merits of the case, it's
24
important that we underscore that the presumption of innocence
25
pertains to Mr. Epstein, now and until such time, if it comes,
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020186

=== Page 3 ===
J78repsc
3
1
that there is a guilty determination by a jury or by the Court,
2
that he is presumed to be innocent.
3
I did have these questions. One has to do with
4
persons who are categorized as victims. I want to get some
5
assurance from the U.S. Attorney's office that they have been
6
notified about this case and that you will keep them abreast of
7
developments in this case.
8
MR.
:
Yes, your Honor, we are acutely aware
9
of our obligations to the victims in this case. We have
10
notified them and we expect to continue to do so as the case
11
moves forward.
12
THE COURT: Second, for my background, I am aware that
13
there are certain conditions that attach to Mr. Epstein's sex
14
offender status resulting from his Florida state prosecution in
15
or about 2008. One result is that under New York law --
16
correct me if I'm wrong about any of this -- he is considered
17
to be at high risk of committing another sex crime with minors.
18
Is that a fair characterization of his sex offender status?
19
MR.
:
Your Honor, as the government set
20
forth in its submission to Judge Pitman, and we copied this
21
Court, it is our understanding that the defendant is a tier 3
22
sex offender in New York and that that is characterized as
23
high-risk individual.
24
THE COURT: The question that I have is what are the
25
implications, if any, of the search conducted by the U.S.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020187

=== Page 4 ===
J78repsc
4
1
Attorney's office over the weekend of Mr. Epstein's residence
2
on East 71st Street for the terms and conditions of his sex
3
offender status, if any? Are there any consequences or
4
relationship between what was uncovered and what he is obliged
5
to do?
6
MR.
:
May I have one moment, your Honor?
7
THE COURT: Yes.
8
MR.
:
Your Honor, in response to that
9
question, at the outset I should say that we don't have
10
particular interaction with state authorities with respect to
11
those types of notifications. We are, I would say, in the
12
early stages of reviewing those materials. With respect to the
13
defendant's obligations or potential consequences in the New
14
York State system, we certainly will notify whichever
15
authorities are appropriate. I don't think that we have a role
16
other than that.
17
I will say that they are extremely concerning with
18
respect to bail here, with respect to the conduct here, and I
19
expect we will get into that more in our submissions and bail
20
argument.
21
THE COURT: By the way, if defense counsel wants to
22
jump in at any point, feel free to do that?
23
MR. WEINGARTEN: On that, we have not seen the
24
pictures.
25
THE COURT: I haven't either.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020188

=== Page 5 ===
J78repsc
5
1
MR. WEINGARTEN: I understand. It is our expectation
2
that they are ancient, that they are pre his spending time in
3
prison, and/or they are erotic pictures of adults who
4
voluntarily engaged in that conduct.
5
THE COURT: I have a question about the Southern
6
District of Florida nonprosecution agreement dated probably in
7
2008 -- is that correct?
8
MR.
:
It's dated in 2007, your Honor.
9
THE COURT: Is that a public document?
10
MR. WEINGARTEN: It is, your Honor. It's been
11
publicly filed in connection with other civil litigation.
12
THE COURT: Does that agreement bear on in any way the
13
search and results of the search that were conducted at Mr.
14
Epstein's townhouse over the weekend?
15
MR.
:
Not in ways that I am aware of now,
16
your Honor. Again, we are very much in progress on the search.
17
We will continue to consider any other implications beyond this
18
case as we continue to review those materials.
19
On a separate note, your Honor, I want to add the
20
government noted it is aware of its victim obligations. In
21
terms of notification, we have made notification to individuals
22
that we are in particular aware of. We also have listed a
23
phone number for victims to be in touch with the FBI, with the
24
U.S. Attorney's office. We have also put a website up and have
25
asked victims to be in touch with us through those sources as
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020189

=== Page 6 ===
J78repsc
6
1
well. That is just to round out the notification that the U.S.
2
Attorney's office has made.
3
MR. WEINGARTEN: May I be heard briefly on that?
4
THE COURT: Sure.
5
MR. WEINGARTEN: For us, your Honor, the NPA is the
6
center of the universe for everything, search included, because
7
the NPA was the result of an extensive 3-year investigation by
8
law enforcement in Florida. In essence, the Feds made Mr.
9
Epstein plead to a state offense and they declined prosecution
10
federally, and that is translated in the NPA. Mr. Epstein did
11
his time, Mr. Epstein is on the registration list, and Mr.
12
Epstein paid the alleged victims.
13
As I am sure you have noted from the indictment, that
14
conduct too is an ancient history. That conduct is 2002 to
15
2005. It is our belief that this is basically a re-do. This
16
is basically the Feds today, not happy with what happened in
17
the decision that led to the NPA, redoing the same conduct that
18
was investigated 10 years ago and calling it, instead of
19
prostitution, calling it sex trafficking. We think that is the
20
heart of everything, and that will be the centerpiece of our
21
defense, at least legally.
22
THE COURT: My understanding of what the government is
23
asserting is that the episodes that occurred in Manhattan were
24
not included in the nonprosecution agreement in Florida and
25
that there is a separate basis not only for a sex trafficking
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020190

=== Page 7 ===
J78repsc
7
1
count but also for a sex trafficking conspiracy count.
2
MR. WEINGARTEN: We have had good conversations with
3
the prosecutors, and we like and respect them. We are looking
4
forward to getting discovery. We are interested to see whether
5
the prosecutors in Florida, who are now under severe criticism
6
10 years later, steered the alleged victims to New York,
7
whether or not they violated their responsibilities under the
8
NPA.
9
THE COURT: Whether the federal prosecutors in Florida
10
violated their terms and conditions?
11
MR. WEINGARTEN: That will certainly be germane.
12
THE COURT: Is that the point?
13
MR. WEINGARTEN: Yes.
14
THE COURT: Got it.
15
MR.
:
Your Honor, if I could very briefly
16
respond to those points?
17
THE COURT: Sure.
18
MR.
: I expect this will be briefed and
19
argued on Thursday. I don't intend to go into extensive
20
details about that. I just want to flag for the Court that
21
defense counsel is saying that this conduct is ancient. What
22
he is not saying is it is beyond the statute of limitations,
23
because it is not.
24
Second, the allegation that this is some kind of a
25
conspiracy within the Department of Justice is just false.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020191

=== Page 8 ===
J78repsc
8
1
There is no evidence to support that. The investigation was
2
begun and conducted entirely separate from any other district.
3
It began in the Southern District of New York.
4
Certainly there is evidence that was gathered that is
5
consistent with and even overlapping with the prior
6
investigation. But as the Court noted, in particular an entire
7
count of this indictment is with respect to New York victims.
8
And that is before we even get to the fact that the
9
nonprosecution agreement does not bind the Southern District of
10
New York.
11
THE COURT: I was going to ask you about that too.
12
Now that you have mentioned the topic, explain that, would you.
13
MR.
:
Yes, your Honor. I do expect that we
14
can brief this, but the short version is that this prosecution
15
is not precluded by the nonprosecution agreement entered into
16
by the defendant in the Southern District of Florida. That
17
agreement expressly referred to that federal district. It
18
didn't purport to bind any other office or district.
19
It is well-settled in the Second Circuit that a plea
20
agreement in one U.S. Attorney's office does not bind another
21
unless otherwise stated. That is even if, based on case law,
22
the agreement refers generally to "the government." Again,
23
additionally, as set forth in the indictment returned by the
24
grand jury, the substantive count alleges acts occurring in New
25
York and alleges New York-based victims.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020192

=== Page 9 ===
J78repsc
9
1
That is in spite of the fact that the Southern
2
District is not bound, is not a signatory to, and otherwise has
3
no connection to the NPA. And there is no evidence that we
4
have come across that the Southern District of New York was
5
consulted, asked, involved, notified as far as we have seen.
6
For those reasons and others I'm sure we will brief,
7
we don't think the NPA applies to us.
8
MR. WEINBERG: If I may reply briefly, your Honor?
9
THE COURT: Yes.
10
MR. WEINBERG: I have been one of Mr. Epstein's
11
counsel through the CVRA litigation which started in 2008 and
12
continues. In fact, our briefing is today. The NPA provided
13
him with immunity for any offenses arising from a joint
14
FBI/grand jury/U.S. Attorney investigation that led to a
15
decision by Mr. Epstein to plead to a higher state offense than
16
the state prosecutors contemplated. He went to jail, signed an
17
agreement, and has lived up to its terms 100 percent.
18
We have seen in the paperwork of the CVRA, in the
19
Southern District of Florida, in writing at docket 205-2 the
20
government's motion to dismiss CVRA, urging that the witnesses
21
there go to the Southern District of New York and essentially
22
try to motivate them to prosecute for the very same conduct, in
23
other words, the conduct that Mr. Epstein was immunized,
24
including travel between two states, telephonic communications
25
between two states. Florida immunized him for the same travel
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020193

=== Page 10 ===
J78repsc
10
1
and telephonic communications as well as the 1591 category.
2
In addition, the Department of Justice reviewed the
3
NPA on several occasions in 2008 and essentially confirmed that
4
the exercise of discretion shown in Florida was appropriate.
5
But the most important thing is that there was communication
6
between the prosecutors in Florida, perhaps through prosecutors
7
in Georgia that took over the case because the Florida
8
prosecutors were recused as a result of Judge Marrah's
9
decisions in the CVRA case.
10
We know the government is relying in part on evidence
11
that was generated by the Southern District of Florida case
12
back in 2007. They have talked about message pads, telephone
13
records. They are the same message pads and telephone records
14
that reflect conduct that was exclusively 15, 16, 17 years ago.
15
So we do have a principal position that we will put to the
16
Court at the appropriate time regarding the legality of this
17
prosecution and whether or not it is appropriately barred.
18
I can say as a criminal defense lawyer of 45 years,
19
when there is an interstate wire, mailing, travel, and there is
20
one district that is conducting an investigation, you negotiate
21
with that district and count on the Department of Justice to
22
what it does every day decade after decade after decade, which
23
is not to go to the second jurisdiction that received the mail
24
that was sent from the immunizing jurisdiction and have a
25
prosecution on the very same conduct. We will be briefing
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 11 ===
J78repsc
11
1
that.
2
THE COURT: Do you anticipate that there is going to
3
be any discussion here about the legality of the NPA?
4
MR. WEINBERG: Not the legality of the NPA. I think
5
the discussion here is going to be about its scope.
6
THE COURT: From the defense, yes. You don't think
7
you expect to hear anything from the government, for example?
8
MR. WEINBERG: In the Southern District case, the CVRA
9
case, maybe two weeks ago the Northern District of Georgia
10
prosecutors, who are proxy for the Southern District of
11
Florida, filed the submission before District Judge Marrah in
12
the CVRA case totally supporting the constitutionality and
13
legality of the NPA, their discretion to enter into it, and
14
that there absolutely has never been a charge that Mr. Epstein
15
ever did anything other than fully perform his end as a citizen
16
who is expecting the benefits of a contract that he lived up
17
to.
18
THE COURT: I thought there had been some contention
19
that the way that the victims vis-a-vis the Florida NPA were
20
dealt with or not dealt with was one basis for attacking the
21
legality of that arrangement.
22
MR. WEINBERG: The petitioners are vigorously and have
23
vigorously for many years challenged, many years starting quite
24
frankly after Mr. Epstein performed his obligations to go to
25
jail and challenged it, claiming that there was no consultation
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020195

=== Page 12 ===
J78repsc
12
1
prior to the government's entering the agreement.
2
The Department of Justice at the time did not believe
3
the CVRA extended absent a federal charge. The predicate is a
4
federal crime that harms a victim. The petitioners have
5
vigorously asserted a different position. Judge Marrah, in a
6
summary judgment motion, agreed with the petitioners as to the
7
fault of the government in not conferring. The issue of remedy
8
is before Judge Marrah at the present time, your Honor.
9
THE COURT: Okay.
10
MR.
:
Your Honor, if I may very briefly?
11
THE COURT: Yes.
12
MR.
:
The crux of the defense argument here
13
I think cuts precisely the other way. They are arguing that
14
the Southern District of Florida has sort of sent up a flag
15
that these prosecutions could be undertaken elsewhere. That's
16
true. The Southern District of Florida has argued in papers
17
that they believed, the Southern District of Florida believed,
18
that the nonprosecution agreement was limited to that district.
19
They have said that out loud and in public and in their
20
positions in filing.
21
So certainly this investigation was not shoveled to
22
the Southern District of New York from anywhere else, including
23
the Department of Justice. We expect that the nonprosecution
24
agreement will not be an impediment, in particular because the
25
defendant certainly did not lack for sophisticated counsel in
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020196

=== Page 13 ===
J78repsc
13
1
negotiating that agreement, which again did not include the
2
Southern District of New York. We don't expect that to be any
3
impediment at all here.
4
THE COURT: Got it.
5
This is a small item. In the pretrial services report
6
which was prepared today -- how many, if more than one,
7
passports does Mr. Epstein have?
8
MR. WEINGARTEN: Mr. Epstein reported today one. Two
9
others were rescinded. As we understand it, there is one
10
effective passport today.
11
I would like to make one other point about the
12
pretrial that is extremely important.
13
THE COURT: Go ahead.
14
MR. WEINGARTEN: The way it reads is that we have
15
refused to provide information about income and assets.
16
THE COURT: I didn't really read it that way myself.
17
I thought it was incomplete in some places and I thought it
18
could be beefed up, so to speak. But I imagine that in the
19
bail application those matters may be dealt with.
20
MR. WEINGARTEN: Exactly.
21
THE COURT: For Mr.
: In your letter you
22
describe some obstruction or harassment, witness tampering,
23
alleged, by Mr. Epstein. That, I take it, is going to be
24
included in any response or any bail submission made by the
25
government?
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 14 ===
J78repsc
14
1
MR.
:
Your Honor, I think we addressed that
2
in our initial submission. To the extent defense counsel has a
3
response to it, we will evaluate that response and see whether
4
additional submission from the government is required or
5
appropriate.
6
THE COURT: I think that's it for me in terms of
7
questions that I might have had.
8
There is, of course, a conspiracy charge here, one of
9
the two counts. It may be early in your investigation to know.
10
Do you anticipate that there may be other defendants in this
11
proceeding?
12
MR.
:
Your Honor, we don't expect any
13
imminent superseding indictments in this case. It certainly is
14
possible down the road.
15
MR. WEINGARTEN: May I make one point, your Honor?
16
These obstruction allegations we find very nettlesome and
17
bothering. My understanding is that the Feds and Mr. Epstein's
18
attorneys back in the early 2000s, or 2007 and 8, when they
19
were negotiating were looking desperately for an appropriate
20
statute. They finally settled on a state statute that Mr.
21
Epstein pled to. We all know how unusual that is. There was
22
some consideration of a federal statute, including obstruction.
23
So lawyers in good faith were having discussions back
24
and forth whether or not they could squeeze Mr. Epstein's
25
conduct into a particular statute, and they concluded they
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020198

=== Page 15 ===
J78repsc
15
1
couldn't because the facts didn't fit. That is my
2
understanding of how those obstruction discussions arose.
3
THE COURT: Got it.
4
In terms of bail application, it would be helpful, and
5
maybe this is your anticipation, to file written submissions.
6
If you could do that. What I'm getting to is Thursday
7
afternoon is not a good time, in my opinion. I would prefer to
8
do it, if you would go along with this, Monday morning at, say,
9
9:30. That would give everybody more time to make these
10
submissions and to study them. Is that agreeable?
11
MR. WEINGARTEN: Yes.
12
MR. WEINBERG: Yes.
13
THE COURT: Why don't we say Monday at 10:00. Have
14
you arranged written submissions on any time schedule with
15
Magistrate Judge Pitman?
16
MR.
:
May we have just a moment, your
17
Honor, with defense counsel?
18
THE COURT: Yes, would you. And also determine if one
19
party or the other is going first and that the other is
20
responding or they are simultaneous.
21
MR.
: Yes, your Honor. Thank you.
22
(Pause)
23
MR.
: Your Honor, the government is
24
prepared to rely on its initial submission at least for its
25
first argument. I expect defense counsel will respond to that
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020199

=== Page 16 ===
J78repsc
16
1
and propose a package. Then the government would like an
2
opportunity to reply to that submission.
3
The parties would be happy to make those deadlines
4
Thursday and Saturday respectively. However, we are also happy
5
to back that up a little bit if the Court prefers not to
6
receive the government's submission over the weekend. We could
7
do an earlier deadline on Thursday for defense and a late
8
Friday deadline for the Court from the government, depending on
9
what the Court prefers.
10
THE COURT: I was going to propose defense Thursday at
11
noon. Is that okay to get your submission in?
12
MR. WEINBERG: We can do that, your Honor.
13
THE COURT: Thanks.
14
And if you could respond Friday by 5:00 p.m.
15
MR.
: We will, your Honor. Thank you.
16
THE COURT: Then we can have oral presentations. I
17
take it everybody wants to have oral presentations in addition
18
to the written. I'll set aside as much time as we need on the
19
15th at 10:00.
20
I ask the government if there is a speedy trial issue
21
or application that takes us to Monday at 10:00 a.m.
22
MR.
: Yes, your Honor. The government asks
23
that speedy trial time be excluded until Monday. We do expect
24
to begin the process of working on producing discovery, to
25
include discussions with defense counsel about a protective
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020200

=== Page 17 ===
J78repsc
17
1
order. I think, frankly, the outcome of that will be effected
2
by the coming week. But we do expect to have those
3
conversations and therefore request that speedy trial time be
4
excluded until Monday.
5
THE COURT: I am going to find under 18 United States
6
Code 3161 that the request for adjournment, joined in by both
7
sides, to and including Monday the 15th at 10:00 a.m., is
8
appropriate and warrants exclusion of the adjourned time from
9
speedy trial calculations.
10
I further find that the exclusion is designed to
11
prevent any possible miscarriage of justice to facilitate these
12
proceedings and, initially at least, so that counsel has time
13
to prepare written bail submission and to guarantee effective
14
representation of and preparation by counsel for both sides.
15
Thus, the need for exclusion and the ends of justice outweigh
16
the interests of the public and the defendant in a speedy trial
17
pursuant to 18 U.S.C. section 3161 (h) (7) (A) and (B).
18
Does anybody want to add anything to today's session?
19
MR.
:
Your Honor. May we have one more
20
moment with defense counsel?
21
THE COURT: Sure.
22
(Pause)
23
MR.
:
Nothing from the government. Your
24
Honor.
25
THE COURT: Defense?
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020201

=== Page 18 ===
J78repsc
18
1
MR. WEINBERG: Nothing from the defense, your Honor.
2
THE COURT: Nice to see you all. See you on Monday.
3
Thank you.
4
(Adjourned)
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00020202


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=== Page 1 ===
From:
To:
)"
Subject: RE: FOIA, Jeffrey Epstein
Date: Tue, 16 Mar 2021 16:44:00 +0000
Sure thing!
From:
Sent: Tuesday, March 16, 2021 12:30 PM
To:
>;
Cc:
>;
(USANYS)
Subject: RE: FOIA, Jeffrey Epstein
Hi
Thanks very much, I'll check with
to make sure I have the complete data set, and thanks for your help putting this
together.
Best,
From:
Sent: Tuesday, March 16, 2021 10:08 AM
To:
is
Cc:
is
(USANYS)
Subject: RE: FOIA, Jeffrey Epstein
Hi
I've attached a list that I put together. We have also forwarded a list to
which may be more comprehensive.
We've tried our best to chase all of these requests down. Please let me know if you have any questions.
Thanks,
From:
>
Sent: Monday, March 15, 2021 5:33 PM
To:
Cc:
>;
(USANYS)
i
;
Subject: RE: FOIA, Jeffrey Epstein
Hi
I am adding an attorney
on here. He may have a list of such requests to pass along.
Best,
EFTA00018989

=== Page 2 ===
From:
Sent: Monday, March 15, 2021 5:10 PM
To:
Cc:
is
(USANYS)
Subject: FOIA, Jeffrey Epstein
Hi
In connection with a criminal discovery matter, my colleagues and I were hoping to track down a list of all Jeffrey Epstein-
related FOIA requests, which we understand are tracked through EOUSA
recommended that we reach out
to you, in the hopes that you might be able to help us pull together a list (or help us connect with someone who can
gather that information). We'd very much appreciate any information or guidance you might have.
Thanks so much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00018990


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=== Page 1 ===
From:
To:
Subject: RE: U.S. V. Maxwell, 20 Cr. 330 (AJN) -- proposed protective order
Date: Thu, 09 Jul 2020 19:36:13 +0000
Attachments: 2020-07-03,_GM,_protective_order_for_discovery_(AJN).docx
Chris, Mark,
Further to our previous discussions, attached please find a proposed protective order. Once we have a finalized order
from the Court, we expect to be able to begin to make productions very shortly. Please let us know if any questions or
issues, and we'll get the ball rolling on discovery.
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00020367


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
Subject: RE: Discovery Issues
Date: Mon, 29 Mar 2021 22:37:05 +0000
Inline-Images: image001.jpg; image002.jpg
Thank you!
From:
(USANYS) [Contractor]
Sent: Monday, March 29, 2021 6:28 PM
To:
)
Cc:
>;
(USANYS)
Subject: RE: Discovery Issues
The materials have gone out successfully. I've attached a screenshot of the confirmation for our records.
From:
Sent: Monday, March 29, 2021 6:24 PM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: FW: Discovery Issues
Will, would you please send these and let me know when they've gone out? Thanks so much!
From: Christian Everdell
Sent: Monday, March 29, 2021 6:22 PM
To:
)
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; ; Laura Menninger
>; Bobbi Sternheim
-
is
(USANYS) [Contractor]
i
Thomas J. Powers
Subject: RE: Discovery Issues
Thanks,
Please send the docs via the link below:
From:
)
Sent: Monday, March 29, 2021 3:53 PM
To: Christian Everdell;
);
(USANYS)
Cc: 'Jeff Pagliuca'; Laura Menninger; Bobbi Sternheim
(
);
(USANYS) [Contractor]
Subject: RE: Discovery Issues
Chris,
EFTA00019595

=== Page 2 ===
Following up on point number 7, that gap would not come in between those two productions but would instead be
contained solely in the November 18, 2020 production. If you are missing those files, the omission was unintentional, and
we have those files available to produce immediately. If you can send a link to your ftp site, our paralegal can upload
those materials right away.
Best,
Assistant United States Attorney
Southern District of New York
From:
Sent: Monday, March 29, 2021 3:36 PM
To: Christian Everdell
i
>;
(USANYS)
Cc: 'Jeff Pagliuca'
; Laura Menninger
>; Bobbi Sternheim
Subject: RE: Discovery Issues
Chris,
We are available for a call to discuss tomorrow between 1pm and 2pm, between 3pm and 5pm, or after 5:30pm. Please
let us know if there is a time in those windows that would work on your end. In the meantime, below are some initial
responses:
1. Our supervisors have indicated that we are not permitted to send a drive that our IT department did not load to
the MDC. As a result, we cannot provide the drive directly to the MDC. That said, I am happy to join you in asking
the MDC to accept the drive from you. If the MDC still refuses, then my office would not object to an application to
Judge Nathan for an order directing the MDC to accept the drive from you, though we would need to allow MDC
legal counsel the opportunity to note their objections to Judge Nathan.
2. The MDC recently alerted us to this issue, and our paralegal converted the excel files at issue to pdfs and sent a
new CD with those pdfs to the MDC. If you client still cannot view them, then we are happy to load them to a drive
if you would like to provide one for us.
3. I have asked our vendor to look into this issue and will get back to you when I have spoken with them.
4. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said,
similar to the note I sent in my email regarding highly confidential images on March 16, 2021, the electronic files
recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized
each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except for data
showing when a particular file was saved to a drive by the investigative team or prepared for production.
5. As indicated in our November 9, 2020 discovery letter, all images within Bates range SDNY_GM_00467566 though
SDNY_GM_00514100 were seized during the 2019 searches of Epstein residences. These are the images from the
CDs that were recovered during those searches, so they did not come from any of the electronic devices that were
EFTA00019596

=== Page 3 ===
the subject of extractions by CART. As a result, these images would not have CART numbers. As for the metadata, I
have asked our vendor to look into this issue and will get back to you when I have spoken with them.
6. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, I
note again that the electronic files recovered from Epstein's devices have the same metadata on the hard drive that
was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so
none is viewable. Additionally, as indicated in our November 9, 2020 discovery letter, all images within the
SDNY011 load file (Bates range SDNY_GM_00467566 though SDNY_GM_00514100) were seized during the 2019
searches of Epstein residences. These are the images from the CDs that were recovered during those searches, so
they did not come from any of the electronic devices that were the subject of extractions by CART. As a result,
these images would not have CART numbers.
7. I have asked our paralegals and vendor to look into the Bates gap and will get back to you when I have spoken to
them.
Best,
Assistant United States Attorney
Southern District of New York
From: Christian Everdell
Sent: Monday, March 29, 2021 2:40 PM
To:
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; Laura Menninger
>; Bobbi Sternheim
Subject: Discovery Issues
and
-
We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a
call to discuss.
1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created
(without the highly confidential items). You had said you would check to see if you could facilitate this. We have
not heard back from you. Are you able to send Ms. Maxwell the hard drive?
2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and
must use the prison computer. But the prison computer cannot read some of the files. We can include these files
on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please
advise which way you would like to proceed.
3. A number of the emails in the discovery - over 109,000 - were produced without their attachments (see tab 1 of
the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the
EFTA00019597

=== Page 4 ===
missing attachments, if they exist.
4. A number of electronic documents - over 110,000 - that were extracted from one of Epstein's devices, as identified
by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or
afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with the original
metadata for these files.
5. A number of photographs - over 6500 - were produced in native format, but do not have a CART number and have
"date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please
provide the CART number for these photographs or specify which device they came from. Also, we request that
you produce a metadata overlay with the original metadata for these files.
6. A number of the audio/visual files - over 460 - have similar metadata issues (see tab 4 of the attached Excel file).
These fall into the following buckets:
a. SDNY_GM_SUPP: these have CART numbers, but were produced without metadata load files and have
"date created" and "date last modified" dates in September-November 2020, after the date the device was
seized. We request that you produce a metadata overlay with the original metadata for these files.
b. SDNY005 (October 20, 2020 production): these are a few videos from the SDFL or PBPD investigations that
were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that
you produce a metadata overlay with the original metadata for these files.
C. SDNY011 (November 9, 2020 production): these were produced in native form with load files, but do not
reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these
files or indicate their source. Also, we request that you produce a metadata overlay with the original
metadata for these files.
7. There is a gap between 11/18 and 12/18 production numbers (SDNY_GM_02742044 to 2742183). Was that
intentional or are we missing those documents?
Please let us know your responses as soon as possible.
Thanks,
Chris
Christian R Everdell
COHEN & GRESSER LLP
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00019598


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=== Page 1 ===
From:
To: Gloria Allred
Subject: Re: Urgent!
,an Epstein victim, just told me that she was able to get child care
and would like to fly to New York for the hearing Tuesday. What is your telephone number,
so that I can call you a.s.a.p.?
Date: Sun, 25 Aug 2019 18:25:11 +0000
Inline-Images: image001.png; image002.jpg
Thanks, I sent this to
> On Aug 25, 2019, at 2:24 PM, Gloria Allred
wrote:
>
>
Martindale-Hubbell"
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2017
ALLRED, MAROKO & GOLDBERG
2018
Best Lawyers
EFTA00019682


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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
(USANYS)"
)"
Cc:
(USANYS)"
Subject: RE: Maxwell superseder prosecution memo
Date: Wed, 24 Mar 2021 15:19:56 +0000
Attachments: Maxwell_S2_Indictment_v1_redline.docx
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
)
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
To:
is
is
(USANYS)
is
Cc:
(USANYS)
Subject: FW: Maxwell superseder prosecution memo
EFTA00019484

=== Page 2 ===
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)
i
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
is
(USANYS)
is
)
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)
is
(USANYS)
is
>;
(USANYS)
is
)
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,
EFTA00019485


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=== Page 1 ===
From:
<noreply@box.com>
To:
Subject:
has invited new collaborators to 'Epstein Death' folder on Box
Date: Wed, 22 Jan 2020 16:28:07 +0000
has invited 1 collaborator(s) to 'Epstein Death' folder:
Epstein Death
Epstein Death
Collaborated Folder
View Folder
Collaborators Invited:
usdoj.gov@esfs.us
About Box Privacy Policy * Edit Notification Settings . 900 Jefferson Avenue, Redwood City, CA 94063, USA
C 2020
This is an official notification from the USAfx File Exchange system.
EFTA00018102


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Confidential - Epstein
Date: Fri, 16 Aug 2019 17:23:32 +0000
Looks good
From:
(USANYS)
Sent: Friday, August 16, 2019 9:39 AM
To:
(USANYS)
Subject: RE: Confidential - Epstein
Thoughts?
Thank you for reaching out. We are not able to share that information at this time. If there is anything that you believe
would be useful for us to know as we continue our investigation, please let us know.
From:
(USANYS)
Sent: Friday, August 16, 2019 9:33 AM
To:
(USANYS)
Subject: FW: Confidential - Epstein
How should we respond to this?
From: Martin G. Weinberg
Sent: Thursday, August 15, 2019 4:53 PM
To:
(USANYS)
is
(USANYS)
Cc: 'Miller, Michael'
>; 'Martin G. Weinberg'
>; Reid Weingarten
Subject: Confidential - Epstein
provided us with your contact info. As the prior criminal defense attorneys for Mr
Epstein, and with the approval of the attorney for his Estate, we would ask for you to consider allowing one or more of us
to view any videos showing his jail cell at the MCC or the hallway leading to the entry to his jail cell from midnight-7 AM
on Aug 10, 2019. We would appreciate your consideration of this request.
If we can otherwise help, let us know.
Thanks
Marty
Martin G. Weinberg, Esq.
This Electronic Message contains information from the Law Office
of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee
only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents
of this message is prohibited.
EFTA00018898


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=== Page 1 ===
From:
To:
Subject: Jeffrey Epstein Doc: Shocking Revelations from Netflix's 'Filthy Rich' - Rolling Stone
Date: Fri, 29 May 2020 17:43:51 +0000
https://www.rolingstone.com/culture/culture-features/jeffrey-epstein-filthy-rich-netflix-documentary-1006535/
Sent from my iPhone
EFTA00019099


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=== Page 1 ===
From:
"
)"
To:
(USANYS)"
)"
Subject: FW: JOINT Proposed Voir Dire Sent_(Reponse to Defense v1) (002).docx
Date: Sun, 10 Oct 2021 19:50:24 +0000
Attachments: JOINT_Proposed_Voir_Dire_Sent_(Reponse_to_Defense_v2).docx
Updated version that incorporates
edits is attached and on the share.
From:
(USANYS)
Sent: Sunday, October 10, 2021 3:08 PM
To:
(USANYS)
is
)
>;
Cc:
(USANYS)
Subject: JOINT Proposed Voir Dire Sent_(Reponse to Defense v1) (002).docx
This looks good. A few additions in comment bubbles.
I'm going to call you now.
EFTA00020094


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=== Page 1 ===
From:
=
To:
Subject: Accepted: Meet re: Epstein Investigation
Date: Wed, 05 Dec 2018 01:24:22 +0000
Importance: Normal
Attachments: unnamed
EFTA00019429


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c0:
=== Page 1 ===
From:
Subject: Re: Jeffrey Epstein's cell is three doors down from El Chapo
Date: Fri, 12 Jul 2019 21:59:45 +0000
Importance: Normal
Billionaire (or multi-millionaire's) row...
Sent from my iPhone
> On Jul 12, 2019, at 5:57 PM,
wrote:
>
>
V
https://nypost.com/2019/07/12/jeffrey-epsteins-cellis-three-doors-down-from-el-chapo/
>
>
> Sent from my iPhone
EFTA00018269


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=== Page 1 ===
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
July 2, 2020
The Honorable Katharine H. Parker
United States District Court
Southern District of New York
500 Pearl Street
New York, New York 10007
Re:
Unsealing of Indictment 20 Cr. 330
Dear Judge Parker:
The Government respectfully requests that Indictment 20 Cr. 330 be unsealed and that a
United States District Judge be assigned to the case. A proposed order to that effect is attached.
This case is designated as a Wheel C case.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By:
/
/
Assistant United States Attorneys
Tel.:
Enclosure
EFTA00020352

=== Page 2 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
Unsealing Order
— V. —
20 Cr. 330
GHISLAINE MAXWELL,
Defendant.
Upon the application of the United States, by the Acting United States Attorney for the
Southern District of New York, Audrey Strauss, by Assistant United States Attorney
;
It is found that the Indictment in the above-captioned case is currently sealed and the United
States Attorney's Office has applied to have that Indictment unsealed, and it is therefore:
ORDERED that the Indictment in the above-captioned action be unsealed and remain
unsealed pending further order of the Court.
Dated:
New York, New York
July 2, 2020
HONORABLE KATHARINE H. PARKER
UNITED STATES MAGISTRATE JUDGE
SOUTHERN DISTRICT OF NEW YORK
EFTA00020353

=== Page 3 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
GHISLAINE MAXWELL,
Defendant.
ORDER
20 Cr. 330 ( )
(18 U.S.C. $$ 2422, 2423 (a), 1623, 371, & 2.)
AUDREY STRAUSS
Acting United States Attorney.
EFTA00020354


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 10893150(1) has received final approval
Date: Mon, 23 Dec 2019 17:08:41 +0000
Importance: Normal
Dear
Final voucher 10893150(1) has received final approval.
Trip ID: 10893150
Voucher ID: 1
Voucher type: Final
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R20NYS13257 - U.S. V. Epstein - Witness Interviews
Destination: Santa Monica, CA, United States
Dates: 2019-12-15 - 2019-12-17
Current status: Voucher Awaiting Payment
Voucher total expenses: 1400.38
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):
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This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
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EFTA00019903


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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: Your Amazon.com order of "2019 Newest HP Pavilion 15..." and 2 more items.
Date: Tue, 10 Nov 2020 20:28:23 +0000
Attachments: 2020-11-10,_GM,_letter_to_MDC_Warden.docx
I just addressed it to
- if this looks okay to you, once
reviews it we can email the letter to
and ask her
how she'd like us to get the laptop to MDC.
From:
)
Sent: Tuesday, November 10, 2020 2:26 PM
To:
Subject: RE: Your Amazon.com order of "2019 Newest HP Pavilion 15..." and 2 more items.
I don't know the new Warden's name. I I think it's fine to just address it to "Warden, Metropolitan Correctional Center".
Thanks!
From
)
Sent: Tuesday, November 10, 2020 12:26 PM
To:
)
Subject: Fwd: Your Amazon.com order of "2019 Newest HP Pavilion 15..." and 2 more items.
What is the warden's name? I can draft the letter we discussed.
Sent from my iPhone
Begin forwarded message:
From:
(USANYS)"
Date: November 10, 2020 at 12:23:28 PM EST
To:
)"
)"
Cc:
(USANYS)"
,
(USANYS)"
Subject: RE: Your Amazon.com order of "2019 Newest HP Pavilion 15..." and 2 more items.
The Maxwell Laptop is ready to be picked up in room 307. We removed all the laptops electronic communication, so it
has no Wi-Fi, Bluetooth or Ethernet connection capabilities. We tested access to the production data with the backup
BOP production and works fine. We placed a sticker on the laptop with the password.
Let me know if you have any questions.
From:
)
Sent: Monday, November 9, 2020 8:53 PM
To:
(USANYS)
)
Cc:
(USANYS)
(USANYS)
Subject: RE: Your Amazon.com order of "2019 Newest HP Pavilion 15..." and 2 more items.
Thanks so much,
Is the laptop large enough to save any of Maxwell's discovery on it? Or would doing so just slow
it down? I ask because her attorneys requested that we load her discovery onto the laptop if possible.
EFTA00019207

=== Page 2 ===
From:
(USANYS)
Sent: Monday, November 9, 2020 2:11 PM
To
Cc:
(USANYS)
)
(USANYS)
Subject: RE: Your Amazon.com order of "2019 Newest HP Pavilion 15..." and 2 more items.
It will be ready tomorrow morning.
From:
)
Sent: Monday, November 9, 2020 2:09 PM
To:
(USANYS)
Cc:
(USANY
;
)
(USANYS)
Subject: Re: Your Amazon.com order of "2019 Newest HP Pavilion 15..." and 2 more items.
Hi
Just checking on this- do you have an estimate of timing?
Thanks very much,
Sent from my iPhone
On Nov 6, 2020, at 11:00 AM,
(USANYS)
wrote:
Hard to tell it depends on getting all the updates loaded and configured. Let you know later when we have more info.
From:
)
Sent: Friday, November 6, 2020 10:57 AM
To:
(USANYS)
Cc:
USANYS)
is
)
(USANYS)
Subject: Re: Your Amazon.com order of "2019 Newest HP Pavilion 15..." and 2 more items.
Thanks very much, do you think it will be possible for us to deliver this to MDC on Monday?
Sent from my iPhone
On Nov 6, 2020, at 10:41 AM,
(USANYS)
wrote:
It has we are currently testing and configuring it to ensure it meets BOP standards.
From:
)
Sent: Friday, November 6, 2020 10:33 AM
To
USANYS)
Cc:
(USANYS)
;
)
(USANYS)
Subject: RE: Your Amazon.com order of "2019 Newest HP Pavilion 15..." and 2 more items.
EFTA00019208

=== Page 3 ===
Hi
Thanks again for your help with this - I'm checking in on the status of the laptop. Has it arrived?
Thanks,
From:
(USANYS)
Sent: Tuesday, November 3, 2020 7:20 AM
To:
Cc:
(USANYS)
)
;
USANYS)
Subject: FW: Your Amazon.com order of "2019 Newest HP Pavilion 15..." and 2 more items.
See below looks like the laptop might be here by Friday but most likely early next week. See below.
From:
(USANYS)
Sent: Monday, November 2, 2020 3:09 PM
To:
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
Subject: FW: Your Amazon.com order of "2019 Newest HP Pavilion 15..." and 2 more items.
FYI
From: Amazon.com <auto-confirm@amazon.com>
Sent: Monday, November 02, 2020 3:08 PM
To:
(USANYS)
Subject: Your Amazon.com order of "2019 Newest HP Pavilion 15..." and 2 more items.
Your
Amazon.c
Account
om
Amazon.com
Order Confirmation
Order #111-2544752-6074601
Order #111-0303935-3604241
Order #111-3128522-0349002
Hello
Thank you for shopping with us. We'll send a confirmation once your items have shipped. Your order details are
indicated below. If you would like to view the status of your order or make any changes to it, please visit Your Orders on
Amazon.com. Your digital video games and software purchases will be available in Your Games and Software Library.
Your purchase has been divided into 3 orders.
This order is placed on behalf of U.S. Attorney's Office, SDNY.
Order Details
Order #111-2544752-6074601
Placed on today, November 2
EFTA00019209

=== Page 4 ===
Your guaranteed delivery date is:
Your order will be sent to:
Monday, November 9
New York, NY
Your shipping speed:
United States
FREE Shipping
Order Details
Dell USB DVD Drive-DW316
$27.99
Personal Computers
Sold by Amazon.com Services LLC
Condition: New
Order Total:
$27.99
The payment details of your transaction can be found on the order invoice.
Order #111-0303935-3604241
Placed on today, November 2
Your estimated delivery date is:
Your order will be sent to:
Friday, November 6-
Tuesday, November 10
New York, NY
United States
Your shipping speed:
Standard Shipping
Order Details
2019 Newest HP Pavilion 15 15.6" HD Touchscreen
$757.98
Business Laptop Intel Quad-Core i5-8250U, 16GB
DDR4, 512GB SSD, Type-C, HDMI, WiFiAC, UHD,
Windows 10
Personal Computers
Sold by PConline365
Condition: New
Order Total:
$757.98
The payment details of your transaction can be found on the order invoice.
Order #111-3128522-0349002
Placed on today, November 2
Download and manage your digital video games and software purchases from
Games and software library
Microsoft Office Home and Business 2019 Download 1
$219.99
Person Compatible on Windows 10 and Apple MacOS
EFTA00019210

=== Page 5 ===
Microsoft
Sold by: Amazon.com Services LLC
Order Total:
$219.99
The payment details of your transaction can be found on the order invoice.
To learn more about ordering, go to Ordering from Amazon.com.
If you want more information or need more assistance, go to Help.
We hope to see you again soon!
Amazon.com
Top picks for you
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By placing your order, you agree to Amazon.com's Privacy Notice and Conditions of Use. Unless otherwise noted, items sold by Amazon.com or
Amazon Digital Services, Inc. are subject to sales tax in select states in accordance with the applicable laws of that state. If your order contains
one or more items from a seller other than Amazon.com and/or Amazon Digital Services, Inc., it may be subject to state and local sales tax,
depending upon the seller's business policies and the location of their operations. Learn more about tax and seller information.
This email was sent from a notification-only address that cannot accept incoming email. Please do not reply to this message.
EFTA00019211


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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: GM -- search warrant returns
Date: Wed, 21 Oct 2020 14:19:08 +0000
Embedded: RE:_GM__search_warrant_returns.msg
Sender:
Subject: RE: GM -- search warrant returns
Message-Id:
M>
To:
To:
Cc:
Cc:
EFTA00017947


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=== Page 1 ===
From: "Miller, Michael"
To:
,
Cc:
"Weingarten, Reid"
"Lucas, Morgan"
,
"Scavelli, Michael"
Subject: Epstein
Date: Tue, 20 Aug 2019 20:37:54 +0000
Attachments: 18_2019.08.20_Stipulation_to_Withdraw_Appeal-c2.pdf
Dear
-
Please see the attached that we filed a few minutes ago.
Mike
Michael C. Miller
Partner
www.steptoe.com/mmiller
Steptoe
direct
Steptoe & Johnson LLP
fax
1114 Avenue of the Americas
cell
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.
EFTA00019666


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=== Page 1 ===
From: Nathan NYSD Chambers
To: David Oscar Markus
Cc: bcsternheim_mac.com
Jeff Pagliuca
,
Laura Menninger
"Christian Everdell"
Subject: Re: Response of David Oscar Markus in United States V. Maxwell 20-Cr-330
Date: Fri, 30 Jul 2021 21:26:37 +0000
Attachments: 20cr330_Order_7.30.21.pdf
Dear Counsel:
Please see attached.
Sincerely,
Chambers of Judge Nathan
Subject: Response of David Oscar Markus in United States V. Maxwell 20-Cr-330
CAUTION - EXTERNAL:
Dear Judge Nathan,
I hope this email finds you and your staff doing well.
On June 30, 2021, the Government filed a letter directed at me, and this Court ordered that I respond by
today. I have not entered an appearance in this proceeding and am not a member of the Southern District
of New York, so I do not have filing privileges. Accordingly, I am emailing this responsive letter to
Chambers and respectfully request that it be filed on the public docket.
If the Court prefers that I have it filed it in a different fashion, please let me know.
I am, of course, also copying government counsel and defense counsel.
Have a nice weekend,
David
--David Oscar Markus
Markus/Moss
markuslaw.com
EFTA00018026

=== Page 2 ===
305-379-6667
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
EFTA00018027


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=== Page 1 ===
DEPARTMENT
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
July 2, 2020
The Honorable Katharine H. Parker
United States District Court
Southern District of New York
500 Pearl Street
New York, New York 10007
Re:
Unsealing of Indictment 20 Cr. 330
Dear Judge Parker:
The Government respectfully requests that Indictment 20 Cr. 330 be unsealed and that a
United States District Judge be assigned to the case. A proposed order to that effect is attached.
This case is designated as a Wheel C case.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By:
/
/
Assistant United States Attorneys
Tel.:
Enclosure
EFTA00020355

=== Page 2 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
Unsealing Order
— V. -
20 Cr. 330
GHISLAINE MAXWELL,
Defendant.
Upon the application of the United States, by the Acting United States Attorney for the
Southern District of New York, Audrey Strauss, by Assistant United States Attorney
;
It is found that the Indictment in the above-captioned case is currently sealed and the United
States Attorney's Office has applied to have that Indictment unsealed, and it is therefore:
ORDERED that the Indictment in the above-captioned action be unsealed and remain
unsealed pending further order of the Court.
Dated:
New York, New York
July 2, 2020
HONORABLE KATHARINE H. PARKER
UNITED STATES MAGISTRATE JUDGE
SOUTHERN DISTRICT OF NEW YORK
EFTA00020356

=== Page 3 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
GHISLAINE MAXWELL,
Defendant.
ORDER
20 Cr. 330 ( )
(18 U.S.C. $$ 2422, 2423 (a), 1623, 371, & 2.)
AUDREY STRAUSS
Acting United States Attorney.
EFTA00020357


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=== Page 1 ===
From:
.
(NY) (FBI)"
To:
)"
Cc:
(NY) (FBI)"
Subject: Re: [EXTERNAL EMAIL] - RE: Tomorrow - MDC
Date: Fri, 06 Nov 2020 13:54:11 +0000
Thank you.
On Nov 6, 2020 08:52,
)"
wrote:
Good morning,
I am not going to be present today. The purpose of the visit is just for Maxwell and her attorney to review the
contents of the laptop. Please proceed to the MDC visitor entrance, let the guard know you are from the FBI and
there for a visit with inmate Ghislaine Maxwell. They should then direct you to the visiting area. If there are
any issues, you can ask that they contact MDC legal counsel
, who knows to expect you.
I'm cc'ing
in case there are any other steps that the last pair of agents to handle this type of visit with
Maxwell took that I'm not aware of.
If you have any questions or issues, please feel free to call my cellphone at
Thank you so much for helping with this today.
On Nov 6, 2020, at 8:36 AM,
(NY) (FBI)
wrote:
Good morning
Where would you like us to meet you this morning?
On Nov 5, 2020 15:04,
)"
wrote:
Thank you so much!
Assistant United States Attorney
Southern District of New York
EFTA00019117

=== Page 2 ===
From:
(NY) (FBI)
Sent: Thursday, November 5, 2020 1:29 PM
To:
is
>;
(USANYS)
is
(NYPD)
Cc:
(NY) (FBI)
>;
(NY) (FBI)
Subject: Tomorrow - MDC
Copied here are SA
and SA
to assist at MDC tomorrow. I informed them that the new
time was from 9:15am - 3pm. Let me know if you need anything else from me.
Thank you
and
Thanks,
Special Agent Amanda Young
FBI New York Field Office
Child Exploitation/Human Trafficking
C:
EFTA00019118


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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Cc:
)"
Subject: Memo to File re Efforts to Identify
Interviews during Florida Investigation
Date: Wed, 29 Sep 2021 22:24:08 +0000
Team,
As discussed, below is a summary of the efforts we have taken to learn how many times
was
interviewed during the Florida investigation and to gather any record of such interview(s):
AUSAs reviewed scans of full Florida FBI file on Relativity. From that review, we identified handwritten notes and
302 reflecting a single interview occurring on or about August 7, 2007 with Florida FBI agents.
AUSAs and paralegals reviewed scans of full SDFL file on Relativity. From that review, we identified no record of any
additional interviews with
AUSAs conducted a keyword search of AUSA
email inbox, which included the search terms "Jane Doe,"
and
From that review, we identified no record of any additional interviews with
AUSAs asked
how many times she recalled being interviewed by the FBI in Florida.
indicated
that she could not recall whether she met with the Florida agents once or twice. AUSA
took notes
memorializing that statement.
AUSAs asked SA
how many times she recalled interviewing
could not
recall specifically whether
was interviewed any additional times after the August 7, 2007 interview.
indicated that follow-up interviews may not have been documented unless a witness made a new or
different statement during the interview(s). AUSAs
took notes memorializing that statement.
AUSA
emailed her contact who had facilitated SDNY's review of the SDFL Epstein file to ask whether SDFL is
aware of any additional interviews conducted with
AUSA
has not yet heard back.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00018757


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: JE estate meeting
Date: Fri, 20 Dec 2019 22:17:02 +0000
We're not yet exactly sure what our ability is to provide to the Trustees what is effectively discovery in a now-defunct
criminal case against Epstein himself; that said, I can convey that we did produce to defense counsel detailed search
warrant returns in connection with the New York property. Perhaps you would be able to obtain those from Epstein's
criminal defense counsel? In particular I believe what you're looking for would be especially at USAO_4381-4445, but
potentially also USAO_2662-4380 (though I note that a handful of those pages were marked as Confidential under a
protective order, as set forth in the discovery letter sent to counsel on July 31, 2019). We will also review the status of the
search warrant return with respect to the island property (and we have not searched the New Mexico property), and I
hope this is useful in the interim.
Separately, I've conveyed your request for a meeting to discuss the possibility of resolving the Government's potential
forfeiture claims, and I haven't yet gotten a response to relay but will let you know as soon as I do (and will also provide
these dates in connection with your request).
thanks,
Alex.
From:
Sent: Thursday, December 19, 2019 19:09
To:
Cc:
Subject: JE estate meeting
Alex:
To follow up on our call, can you please send us the search warrant returns/inventories and, if possible, any additional
detail regarding the items that were seized in the two searches of the New York property and the search of the New
Mexico property.
With respect to a next meeting with you and the Chief of the Criminal Division and, of course, any other colleagues you
wish to attend, the following dates in early January would be good for us:
January 3, 6 (before 2:00), 7, 8 (1:00 or later), 9 (after 11:00), or 10
Happy and Healthy New Year from Andy and me.
Partner
Co-Chair, White Collar Defense
Hughes Hubbard & Reed LLP
New York, NY 10004-1482
Office
Cell
Fax
EFTA00019904

=== Page 2 ===
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
EFTA00019905


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=== Page 1 ===
CFN 20200399066
OR BK 31849 PG 39
RECORDED 10/23/2020 09:56:41
Palm Beach County, Florida
AMT 200.00
DEED DOC 1.40
Sharon R. Bock
CLERK & COMPTROLLER
After Recording Return To:
Pgs 0039-0040; (2Pgs)
Love & Bliss Inc, Church Religious Corporation,
358 El Brillo Way, Palm Beach,
33480 Florida
This document prepared by:
John Mayer ESQ.
3110 Spring Glen Rd, Suite 303
Jacksonville, lot FL 32207
716-634-3419
Warranty Deed
This Warranty Deed made this 9th day of March, 2019, between Laurel Inc, a Florida Corporation whose post office address ST.
Thomas VI 00802 3501. grantor and Love & Bliss Inc, Church Religious Organization, a Florida, Not for Profit Corporation,
whose post office address, 358 El Brille Way, Palm Beach, 33480, Florida grantee:
(Whenever used herein the terms "grantor" and "grantee" include all the parties to this instrument and the heirs, legal representatives,
and assigns of individuals, and the success and assigns of corporations, trusts and trustees)
Witnesseth, that said, Grantor, for and in consideration of the sum of TWO HUNDRED DOLLARS AND 00/100 DOLLARS, (U.S
$200.00) and other good and valuable considerations to said grantor in hand paid by said grantee, the receipt whereof is hereby
acknowledged, has granted, bargained, and sold to the said grantee, and grantee's heirs, and assigns forever, the following described
land, situate, lying and being in the Palm Beach County I Florida, to-wit:
El BRAVO PK RPL L39 L, EL BRAVO PK RPL L40 L,
of the Public Records of Palm Beach County, Florida.
Parcel Identification Number: 50-43-43-27-06-000-0391
Together with all of the tenements, hereditaments and appurtenances thereto belonging or in anywise appertaining.
To have and to Hold, the same in fee simple forever.
And the grantor hereby covenants with said grantee that the grantor is lawfully seized of said land in fee simple; that the grantor has
good right and lawful authority to sell & convey said land; that the grantor hereby fully warrants the title to said land & will defend
the same against the lawful claims of all persons whomsoever; and that said land is free of all encumbrances, except taxes accruing
subsequent to December 31, 2018.
EFTA00019200

=== Page 2 ===
CFN 20200399066
BOOK 31849 PAGE 40
2 OF 2
In Witness Whereof, grantor has hereunto set grantor's hand and seal the day
and year first above written. signed, sealed and delivered in our presence:
Witness Just Printed Name
JODY Tutt
B JEFFREY EPSTEIN
GRANTOR:
&
Witness Printed Name Jerry Martinez
State of Florida
County of Palm Beach
The foregoing instrument was acknowledge before The by personal presence & presented Photo ID on this 9th day of March, 2019 by
Jeffrey E. Epstein, as president of Laurel Inc. a Florida Corporation, Jeffrey E. Epstein a single man, on behalf of the
company, he is personally known to me.
Ados
STATE
Natary Public
LIANAL JOHNSON
rint Name:
Commission # GG 977803
Expires June 10, 2022
My Commission Expires:
Bonded The Troy Fain Insurance 800-885-7019
EFTA00019201


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=== Page 1 ===
From:
To:
Subject: NYTimes: Prince Andrew Says He 'Let the Side Down' When He Stayed With Jeffrey Epstein
Date: Sat, 16 Nov 2019 14:34:10 +0000
Prince Andrew Says He 'Let the Side Down' When He Stayed With Jeffrey Epstein
https://www.nytimes.com/2019/11/15/world/europe/prince-andrew-interview-epstein.html?smid=nytcore-ios-
share
EFTA00017940


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=== Page 1 ===
From: Mariann Wang
To:
)"
Cc: Gloria Allred
Subject: Tomorrow's meeting
Date: Thu, 01 Apr 2021 14:53:20 +0000
Our client has requested that we cancel tomorrow's meeting. She has now had to recount her interactions with
Epstein one too many times, and since it's her understanding that it's unlikely that any of her information would
in fact materially advance your current prosecutions, she'd prefer to forego another interview.
Hope that's ok on your end, and of course let us know if you have any questions at all.
Mariann
EFTA00018021


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=== Page 1 ===
From: "Miller, Michael"
To:
)"
Cc:
)"
)"
"Weingarten, Reid"
"Martin G.
Weinberg" <owlmgw@att.net>, "Scavelli, Michael" <mscavelli@Steptoe.com>, "Meade,
Jason" <jmeade@Steptoe.com>
Subject: United States V. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.)
Date: Tue, 20 Aug 2019 15:41:50 +0000
Attachments: 8.20.19_Epstein_Letter_to_SDNY-c2.pdf; 8.20.19_Epstein_Letter_to_MCC-c2.pdf;
8.20.19_Epstein_Letter_to_FBI-c2.pdf
Please find attached correspondence for your attention. We intend to serve these requests separately on the MCC and
the FBI, but are providing you with copies of all three letters as a courtesy. If you are willing to accept service for all three,
we will not otherwise serve them.
Mike
Michael C. Miller
Partner
+1 212 506 3955 direct I +1 917 349 9129 mobile I +1 212 506 3950 fax
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.
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=== Page 1 ===
From: Sigrid McCawley <smccawley@bsfllp.com>
To:
)"
Subject: Shoppers Travel
Date: Fri, 22 Mar 2019 19:59:35 +0000
Attachments: 2016-04-26_Notice_of_Serving_Subpoena_(Shopper's_Travel).pdf
Hello
Per our conversation today - this is the Shopper's Travel Subpoena. My recollection is that the company hired lawyers
and raised a bunch of objections - we never got any docs. Hopefully you will have better luck!
Thanks,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
Fort Lauderdale, FL, 33301
www.bsfllp.com
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, 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
EFTA00019483


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=== Page 1 ===
From:
Subject: FW: Subpoena request
Date: Mon, 19 Aug 2019 15:54:43 +0000
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
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
EFTA00019324


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: fact witness travel request:
Date: Wed, 08 Sep 2021 20:36:13 +0000
Attachments:
_Fact_Witness_Travel_Request.docx
Hi
Attached is a request for this witness to travel to SDNY for trial prep later this month.
Thanks!
From:
Sent: Friday, August 6, 2021 2:49 PM
To:
Cc:
Subject: fact witness travel request:
Hi
Attached is a request for a witness to travel to SDNY for trial prep in the Maxwell case later this month. The meeting is on
the morning of August 20th, and the witness is hoping to fly up the day before hand and fly home the same day of our
meeting.
Thanks very much, and hope you have a nice weekend!
EFTA00017864


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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From: AUSA
Date: November 20, 2021
Re:
United States V. Ghislaine Maxwell
Court Docket No: 20 Cr. 330
USAO No: 2018R01618
Witness Name:
Witness DOB:
(Name/DOB as printed here will be forwarded to travel agency and then to TSA and must exactly
match the witness's driver's license or other travel ID or TSA will not permit the witness to fly.)
Witness Address:
Witness TelNos (mobile):
Witness e-mail:
Witness Needed to Appear in SDNY on
Date: 11/27/21
Time: 5 PM
Witness Needed to Appear for:
Trial ( )
Date: 11/27/21
Grand Jury ( )
Date:
Trial/GJ Prep (X)
Date:
Estimated Dates Witness will Arrive: 11/27/21
Depart: 12/2/21
Is the person a Fact Witness and not an Expert Witness?
(Yes/No):
Yes
Current Federal Civilian or Military Employee?
(Yes/No):
No
Is the Witness Facing Criminal Charges?
(Yes/No):
No
Does the Witness Reside Outside the Continental United States?
(Yes/No):
No
Is this Witness a Victim-Witness?
(Yes/No):
No
Hotel Required?
(Yes/No):
Yes
Has the Witness advised you of any unusual travel expenses?
(Yes/No):
No
Unusual expenses of fact witnesses can include
special travel arrangements
rev. 2019.11.19
EFTA00019452

=== Page 2 ===
care for dependent child or incapacitated family member left at home
kennel fees for pets
necessary travel companion
extra baggage (more than one bag)
Please describe the unusual expense:
For Victim-Witness Coordinator:
1. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW
is apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should
be used.
For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to
court/GJ testimony.
Witnesses may only be brought in under the FEWS appropriation for grand jury testimony that
has been scheduled and where the witness is expected to testify before the grand jury; court
testimony; or preparation for same. Any other witness travel, e.g., for investigative interviews,
must be covered by the investigating component from litigative funds. See Ed Tyrrell.
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
EFTA00019453


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=== Page 1 ===
From:
"
M. (NY) (FBI)"
To:
)"
)"
)"
Cc:
N. (NY) (FBI)"
Subject: Subpoenas Re
Date: Thu, 15 Aug 2019 21:07:45 +0000
Attachments:
Please prepare and return to me subpoenas for Wells Fargo, CITI, MoneyGram, Western Union and Experian
regarding
.
I have attached the riders for the subpoenas. I will serve the subpoenas.
Additionally, please utilize the following text in the subpoenas:
If you have any questions, please contact Forensic Accountant
or Special Agent
Please forward the results in an electronic format to Special Agent
Federal Bureau of
,
Investigation, 26 Federal Plaza, New York, NY 10278, telephone
,
If you have any questions or comments, please contact me.
Thanks
Forensic Accountant
FBI New York Field Office
26 Federal Plaza
NYC, NY 10278
Office:
EFTA00020166


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=== Page 1 ===
From:
Subject: Fwd: Epstein update
Date: Sat, 10 Aug 2019 15:31:36 +0000
Just FYI. Will let you know if we get any additional information. I'll be in the subway for the next half hour or
so but then at my desk today.
Sent from my iPhone
Begin forwarded message:
From:
Date: August 10, 2019 at 11:30:02 EDT
To:
Subject: Re: Epstein update
It is frankly unbelievable to me that BOP is issuing public press releases on this before telling us basic
information so that we can relay it to his attorneys who can relay it to his family. When can we expect to get
either some sort of statement we can pass along to counsel as accurate and reliable or have a call with
someone?
I understand from the Marshals that they have been unsuccessful in reaching anyone with authority at BOP, and
given the BOP press release that was just put out I assume we need to speak with someone there. Please
advise.
Thank you.
On Aug 10, 2019, at 10:43,
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,
EFTA00018964

=== 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
EFTA00018965


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)" <BWilliams8@usa.doj.gov>
Cc:
(USANYS)"
Subject: RE: Criminal Division update.
Date: Fri, 14 Feb 2020 15:49:37 +0000
Attachments: PC_Unit__Short_Form_Update.2.14.20v2.docx
Here is PC.
From:
USANYS)
Sent: Thursday, February 13, 2020 2:13 PM
To:
Subject: RE: Criminal Division update
Final reminder.
From:
USANYS)
Sent: Wednesday, February 12, 2020 2:11 PM
To:
Subject: RE: Criminal Division update
Another reminder.
From:
(USANYS)
Sent: Monday. February 10. 2020 12:08 PM
To:
EFTA00019883

=== Page 2 ===
Cc:
(USANYS)
Subject: RE: Criminal Division update
Reminder:
I know it's not August ©, but the report is due this Friday.
From:
USANYS)
Sent: Thursday, February 6, 2020 11:21 AM
To:
Cd
USANYS)
Subject: RE: Criminal Division update.
Ok everyone, let's get out of panic mode. The update is now due on Friday, August 14th. So, now you have
plenty of time. Sorry, for any inconvenience.
From:
(USANYS)
Sent: Thursday, February 6, 2020 10:15 AM
To:
Subject: Criminal Division update.
is due. Please e-mail them to me - Stephanie is out of the Office.
Thanks,
EFTA00019884


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=== Page 1 ===
From:
To:
Subject: Following Epstein's Arrest, Spotlight Shifts to Financier's Longtime Associate - WSJ
Date: Fri, 12 Jul 2019 01:09:06 +0000
Importance: Normal
https://www.wsj.com/articles/following-epsteins-arrest-spotlight-shifts-to-financiers-longtime-asociate-
11562881299
Sent from my iPhone
EFTA00018177


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: Read: US V. Epstein
Date: Thu, 25 Mar 2021 19:29:02 +0000
EFTA00019041


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
December 16, 2020
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
In recognition of the Government's ongoing discovery obligations, today we are producing
the materials listed in the below index. These discovery materials are stamped with control
numbers SDNY_GM_00274187 through SDNY_GM_0274303.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case.¹ This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. An index of the materials contained in this production is below:
1 Files in PDF format designated as "confidential" under the protective order have been stamped
"confidential." However, certain files cannot be individually labeled as confidential on the
documents themselves due to their file format.
06.20.2018
EFTA00019420

=== Page 2 ===
Page 2
Bates Start
Bates End
Summary Description
Confidential
Designation
UBS Subpoena Return, 12-15-2020
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not
hesitate to reach out if you have any difficulty accessing these materials or if you wish to
arrange a time to review physical items in the FBI's custody.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
06.20.2018
EFTA00019421


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 29, 2020
BY FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the CD containing discovery materials pertinent to Ghislaine Maxwell
(02879-509) is
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
EFTA00018260


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=== Page 1 ===
From:
To: "Kathleen E. Cassidy"
Cc: Samidh Guha
Susan Necheles
Subject: Re: Section 1512
Date: Mon, 09 Nov 2020 15:01:52 +0000
Great, thanks. Talk to you then- we can use this line:
Sent from my iPhone
On Nov 9, 2020, at 9:58 AM, Kathleen E. Cassidy
wrote:
Yes, that is fine. Thanks,
Kate
From:
Sent: Monday, November 9, 2020 9:57 AM
To: Kathleen E. Cassidy
Cc: Samidh Guha
; Susan Necheles
;
Subject: Re: Section 1512
Hi Kate,
Would Wednesday at 12:30 p.m. work?
Thanks,
Sent from my iPhone
On Nov 9, 2020, at 8:43 AM, Kathleen E. Cassidy
wrote:
Hi all, I apologize but can we move our call to Wednesday? We can be available at your convenience. Thanks, Kate
Sent from my iPhone
On Nov 5, 2020, at 5:22 PM,
wrote:
Thanks very much. We are free anytime from 3 pm onwards on Monday, is there a time that works best for you?
Sent from my iPhone
On Nov 5, 2020, at 5:17 PM, Kathleen E. Cassidy
wrote:
Hi
EFTA00019119

=== Page 2 ===
We thought it would be useful to schedule a call for Monday. Is there a time that would work for you all?
Best,
Kate
From:
Sent: Thursday, November 5, 2020 11:35 AM
To: Kathleen E. Cassidy
; Samidh Guha
Susan Necheles
Subject: RE: Section 1512
Hi all,
Hope everyone is doing well. I'm checking in to see if you have any updates on timing for next steps. As always,
please let us know if it would be useful to schedule a call.
Thanks,
From: Kathleen E. Cassidy
Sent: Wednesday, October 28, 2020 3:50 PM
To:
Samidh Guha
; Susan Necheles
Cc:
Subject: RE: Section 1512
Hi all,
We are working on drafting something up and will get back to you by early next week.
Thanks,
Kate
From:
Sent: Monday, October 26, 2020 1:03 PM
To: Kathleen E. Cassidy
Samidh Guha
Susan Necheles
Subject: RE: Section 1512
All,
and I wanted to follow up to ask if a call would be useful to check in - we recognize you will
likely need more time to evaluate this, but it would be helpful to discuss where we are. Are you available for a call
this week?
Thanks,
From:
Sent: Monday, October 19, 2020 6:57 PM
EFTA00019120

=== Page 3 ===
To: Kathleen E. Cassidy
; Samidh Guha
; Susan Necheles
Cc:
Subject: RE: Section 1512
All,
Following up on our discussions, we wanted to send you a preliminary statement of facts, so that we can discuss
whether there might be room for agreement. Whenever you're ready to discuss, please let us know when you'd
like to schedule a call.
Please note that the language below isn't final from our perspective - we're happy to discuss any issues you see
with the statement, and it's possible there might be modifications on our end as well. However, we wanted to have
a starting point so that we could have more concrete discussions with you about whether a resolution is possible
here.
As we've discussed, this isn't a plea offer, and we don't intend to issue a plea offer before notifying and consulting
with victims.
Thanks,
EFTA00019121

=== Page 4 ===
From: Kathleen E. Cassidy
Sent: Wednesday, September 23, 2020 12:51 PM
To:
Cc: Samidh Guha
Susan Necheles
Subject: Re: Section 1512
We can use this dial in for 4:30.
Talk to you then.
Sent from my iPhone
On Sep 23, 2020, at 9:59 AM,
wrote:
Hi Kate,
Just following up to confirm that we are scheduled to talk today at 4:30 p.m. If that time no longer works for you,
please let us know.
Thanks,
Sent from my iPhone
On Sep 22, 2020, at 8:57 AM,
wrote:
Hi Kate,
EFTA00019122

=== Page 5 ===
That works for us, thanks. Could you please send us a conference line?
Thanks,
Sent from my iPhone
On Sep 21, 2020, at 9:48 PM, Kathleen E. Cassidy
wrote:
Hi
Would 4:30 on Wednesday work for you all?
Thanks,
Kate
From:
Sent: Friday, September 18, 2020 11:15 AM
To: Kathleen E. Cassidy
Cc: Samidh Guha
Susan Necheles
(USANYS)
Subject: Re: Section 1512
Hi Kate,
Thanks very much. We are free for a call on Wednesday at 3 p.m. or later. Would that work for you?
Thanks,
Sent from my iPhone
On Sep 18, 2020, at 9:54 AM, Kathleen E. Cassidy
wrote:
Hi
Yes, thank you for your email. Can we schedule a call for mid-week next week? What works for you guys?
Thanks,
Kate
From:
Sent: Thursday, September 17, 2020 12:49 PM
To: Samidh Guha
Kathleen E. Cassidy
; Susan Necheles
Subject: RE: Section 1512
Hi all,
I'm following up on my email below to confirm that you've received it. If you have any questions, please let
us know. We are available for a call next week if you're ready to discuss further.
Thanks,
EFTA00019123

=== Page 6 ===
From:
Sent: Friday, September 11, 2020 12:21 PM
To: 'Samidh Guha'
'Kathleen E. Cassidy'
; 'Susan
Necheles'
Subject: RE: Section 1512
All,
Following up on your questions about 18 U.S.C. § 1510, we wanted to let you know that it is our
understanding that Section 1510 requires proof that the defendant knew the relevant law enforcement
official was in fact a federal law enforcement official. See United States V. Escalera, 957 F.3d 122, 131 n.11
(2d Cir. 2020) (citing United States V. Grande, 620 F.2d 1026, 1036-37 (4th Cir. 1980) ("We read this legislative
history to articulate a congressional intention that one may be found to have violated § 1510 only upon
proof beyond a reasonable doubt, inter alia, that the person who was intimidated, threatened, or harmed
was about to communicate information to another known by the accused to be a federal criminal
investigator.")). By contrast, as we have discussed, Section 1512(b)(3) has no such requirement. If you have a
different view of that issue or if there are any authorities you would like us to review, we'd be happy to look
more closely at the issue.
Please let us know if you have any questions, or if a call would be useful to discuss.
Thanks,
From:
Sent: Thursday, September 3, 2020 12:46 PM
To: Samidh Guha
Kathleen E. Cassidy
>; Susan
Necheles
Subject: Section 1512
Hi all,
Following up on our conversation last week, we wanted to send you two cases that we believe bear directly
on the question you raised regarding Section 1512(b)(3). We're happy to discuss further when we speak
tomorrow, but we wanted to send these to you in advance in case that's useful.
Thanks,
EFTA00019124

=== Page 7 ===
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=== Page 1 ===
1
j7v2espC kjc
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
2
X
3
UNITED STATES OF AMERICA,
New York, N.Y.
4
V.
19 Cr. 490 (RMB)
5
JEFFREY EPSTEIN,
6
Defendant.
7
X
Conference
8
July 31, 2019
11:05 a.m.
9
10
Before:
11
HON. RICHARD M. BERMAN,
12
District Judge
13
14
APPEARANCES
15
GEOFFREY S. BERMAN
16
United States Attorney for the
Southern District of New York
17
BY:
18
Assistant United States Attorneys
19
20
MARTIN G. WEINBERG
Attorney for Defendant
21
22
STEPTOE & JOHNSON, LLP
Attorneys for Defendant
23
BY: MICHAEL C. MILLER
24
25
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
EFTA00020203

=== Page 2 ===
2
j7v2espC kjc
1
THE COURT: So, today's conference was scheduled at
2
the end of the July 18 court conference hearing on that date.
3
I thought that we would devote at least the -- well, probably
4
most of today's proceeding to talking about the schedule in
5
this case, and I asked the lawyers to get together and see if
6
they could come up with a mutually agreeable schedule, which
7
would include trial date, motion practice, discovery, etc.
8
Does anybody want to let me know how you made out?
9
MS.
: Yes, your Honor.
10
We have conferred with defense counsel and talked
11
about a proposed schedule for this case. So we are prepared to
12
propose to the court today a schedule for discovery, for
13
discovery-related motions, for pretrial motions, and we are
14
also prepared to talk about setting a possible trial date.
15
THE COURT: Okay. What have you got in mind?
16
MS.
: So, with respect to discovery, we would
17
propose a discovery deadline of October 31 to complete
18
discovery, with one exception. There are materials from
19
devices seized from the defendant's residence in New York, and
20
the F.B.I. is beginning the process of reviewing that data.
21
In discussing that with defense counsel, we have begun
22
to discuss a process for a privilege-review protocol. It's
23
possible that process may take longer than October 31. But
24
aside from that universe of documents, we would propose setting
25
a schedule of October 31 as a deadline for discovery.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
EFTA00020204

=== Page 3 ===
3
j7v2espC kjc
1
For discovery-related motions, we would propose that
2
the defense file any motions that they are aware of relating to
3
discovery, to include motions relating to the nonprosecution
4
agreement, by September 13 --
5
THE COURT: By when?
6
MS.
:
September 13, your Honor.
7
--- that the government be permitted to respond by
8
October 4; with any reply due on October 11, as necessary.
9
Of course we understand that if the defense comes to
10
have additional motions related to discovery based on the
11
ongoing discovery process that we will confer and propose an
12
additional briefing schedule beyond that, as necessary. But
13
with respect to motions that the defense is already aware of,
14
including the NPA, that is the schedule that we would propose
15
at this time.
16
Regarding pretrial motions, your Honor, we would
17
propose that the defense file their motions by January 10, that
18
the government be permitted to respond by February 10, and that
19
any replies be due on or before February 24.
20
THE COURT: Got it.
21
MS.
: And finally, your Honor, we are prepared to
22
discuss a trial date in this case. The government is asking
23
the court to set a trial date in this matter. We would propose
24
that the court schedule this matter for trial in June of next
25
year, and we estimate that the trial would take approximately
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 4 ===
4
j7v2espC kjc
1
four to six weeks, and so that trial date would carry into
2
July. And I understand that the defense has some comments
3
about that proposal, but that's the government's proposal with
4
respect to a trial date.
5
THE COURT: Okay. Let me hear from the defense.
6
Do I understand it correctly that, with the exception
7
of the trial date, those dates are agreeable?
8
MR. WEINBERG: Those dates are agreeable, your Honor.
9
THE COURT: Counsel, whatever you wish to add, that
10
would be fine.
11
MR. WEINBERG: We would ask the court to set a
12
preliminary trial date immediately after Labor Day. I say
13
preliminary because we want time to assess Mr. Epstein's --
14
THE COURT: This year?
15
MR. WEINBERG: Yes.
16
THE COURT: This Labor Day. Okay.
17
MR. WEINBERG: We want time to assess Mr. Epstein's
18
ability to
19
(Counsel confer)
20
MR. WEINBERG: I'm sorry. I am being told that your
21
Honor was inquiring as to the year. Let me --
22
THE COURT: Yes. I thought you wanted a speedy trial,
23
and so --
24
MR. WEINBERG: Not with a four- to six-week trial with
25
discovery coming in October, Judge. I apologize for being
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
EFTA00020206

=== Page 5 ===
5
j7v2espC kjc
1
imprecise. Labor Day 2020 or immediately thereafter. And I
2
make that recommendation -- we haven't received the discovery
3
yet. Understandably, it is coming, and I'm not in any way
4
contesting that there has been a delay, but we haven't had an
5
opportunity to start reviewing what the government has
6
predicted to be over a million pages of discovery with
7
Mr. Epstein and to assess Mr. Epstein's ability to exercise his
8
constitutional right, while at MCC, in assisting counsel
9
prepare for a very difficult case that addresses events that it
10
is alleged occurred 14 to 17 years ago.
11
THE COURT: Okay.
12
MR. WEINBERG: So, we need time to receive a million
13
pages of discovery and to prepare to defend a four- to six-week
14
trial, when a lot of the immediate attention is going to be on
15
the very unique and complex constitutional issues connected to
16
the nonprosecution agreement, our contention that the
17
government's allegations are inextricably intertwined and
18
constitutionally barred by the NPA. There are double jeopardy
19
issues both connected to the conspiracy count, which looks to
20
be an overlap with one of the charges that was expressly within
21
the immunity provisions in the NPA. We are going to be
22
spending a lot of time, and that's why I agreed with the
23
government that we should make early discovery motions on the
24
NPA-related issues, on double-jeopardy-related issues, so that
25
we could not only facially brief the motion to dismiss, but
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
EFTA00020207

=== Page 6 ===
6
j7v2espC kjc
1
have the discovery, the subfacial discovery, if you will, so
2
that we could make a comprehensive briefing along the lines of
3
the schedule for motions.
4
THE COURT: That's what I was going to suggest, if
5
there is a time period when you could put it all together, as
6
it were, and there is a lot of flexibility. So I will leave
7
these dates, you know, for now.
8
With respect to the trial date, I could accommodate
9
either June or September of 2020. The issue is not so much as,
10
from my point of view, when you are all ready, but what part of
11
the calendar I block out. So is it realistic to block out time
12
in June?
13
MR. WEINBERG: I think it is -- I don't want to have
14
the court block out a six-week time and then come to the court
15
in March and say we need a continuance and risk a September
16
date.
17
THE COURT: Got it. Okay. So a September date, you
18
are saying, sounds like it certainly is realistic.
19
MR. WEINBERG: Thirteen months sounds like the amount
20
of time that we would ordinarily need to prepare a case of this
21
magnitude and scope.
22
THE COURT: All right. That is fine for me.
23
Just while we are taking care of details, a speedy
24
trial issue or application? Why don't we extend it to
25
September of 2020?
SOUTHERN DISTRICT REPORTERS, P.C.
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EFTA00020208

=== Page 7 ===
7
j7v2espC kjc
1
MR. WEINBERG: This case certainly meets all of the
2
statutory criteria for complexity and we would agree to that
3
extension, Judge.
4
MS.
:
Your Honor, may I briefly be heard with
5
respect to the trial date?
6
THE COURT: Oh, sure. You know, it does sound like it
7
is kind of premature, but I'm happy to hear you. It is often
8
the defense that is ahead of the government, or not often, but
9
equally, but here it is the other way around. So if the
10
defense is not ready, it would be my practice to defer to the
11
defense, but I don't know that it is fixed in stone either way.
12
But, sure, I am happy to hear you.
13
MS.
:
Your Honor, by way of background, we had
14
initially proposed to the defense a May trial date. We think
15
that there is a public interest in bringing this case to trial
16
as swiftly as manageable. We understand, given their concerns
17
in wanting to have more time, we proposed a date in June as a
18
compromise position. We understand if the defense has
19
indicated that they need additional time. We are sensitive to
20
those concerns. But we do have a concern about the notion of
21
setting a September trial date and that that trial would be
22
preliminary or as a placeholder. Thirteen months is a
23
considerable amount of time for a case of this nature to go to
24
trial; and, again, given the time period of the charged conduct
25
and the length of time that's passed, we do think that there is
SOUTHERN DISTRICT REPORTERS, P.C.
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EFTA00020209

=== Page 8 ===
8
j7v2espC kjc
1
a public interest in scheduling a fixed trial date in this
2
case. Of course we understand if issues arise in the interim,
3
we will address that as it occurs, but we do think it makes
4
sense at this juncture to set a firm trial date. We don't
5
think that any delay in this case is in the public interest.
6
THE COURT: Counsel.
7
MR. WEINBERG: We think that the delay in bringing
8
this charge, your Honor, the natural corollary of that is to
9
make it more difficult, not easier, for us to defend
10
Mr. Epstein. For instance, there are certain sealed files for
11
potential witnesses that we would have to go to other courts to
12
seek to unseal. There is an NPA to litigate. This case is not
13
your ordinary 1591 case. A case of four to six weeks is not
14
the ordinary amount of time the government takes to prosecute,
15
whether it is old or new cases. We need 13 months. I'm trying
16
to make a principled argument, Judge, that that would be a
17
schedule that we would try our best to meet, conditioned on our
18
ability to work with Mr. Epstein under the current conditions.
19
Thank you, sir.
20
THE COURT: Okay.
21
So, we are going to monitor the case from now until
22
then anyway, so I think everybody will be in a better position
23
to know what is realistic with respect to a trial date. I will
24
exclude time from today through, let's say, June 8, but that,
25
of course, is without prejudice to hearing from the defense and
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
EFTA00020210

=== Page 9 ===
9
j7v2espC kjc
1
the government as to actually where things stand. Long before
2
then we will know. So we will have a conference, or several,
3
between now and then. Let's see where everybody is as the
4
months go by, and then we will know when we can effectively
5
hold the trial.
6
So I am going to find, under 18 United States Code $
7
3161, that the request for adjournment, joined in by both
8
sides, is appropriate and warrants exclusion of the adjourned
9
time from Speedy Trial calculations. I further find that the
10
exclusion is designed to prevent any possible miscarriage of
11
justice, to facilitate these proceedings, including extensive
12
pretrial preparation, and to guarantee effective representation
13
of and preparation by counsel for both sides, and thus the need
14
for exclusion and the ends of justice outweigh the interests of
15
the public and the defendant in a speedy trial pursuant to 18
16
United States Code § 3161 (h) (7) (A) and (B). So that exclusion
17
goes to June 8, 2020 preliminarily.
18
Counsel, is it your thought that these motions would
19
be on submission or did you want to have oral argument with
20
respect to any aspect of them?
21
MR. WEINBERG: We would seek oral argument, your
22
Honor.
23
THE COURT: So let's set October 28, 2019 for oral
24
argument, and I am tentatively reserving some time on my
25
calendar, as I said before, on June 8, 2020, but I will have a
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
EFTA00020211

=== Page 10 ===
10
j7v2espC kjc
1
much better feel for where things are long before that and
2
certainly I would say on October 28 we would have a much
3
clearer picture of how things stand.
4
So there you have it. Did you have -- go ahead.
5
MS.
: Just to clarify, your Honor, what time would
6
the court like the parties to appear on October 28?
7
THE COURT: 10 a.m.
8
MS.
: Thank you, your Honor.
9
THE COURT: And the June 8 date is 9 a.m. Okay?
10
MR. WEINBERG: Would your Honor want to schedule an
11
argument on the substantive motions that will be fully briefed
12
before the court on February 24?
13
THE COURT: Yup.
14
So let's schedule that oral argument for March 12,
15
2020, at 10 a.m.
16
Great. So anything anybody else has to talk about?
17
MR. WEINBERG: Not from the defense, your Honor.
18
MS.
: Not from the government, your Honor. Thank
19
you.
20
THE COURT: Okay.
21
MR. WEINBERG: Thank you very much, sir.
22
THE COURT: Nice to see you all.
23
o0o
24
25
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
EFTA00020212


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=== Page 1 ===
From: "Moyne, Parvin"
To:
)"
Cc: "Moyer, Thomas"
)"
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Date: Thu, 22 Aug 2019 16:01:30 +0000
Sounds good.
We made another production last night. If it is helpful for us to run through that with you before the proffer, let us know
and we can jump on a call.
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
From:
Sent: Wednesday, August 21, 2019 11:29 PM
To: Moyne, Parvin
Cc: Moyer, Thomas
V.
V.
)
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
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
i
is
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:
EFTA00020114

=== Page 2 ===
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
>;
>;
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
From:
Sent: Tuesday, August 20, 2019 11:58 PM
To: Moyne, Parvin
Cc: Moyer, Thomas
>;
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
is
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 relationship with the bank, the different accounts affiliated with
Epstein and the types of transactions found in the accounts. We would also highlight various transactions that we have
EFTA00020115

=== Page 3 ===
noted in our internal investigation. Our aim is that the attorney proffer would help you in sifting through the records we
have provided so you can more readily identify whatever information you are most interested in. Following the proffer,
if there are particular accounts or transactions of interest, we can identify the person within DB who can best answer
questions on those areas and that person would then meet with you.
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,
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:
>;
)
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
)
EFTA00020116

=== Page 4 ===
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
&
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-
EFTA00020117

=== Page 5 ===
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.
EFTA00020118


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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein Team Meeting
Date: Sun, 08 Dec 2019 19:10:23 +0000
Importance: Normal
Attachments: unnamed
EFTA00018918


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=== Page 1 ===
From:
To:
Subject: RE: Expert Testimony
Date: Mon, 02 Nov 2020 18:08:07 +0000
Good for me too, thanks.
From
Sent: Monday, November 2, 2020 1:04 PM
To:
Subject: RE: Expert Testimony
Good for me, thanks
From:
Sent: Monday November 02 2020 12:09 PM
To:
Subject: Fwd: Expert Testimony
2 work for you on Wednesday?
Sent from my iPhone
Begin forwarded message:
From: Dawn Hughes
Date: November 2, 2020 at 10:53:58 AM EST
To:
Cc:
Subject: Re: Expert Testimony
Yes. I would be happy to speak with you all. I have some open time on Wednesday after 2:00. Let
me know what works for you.
Best,
Dr. Hughes
DAWN M HUGHES, PHD ABPP
CLINICAL AND FORENSIC PSYCHOLOGIST
EFTA00018082

=== Page 2 ===
On Thu, Oct 29, 2020 at 3:48 PM
wrote:
Dr. Hughes,
Together with colleagues,
and
I'm one of the federal prosecutors handling
the case of United States V. Ghislaine Maxwell, which is scheduled to go to trial on July 12, 2021 in the
Southern District of New York. We would be interested in speaking with you about your availability to
testify as an expert witness at trial. Are you available for a call tomorrow or next week to discuss?
Thanks verv much.
EFTA00018083


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=== Page 1 ===
From:
Jo" </O=FBI/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=AGCJPRYO>
To: "Adele Thonn" <athonn@jeffersoncompanies.com>
Subject: RE: Conference Information
Date: Wed, 20 Apr 2011 15:21:50 +0000
Importance: Normal
Inline-Images: image001.jpg
Adele,
Thanks again for looking through your records and helping with this.
After finding information about your conference online, it seemed to be the type of event/conference that I was looking
for, but I knew that it could be a shot in the dark.
The convention and visitors bureau will be my next call.
Thank you again.
Regards,
SA
FBI Miami Division
505 Flagler Dr. Ste. 500
West Palm Beach, FL 33401
(561) 833-7517
(561) 650-6951 fax
From: Adele Thonn [mailto:athonn@jeffersoncompanies.com]
Sent: Wednesday, April 20, 2011 11:16 AM
To:
Jo
Subject: Re: Conference Information
Good morning,
I wanted to follow-up with you to let you know that we have not been able to find any
information on the two individuals below.
I will tell you that the convention business in New Orleans is very busy. Our event is held here every year, but is
very small in comparison to many other meetings and conventions that are held here on a non-regular basis. If
there's a possibility that they could have attended another event that was in the city, you may want to contact the
New Orleans Convention & Visitors Bureau (www.neworleanscvb.com) to see what other events may have
occurred during that time. I do not know how far their records go back, but having worked in hotels in the city, I
know that they publish lists to its members of meetings taking place in the city.
Sorry we couldn't be of more help.
Adele
On Apr 14, 2011, at 3:00 PM,
Jo wrote:
EFTA00019165

=== Page 2 ===
Good afternoon,
After calling 1-800-648-8411 for general conference information, the young lady there suggested that I email you as the
conference coordinator.
I am a special agent with the Miami Division/West Palm Beach Office of the FBI. The phone number below, 561-833-7517,
is the main office number in West Palm Beach, and Miami's office number is 305-944-9101. (The switchboard operators at
either number can verify my identity.)
I am trying to locate the financial and /or investment conference that two individuals attended in New Orleans between
approximately 1998-2000 and what hotels your conference would have used during those time periods. I believe your
conference may be the one I am looking for.
I am trying to determine if the following two individuals attended the New Orleans Investment Conference between 1998-
2000;
1. Jeffrey Epstein
2.
Any information or assistance you could provide would be greatly appreciated.
Thank you,
SA
FBI Miami Division
505 Flagler Dr. Ste. 500
West Palm Beach, FL 33401
(561) 833-7517
(561) 650-6951 fax
Adele A. Thonn
Conference Director
Jefferson Financial, Inc.
111 Veterans Boulevard, Suite 1555
Metairie, LA 70005
Direct Phone: (504) 832-3278
Main Phone: (504) 837-3033
Fax: (504) 837-4885
E-mail: athonn@jeffersoncompanies.com
Conference website: www.neworleansconference.com
Find us on
f
Facebook
Click here for New Orleans Investment Conference Facebook Page
EFTA00019166


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 16, 2019
MoneyGram International, Inc.
Attn: Global Subpoena Processing
1550 Utica Avenue South
MS: MBC-5508
Minneapolis, MN 55416
subpoena@moneygram.com
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
By:
Assistant United States Attorney
Southern District of New York
EFTA00019976

=== Page 2 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
MoneyGram International, Inc.
Attn: Global Subpoena Processing
1550 Utica Avenue South
MS: MBC-5508
Minneapolis, MN 55416
subpoena@moneygram.com
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the GRAND JURY of the people of the United States for the Southern District of New York, at
the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New
York, New York, in the Southern District of New York, at the following date, time and place:
Appearance Date:
August 30, 2019
Appearance Time: 10 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 Forensic Accountant
at
or Special Agent
at
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
August 16, 2019
Gilby
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
UNITED COURT
FOR
Assistant United States Attorney
THE
RICT
YORK
One St. Andrew's Plaza
New York, New York 10007
Telephone: 212-637-2324
EFTA00019977

=== Page 3 ===
RIDER
(Grand Jury Subpoena to MoneyGram, dated August 16, 2019)
Please provide any and all available information regarding money transfers and 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, and
the amount and currency distributed) for the following identifiers:
NAMES/ENTITIES
DOB
SSN
ADDRESS
PHONE
EMAIL
ACCOUNT NUMBERS:
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
n
; 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
at
or Special Agent
at
with any questions.
3
EFTA00019978

=== Page 4 ===
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
EFTA00019979

=== 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 August 16, 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.
EFTA00019980


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=== Page 1 ===
STATE
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
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)
The password for the drive containing witness materials pertinent to Ghislaine Maxwell
(02879-509) is
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
/s
Assistant United States Attorneys
EFTA00018891


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=== Page 1 ===
From:
To:
Subject: RE: NYU Law Interns -- Fall Semester
Date: Mon, 29 Jul 2019 15:18:19 +0000
Hi
and
I'd be interested in working with an intern this fall. Full disclosure, I think my workload in the fall will be mostly Epstein-
related, and I don't have any trials or hearings scheduled, so I'm not sure it would be a very diverse experience.
From:
Sent: Monday, July 29, 2019 10:31 AM
To: USANYS-Attorneys-Criminal
Cc:
Subject: NYU Law Interns -- Fall Semester
Please let us know if you would be interested in working with an NYU Law School intern in the Fall semester (September
3-December 3). Please also let us know if you (1) have any trials or hearings scheduled during that time, or (2) asked for,
but didn't get, an intern last Spring.
Thanks,
&
EFTA00018395


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=== Page 1 ===
From:
(USANYS)"
To:
Cc:
)"
Subject: Maxwell - Proposed Voir Dire and Jury Questionnaire
Date: Tue, 05 Oct 2021 03:37:17 +0000
Attachments: 021.10.04_Maxwell_Jury_Questionnaire_[Sent_to_Defense].docx;
2021.10.04_Proposed_Voir_Dire_[Sent_to_Defense].docx
Counsel,
Our proposed joint voir dire and jury questionnaire are due on October 11. Please find attached our draft proposals. If
you have disagreements/proposed changes, please note them in track changes. Please send these back to us by COB
October 7 so that we have time to review before submitting to the Court.
Thank you,
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:
EFTA00018840


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=== Page 1 ===
From:
)"
To: "Weinstein, Marc A."
Andrew Tomback
,
Cc:
)"
)"
Subject: RE: SDNY investigation
Date: Sun, 26 Jul 2020 18:51:10 +0000
Attachments: 2020-07-26,_JE,_letter_to_trustees_counsel.pdf
Andy, Marc,
Following up on our recent discussions, please see the attached letter from our Office.
Regards,
Assistant U.S. Attorney
Southern District of New York
EFTA00020320


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=== Page 1 ===
From:
</O=FBI/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=AGCJPRYO>
To: "athonn@jeffersoncompanies.com" <athonn@jeffersoncompanies.com>
Subject: Conference Information
Date: Thu, 14 Apr 2011 20:00:35 +0000
Importance: Normal
Good afternoon,
After calling 1-800-648-8411 for general conference information, the young lady there suggested that I email you as the
conference coordinator.
I am a special agent with the Miami Division/West Palm Beach Office of the FBI. The phone number below, 561-833-7517,
is the main office number in West Palm Beach, and Miami's office number is 305-944-9101. (The switchboard operators at
either number can verify my identity.)
I am trying to locate the financial and /or investment conference that two individuals attended in New Orleans between
approximately 1998-2000 and what hotels your conference would have used during those time periods. I believe your
conference may be the one I am looking for.
I am trying to determine if the following two individuals attended the New Orleans Investment Conference between 1998-
2000;
1. Jeffrey Epstein
2.
Any information or assistance you could provide would be greatly appreciated.
Thank you,
SA
J.
FBI Miami Division
505 Flagler Dr. Ste. 500
West Palm Beach, FL 33401
(561) 833-7517
(561) 650-6951 fax
EFTA00019162


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Ghislaine Maxwell (02879-509)
Date: Mon, 02 Nov 2020 16:21:39 +0000
Thanks
Not surprising but still frustrating that all this nothingness led to an urgent Sunday evening email.
From:
Sent: Monday, November 2, 2020 11:07 AM
To:
Cc:
Subject: RE: Ghislaine Maxwell (02879-509)
Just got the following update from
(which I have conveyed to
Within the last approximately 48 hours, MDC staff has conducted temperature checks in Ms. Maxwell's cell, all of
which revealed that the temperature in Ms. Maxwell's cell was between 71 and 74 degrees. MDC legal counsel
noted that the target temperature for the MDC during this season is 68 degrees. MDC staff also gave Ms. Maxwell
an extra blanket, so she now has three blankets in her isolation cell.
MDC staff physically entered Ms. Maxwell's cell and did not observe any smell or moisture. The unit team leader
physically felt the papers in Ms. Maxwell's cell and observed that they felt normal and in no way damaged by
moisture.
MDC staff will ensure that Ms. Maxwell is able to bring a cup and a snack with her into her isolation cell.
From:
Sent: Sunday, November 1, 2020 1:20 PM
To:
Cc:
Subject: Re: Ghislaine Maxwell (02879-509)
Okay, thanks for the heads up. Please let us know what you learn back from
Sent from my iPhone
On Nov 1, 2020, at 1:06 PM,
wrote:
Chiefs,
FYI, we just received the below from Maxwell's counsel. I've forwarded to
and asked her to call me
ASAP to discuss. Wanted to let you know in case this turns into another letter to AJN.
Thanks,
From:
Sent: Sunday, November 1, 2020 12:41 PM
To:
Cc:
Subject: Ghislaine Maxwell (02879-509)
Good afternoon-
I write to request immediate assistance for Ghislaine Maxwell.
There are many conditions and restrictions placed upon her at the MDC
that are of great complaint, but of immediate concern are conditions within
Ms. Maxwell's isolation cell.
EFTA00018085

=== Page 2 ===
The combination of cold, moisture, and sewage stench have made confinement
in her cell unhealthy, unbearable, and utterly unreasonable.
Her request for an extra blanket has been denied.
Her request for use of her day mug for water has been denied.
(She's been told to cup her hands to drink water from the faucet.)
Her request to keep a snack in her cell has been denied.
The moisture accumulating in her cell risks her health and the security
of her legal work.
You have known me and my reputation among your colleagues and the court.
Trust me when I way that in my 35 years of federal criminal practice, having represented
individuals charged and convicted of terrorism and capital murder, housed in
MCC's 10South and FCI Florence-ADMAX (facilities I have visited), I have never witnessed
such inappropriate and outlandish treatment of a non-violent pretrial detainee held on risk of flight.
The mistreatment of Ghislaine Maxwell reflects negatively on your Office, the Court,
and the BOP. The Government as a whole can and needs to do better.
For today, we seek the bare minimum - a change of cell to a location that is safe
from the cold, moisture, and stench, and an extra blanket to keep her warm.
The rest will be left for another day.
Please assist.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
**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.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
EFTA00018086


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
,
)"
Subject: Daubert motion
Date: Mon, 08 Nov 2021 00:59:53 +0000
Attachments: Motion_to_preclude_Dietz_and_Loftus_v4.docx
Hi team,
In the interest of expediency, here is the Daubert motion for your comments. I still need to write my section, and I'm
doing some significant revisions to the Loftus section, but the Dietz section is done
crushed it. That's the bulk of
the motion, so feel free to read that over, and I'll send you the rest in a second round later.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00018896


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 16, 2019
Citibank N.A.
Legal Services Intake Unit
701 East 60th Street North
Sioux Falls, SD 57117
Fax: 347-809-6937
Attention: Legal Intake Unit
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
By:
Assistant United States Attorney
Southern District of New York
EFTA00019971

=== Page 2 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Citibank N.A.
Legal Services Intake Unit
701 East 60th Street North
Sioux Falls, SD 57117
Attention: Legal Intake Unit
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the GRAND JURY of the people of the United States for the Southern District of New York, at
the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New
York, New York, in the Southern District of New York, at the following date, time and place:
Appearance Date:
August 30, 2019
Appearance Time: 10 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 Forensic Accountant
at
or Special Agent
at
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
August 16, 2019
Gilby
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
UNITED COURT
FOR
Assistant United States Attorney
THE
YORK
One St. Andrew's Plaza
New York, New York 10007
Telephone:
EFTA00019972

=== Page 3 ===
RIDER
(Grand Jury Subpoena to Citibank, dated August 16, 2019)
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, to include all open and closed accounts.
Please provide all images of documents in Adobe PDF files on CDs.
A. Please use the following identifiers:
NAMES/ENTITIES
DOB
SSN
ADDRESS
PHONE
EMAIL
ACCOUNT NUMBERS:
B. Records to be produced should include but are not limited to the items listed below:
1. Data transaction files
2. 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;
3. Signature cards;
4. Proof of identification (including but not limited to copies of identification used to open the
account);
3
EFTA00019973

=== 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; and Customer's email address
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. 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;
16. Any and all corporate resolutions, certifications of incorporation, business certificates and/or
partnership agreements; 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
at
or Special Agent
at
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
EFTA00019974

=== 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 August 16, 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.
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
March 26, 2021
Interlochen Center for the Arts
4000 Highway M-137
Interlochen, MI 49643
Attn: Jeffrey Jocks, Esq.
jjocks@sondeeracine.com
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.
If you intend to disclose the existence of this Grand Jury Subpoena request to a third party,
please let me know before making any such disclosure.
Thank you for your cooperation in this matter.
Very truly yours,
Audrey Strauss
United States Attorney
By:
alison G. me
Assistant United States Attorney
Southern District of New York
(212) 637-2225
EFTA00019503

=== Page 2 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Interlochen Center for the Arts
4000 Highway M-137
Interlochen, MI 49643
Attn: Jeffrey Jocks, Esq.
jjocks@sondeeracine.com
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:
April 12, 2021
Appearance Time: 10 a.m.
to testify and give evidence in regard to alleged violations of federal criminal law, including:
18 U.S.C. §§ 2423(a), 1591
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 (212) 384-1000,
;
and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records.
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
March 26, 2021
andrey Shawss
AUDREY STRAUSS
United States Attorney for the
Southern District of New York
UNITED STATES DISTRICT COURT ILLINOIS
alison y. me
FOR
THE
Assistant United States Attorney
One St. Andrew's Plaza
RICT
TOR
New York, New York 10007
Telephone: 212-637-2225
EFTA00019504

=== Page 3 ===
RIDER
(Grand Jury Subpoena to Interlochen Center for the Arts
dated March 26, 2021)
Please provide any and all student records for the following students who attended Interlochen
Arts Camp and/or Interlochen Arts Academy:
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 (212) 384-1000,
; and (2) accompanied
by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE
IN ELECTRONIC FORMAT IF POSSIBLE.
EFTA00019505

=== Page 4 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. $ 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of
records of the business named below, or I am otherwise qualified as a result of my position with
the business named below to make this declaration.
I am in receipt of a Grand Jury Subpoena, dated March 26, 2021, 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.
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: FW: CORRECTIONAL OFFICERS CHARGED WITH FALSIFYING RECORDS ON
AUGUST 9TH AND 10TH AT THE METROPOLITAN CORRECTIONAL CENTER
Date: Tue, 19 Nov 2019 16:21:10 +0000
Attachments:U.S._v_Tova_Noel_and_Michael_Thomas_19_Cr_830_Indictment_[signed]pdf
Inline-Images: image001.png
Looking forward to the motion to strike the following as superfluous:
During that time period, NOEL and THOMAS were the only correctional officers assigned to the SHU. Aside
from two other officers who briefly visited the common area of the SHU, as confirmed by video surveillance, no
one else entered the SHU, no one conducted any counts or rounds throughout the night, and no one entered the
area in which Epstein was housed.
From: Biase, Nicholas (USANYS)
Sent: Tuesday, November 19, 2019 11:15 AM
Subject: CORRECTIONAL OFFICERS CHARGED WITH FALSIFYING RECORDS ON AUGUST 9TH AND 10TH AT THE
METROPOLITAN CORRECTIONAL CENTER
OF JUSTICE QUI PRO UNITED VILLING
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
CORRECTIONAL OFFICERS CHARGED WITH FALSIFYING RECORDS ON
AUGUST 9TH AND 10TH AT THE METROPOLITAN CORRECTIONAL CENTER
Defendants Allegedly Created Records Falsely Attesting to Required Checks of Inmates the Defendants Never
Did in the Special Housing Unit on the Night Inmate Jeffrey Epstein Committed Suicide
-
Geoffrey S. Berman, the United States Attorney for the Southern District of New York, Guido Modano,
Special Agent in Charge of the Department of Justice Office of the Inspector General, New York Field Office
("DOJ OIG"), and William F. Sweeney Jr., Assistant Director-in-Charge of the New York Field Office of the
Federal Bureau of Investigation ("FBI"), announced today the unsealing of an indictment charging federal
correctional officers TOVA NOEL and MICHAEL THOMAS with making false records and conspiring to make
false records and to defraud the United States by impairing the lawful functions of the Metropolitan Correctional
Center ("MCC"), a Manhattan detention facility that houses federal inmates. NOEL and THOMAS surrendered
this morning. The case is assigned to Southern District of New York U.S. District Judge Analisa Torres.
U.S. Attorney Geoffrey S. Berman said: "As alleged, the defendants had a duty to ensure the safety and
security of federal inmates in their care at the Metropolitan Correctional Center. Instead, they repeatedly failed
EFTA00017935

=== Page 2 ===
to conduct mandated checks on inmates, and lied on official forms to hide their dereliction."
DOJ OIG Special Agent in Charge Guido Modano said: "Correctional Officers swear an oath to carry out
their duties. Completing rounds to verify inmate counts and certifying the accuracy of logs are important tasks
to ensure the safety and security of institutions and the wellbeing of inmates. Those who shirk their duties but
falsely state they have completed them place the institution, fellow employees, inmates, and the public at risk."
FBI Assistant Director William F. Sweeney Jr. said: "Security protocols are in place to protect the public,
fellow officers and inmates being held in the MCC. We allege these officers falsified records to create the
appearance they were following those protocols. The security risks created by this type of behavior are
immense. The message here is simple - citizens place their trust in those who have taken an oath to serve and
protect the public, and when that trust is deliberately violated by public servants, who instead choose to break
those regulations, then they will be held accountable."
According to the Indictment[1] filed today in Manhattan federal court:
On August 10, 2019, NOEL and THOMAS repeatedly failed to complete mandated counts of prisoners
under their watch in the MCC's Special Housing Unit ("SHU"). Instead, for substantial portions of their shifts,
NOEL and THOMAS sat at their desk, browsed the internet, and moved around the common area of the SHU.
To conceal their failure to perform their duties, NOEL and THOMAS repeatedly signed false certifications
attesting to having conducted multiple counts of inmates that they did not do. As a result of those false
statements, the MCC believed prisoners in the SHU were being regularly monitored when, in fact, as a result of
the defendants' conduct, no correctional officer conducted any count or round of the SHU from approximately
10:30 p.m. on August 9 until approximately 6:30 a.m. on August 10, at which time, NOEL and THOMAS
discovered the body of MCC inmate Jeffrey Epstein, who had committed suicide overnight while unobserved.
Background on Relevant Individuals & Entities
The MCC is a federal administrative detention facility located in Manhattan that is run by the Federal
Bureau of Prisons. The MCC employs correctional officers, whose primary duty is to ensure the care, custody,
and control of the inmate population of the MCC. NOEL has been employed as a correctional officer at the
MCC since approximately 2016, and THOMAS has been employed as a correctional officer at the MCC since
approximately 2007. Both NOEL and THOMAS were regularly assigned to work shifts in the SHU at the
MCC.
Correctional officers assigned to guard inmates in the SHU - and throughout the MCC - are required to
conduct institution-wide counts of inmates at regular, scheduled intervals to ensure that each inmate is alive and
accounted for within the MCC. Two officers are required to complete the institutional count for each housing
unit, including the SHU, and are further required to document their performance of the count on an official MCC
form called a count slip. In addition to the institutional count, MCC correctional officers assigned to the SHU
are required to complete rounds every thirty minutes to ensure that each inmate is alive and accounted for within
his cell. Correctional officers working in the SHU are required to complete a form documenting the date and
time of each 30-minute round in each area of the SHU.
On July 6, 2019, Epstein was arrested and detained at the MCC on sex trafficking charges, and was
subsequently assigned to the SHU due to risk factors for suicidality and safety concerns. After an apparent
suicide attempt on July 23, 2019, Epstein was transferred to suicide watch and then psychological observation.
Upon being moved back to the SHU on July 30, 2019, the MCC took steps to guard against future suicide
attempts by Epstein, including by assigning Epstein to the cell closest to the correctional officers' desk.
Conducting the required institutional counts and thirty-minute rounds in the SHU were also part of the MCC's
procedures for ensuring the safety of inmates, including Epstein.
The Events of August 9-10, 2019
EFTA00017936

=== Page 3 ===
On August 9, 2019, NOEL was assigned to work in the SHU from 4:00 p.m. on August 9, 2019, to 8:00
a.m. on August 10, 2019. THOMAS was assigned to work with NOEL in the SHU from 12:00 a.m. until 8:00
a.m. on August 10, 2019. From 4:00 p.m. on August 9 to 8:00 a.m. on August 10, the officers on duty in the
SHU, including NOEL and THOMAS, were responsible for conducting five institutional counts at 4:00 p.m. and
10:00 p.m. on August 9, and at 12:00 a.m., 3:00 a.m., and 5:00 a.m. on August 10. NOEL and THOMAS were
also responsible for completing forms attesting to the completion of each of those counts. In fact, NOEL, and
then NOEL and THOMAS, repeatedly failed to complete mandated counts in the SHU. Instead for substantial
portions of their 12:00-8:00 a.m. shifts, NOEL and THOMAS sat at their desk, browsed the internet, and moved
around the common area of the SHU. During that time period, NOEL and THOMAS were the only correctional
officers assigned to the SHU. Aside from two other officers who briefly visited the common area of the SHU, as
confirmed by video surveillance, no one else entered the SHU, no one conducted any counts or rounds
throughout the night, and no one entered the area in which Epstein was housed.
To conceal their failure to complete their duties, NOEL signed false certifications attesting to having
conducted counts of inmates at 4:00 p.m. and 10:00 p.m., and NOEL and THOMAS signed false certifications
attesting to having conducted counts of inmates at 12:00 a.m., 3:00 a.m., and 5:00 a.m. when, in truth and in fact,
they never conducted such counts. As a result of those false reports, the MCC believed prisoners in the SHU
were being regularly monitored and accounted for when, in fact, no correctional officer conducted any count or
round of the SHU from approximately 10:30 p.m. on August 9 until approximately 6:30 a.m. on August 10, at
which time, NOEL and THOMAS discovered the body of Epstein, who had committed suicide by hanging
himself earlier that morning while unobserved.
NOEL, 31, and THOMAS, 41, are each charged with one count of conspiring to defraud the United
States by impairing, obstructing, and defeating the lawful functions of the MCC, and to make false records,
which carries a maximum sentence of five years in prison. NOEL is also charged with five counts of making
false records, and THOMAS is also charged with three counts of making false records, each of which carries a
maximum sentence of five years in prison.
The statutory maximum and mandatory penalties are prescribed by Congress and are provided here for
informational purposes only, as any sentencing of the defendants would be determined by the judge.
Mr. Berman praised the outstanding investigative work of the Office of the Inspector General, the FBI,
and the New York City Police Department.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys Rebekah
Donaleski and Nicolas Roos are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendants are presumed innocent
unless and until proven guilty.
19-383
###
To view a pdf version of this press release, click here.
Follow us on Facebook | Follow us on Twitter I SDNY website YouTube
Nicholas Biase
EFTA00017937

=== Page 4 ===
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
Mobile:
I
Press Office:
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation.
EFTA00017938


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=== Page 1 ===
The Law Offices of
MONTELL FIGGINS, LLC
www.figginslaw.com
BRANCH OFFICES:
Reply to Newark Office [X]
ASSOCIATES
Kenneth E. Brown, Esq.
Linda Childs, Esq.
January 29, 2020
SENT VIA EMAIL
Assistant United States Attorneys
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Re:
State of NY V Michael Thomas, et al.
Docket No.: 1:19-cr-00830
Discovery Request
Dear Ms.
As previously discussed, I am making a formal request pursuant to Rule 16(a)(1)(C) for
any and all reports, memorandums, written statements, photos, videos, and incident reports
created, manufactured or possessed by the United States Inspector General.
Please see U.S. V. Bryan, 868 F.2d 1032 (1989) if you maintain that Mr. Thomas is not
entitled to the requested documents.
Respectfully yours,
/s/ Montell Figgins
Montell Figgins, Esq.
Attorney for Defendant Michael Thomas
cc:
Jason Erroy Foy, Esq, Counsel for Defendant Noel via ECF
EFTA00017811


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=== Page 1 ===
From:
Subject: Re: ISO Deutsche Bank contact -- in-house or outside counsel
Date: Thu, 11 Jul 2019 03:03:25 +0000
Importance: Normal
Yeah. Also I keep meaning to ask if we're going to reach out to Hoffenberg.
Sent from my iPhone
On Jul 10, 2019, at 10:48 PM,
)
wrote:
https://www.nytimes.com/2019/07/10/business/jeffrey-epstein-net-worth.html
Sent from my iPhone
On Jul 10, 2019, at 22:32,
(USANYS)
wrote:
What's issue?
Sent from my iPhone
On Jul 10, 2019, at 9:58 PM,
)
wrote:
Anybody have a good contact at Deutsche Bank, or have had dealings with a firm representing them? Thx.
EFTA00018170


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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
Subject: FW: 404(b) notice
Date: Fri, 08 Oct 2021 19:49:11 +0000
Attachments: 2021.10.11_Maxwell_Rule_404(b)_letter_-_TAM-IE.docx.
From:
(USANYS)
Sent: Friday, October 8, 2021 3:40 PM
To:
>;
(USANYS)
Cc:
(USANYS)
is
;
Subject: RE: 404(b) notice
Here is one comment from me and Janis.
From:
Sent: Friday, October 8, 2021 2:
>;
(USANYS)
Cc:
(USANYS)
>;
;
Subject: 404(b) notice
Chiefs,
Attached for your review is the draft of our Rule 404(b) letter. It's due on Monday.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 100
EFTA00019046


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=== Page 1 ===
From:
)"
To: "
y (USANYS)
Subject: FW: United States V. Maxwell, 20 Cr. 330, juror questionnaires
Date: Sun, 14 Nov 2021 20:27:23 +0000
Attachments: 2021-11-07_joint_letter_regarding_juror_questionnaires. final.pdf.
From:
Sent: Sunday, November 7, 2021 9:45 PM
To: Nathan NYSD Chambers
Cc:
(USANYS)
is
>;
Subject: United States V. Maxwell, 20 Cr. 330, juror questionnaires
Chambers,
Attached please find a joint letter regarding prospective juror questionnaires.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00018267


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=== Page 1 ===
From:
To:
Subject: Accepted: Meet re: Epstein Investigation
Date: Wed, 05 Dec 2018 00:22:28 +0000
Importance: Normal
Attachments: unnamed
EFTA00019427


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=== Page 1 ===
From:
To:
Subject: RE: Call
Date: Mon, 20 Sep 2021 18:14:45 +0000
Inline-Images: image001.jpg; image002.jpg; image005.jpg
Tried you. Give me a call back.
From:
Sent: Monday, September 20, 2021 1:11 PM
To:
Subject: RE: Call
Can we do 1:30 pm today?
Special Agent
U.S. Department of Justice
Office of the Inspector General
New York Field Office
US
New York, NY 10004
SPECIAL
THE
From:
Sent: Monday, September 20, 2021 12:38 PM
To:
Subject: RE: Call
Hi - Want to talk today? When are you free?
From:
Sent: Thursday, September 16, 2021 9:15 AM
To:
Subject: Call
Good Morning
Please let me know if you have a few minutes to speak with myself and SSA
regarding the Epstein case.
Thank you.
Special Agent
U.S. Department of Justice
Office of the Inspector General
New York Field Office
US
New York, NY 10004
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=== Page 1 ===
From:
To:
Subject: FW: Download complete
Date: Mon, 09 Mar 2020 21:31:21 +0000
Special Agent
FBI New York Field Office
Violent Crimes Task Force
From:
Sent: Wednesday, August 14, 2019 11:08 PM
To:
Subject: Download complete
Priority cameras from dvrl completed downloading. The contractor is here working on the replacement system
and reports that he could get the new system up and recording tonight. The cart and mxu team will be departing.
The A7 Agent and the BOP employee will stay with the DVR until the tech is done and the cameras are up and
recording. Once that is done A7 agent will secure the room with evidence tape until c19 team arrives tomorrow.
I will.stage downloaded video on opwan for mxu to copy tonight to transcode and stage on ttk for review.
The DVR can be shut down and collected tomorrow. I will come back with who ever comes here to do that.
EFTA00017949


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=== Page 1 ===
From:
To:
Subject: FW: Victim contact list
Date: Thu, 22 Aug 2019 15:24:36 +0000
Attachments: 2019.08.20_JE_Victim_List.xlsx
From:
Sent: Tuesday, August 20, 2019 2:32 PM
To:
Cc:
Subject: Victim contact list
Hi
Following up on our meeting yesterday, attached is the updated spreadsheet of all identified victims and noting which
ones have been contacted. Would you please review this with the FBI victim specialists to note any additional contact
with victims since Epstein's death? And if there are still any victims in this spreadsheet who have not been contacted
since Epstein's death, would you please attempt to contact them and make a note of those attempts in the spreadsheet?
Give me a call if you have any questions, and thanks so much for your help with this.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 315 Filed 07/30/21 Page 1 of 3
USDC SDNY
UNITED STATES DISTRICT COURT
DOCUMENT
SOUTHERN DISTRICT OF NEW YORK
ELECTRONICALLY FILED
DOC #:
DATE FILED: 7/30/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
The Government has moved for an order requiring David Markus to comply with Local
Criminal Rule 23.1 following an op-ed that he authored opining on the merits of this pending
case. Dkt. No. 309.
Mr. Markus is plainly a lawyer associated with the defense in this case. His formal
representation has involved handling at least one pre-trial issue for Ms. Maxwell-in particular,
appeals to the Second Circuit of this Court's bail-denial determinations. Dkt. No. 173; see also
United States V. Maxwell, Nos. 21-58-cr(L), 21-770-cr (2d Cir.). Beyond that, he has held
himself out as Ms. Maxwell's attorney in press related to the current trial stage, including in the
op-ed at issue in the Government's letter application, which describes him as "Maxwell's
appellate counsel." He has also attended a proceeding in this matter and spoken on Ms.
Maxwell's behalf to the press afterwards while identified as Ms. Maxwell's attorney. See
Stephen Rex Brown, Ghislaine Maxwell Makes First In-Person NYC Court Appearance, N.Y.
Daily News (Apr. 23, 2021), https://www.nydailynews.com/new-york/ny-ghislaine-maxwel-
arraignment-20210423-b3aza5eh7bddna7r247px2yb7e-story.html.
Nevertheless Mr. Markus argues that he is not subject to Rule 23.1 because he does not
currently represent Ms. Maxwell in any proceedings and has not made an appearance in this
1
EFTA00018028

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 315 Filed 07/30/21 Page 2 of 3
Court. Dkt. No. 314. Rule 23.1 is not so superficial nor easily circumvented. Nothing in the
rule limits its application to lawyers who have formally noticed an appearance. To the contrary,
as the text throughout the rule makes clear, it applies to statements made by lawyers (and others)
"associated" with "pending or imminent criminal litigation." S.D.N.Y. Local Criminal Rule
23.1(a) (last updated Oct. 29, 2018); see also Rule 23.1(b) ("a lawyer participating in or
associated with the investigation"); Rule 23.1(c) ("lawyer or law firm associated with the
prosecution or defense"). An attorney need not be of record in order to be sufficiently
"associated" with a case as to justify application of disciplinary rules regarding extrajudicial
statements. Lawyers who have not filed a formal notice of appearance may still possess
information that lends a perception by the public that their remarks on a pending case hold
greater authority. See In re Hinds, 449 A.2d 483, 496 (N.J. 1982); see also People V. Buttafuoco,
599 N.Y.S.2d 419 (Nassau Cty. Ct. 1993).
Such is the case with Mr. Markus's role in the pending matter. As noted, Mr. Markus has
attended a proceeding in this Court, after which he spoke to the press on Ms. Maxwell's behalf.
He has represented Ms. Maxwell on appeals of this Court's pre-trial bail determinations.
Moreover, Mr. Markus has identified himself as Ms. Maxwell's appellate lawyer in a published
op-ed discussing his opinion of the merits of this case. These facts mean that the public, which
includes potential jurors, may perceive Mr. Markus as an authoritative source of information
regarding the pending matter and may readily consider his remarks to be accurate and reliable.
Mr. Markus is therefore ORDERED to comply with Local Criminal Rule 23.1.
The Government does not ask the Court to discipline Mr. Markus based on his op-ed and
the Court declines to consider whether it violated Rule 23.1 given the potential lack of clarity
with respect to whether Mr. Markus was bound by the rule. The Court emphasizes that the rule
2
EFTA00018029

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 315 Filed 07/30/21 Page 3 of 3
provides illustrative examples of statements that "presumptively involve a substantial likelihood
that their public dissemination will interfere with a fair trial or otherwise prejudice the due
administration of justice within the meaning of the rule." S.D.N.Y. Local Criminal Rule 23(d).
Going forward, Mr. Markus and all lawyers associated with the pending case are now
clearly on notice that their conduct falls under the purview of Local Criminal Rule 23.1. Indeed,
the above concerns do not apply only to Mr. Markus. This Court has previously noted that
"counsel[,] agents for the parties and counsel for potential witnesses" must take care to "protect
the Defendant's right to a fair trial by an impartial jury." Dkt. No. 28. This Court is cognizant
that criminal matters heading toward trial are especially sensitive to extrajudicial statements. All
those associated with this case must act to ensure the case is tried solely in court or else they risk
being deemed responsible for any trial delay or for undermining the integrity of the upcoming
trial. See S.D.N.Y. Local Criminal Rule 23.1(h). In addition to the impact it could have on this
matter, failure to comply could also result in attorney discipline. Id. Rule 23.1(i).
so ORDERED.
Dated: July 30, 2021
New York, New York
Alim D.Nitto
ALISON J. NATHAN
United States District Judge
3
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From:
To:
)"
)"
(NY) (FBI)"
)"
Subject: Little St James Search Warrant Items
Date: Fri, 23 Aug 2019 05:07:08 +0000
Attachments: VI_SW_item_list.xlsx; C20_LSJ_12AUG2019 - PDF.pdf
See attached list of all items recovered from LSJ search warrant. Also see attached search warrant tac plan
which better details what each building was labeled. Hope this helps with drafting the SW for those items.
Please let us know if you have any questions.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
EFTA00019668


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=== Page 1 ===
To:
From:
Sent:
Sat 8/10/2019 3:15:50 PM
Subject: Fwd: NYM Time Line
Fwd: NYM Time Line
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
Date: 8/10/19 11:04 AM (GMT-05:00)
To:
Subject: Fwd: NYM Time Line
CONFIDENTIAL
SDNY_00011145
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=== Page 1 ===
To:
From:
Sent:
Sat 8/10/2019 1:10:56 PM
Subject:
Fwd: 2nd draft of press release
TEXT.htm
Press Release - MCC New York.docx
Some changes were made and this is the latest. Please review and provide answers to the below -
thanks.
Mike
Forwarded message
(1) Has Epstein's next of kin been notified?
(2) Did staff initiate life-saving measures when they first found Epstein at approximately 6:30 am in his
cell?
(3) Did EMS or some sort of hospital staff come out to the institution, and if so, did they initiate life-
saving measures at the institution? And did EMS drive Epstein to the hospital or did BOP drive him to
the hospital?
(4) Was Epstein pronounced dead by EMS (transporting folks) or instead hospital staff at 7:30 am at the
hospital?
(5) Was the FBI notified? Is it being investigated as a suicide?
(6) What date did he first arrive at MCC NY on his PP37?
(7) What are his specific offense titles for which he is indicted? I believe generally the news calls it sex
trafficking, but we should be as specifically accurate based on Sentry (or the court order if we have it).
CONFIDENTIAL
SDNY_00010716
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=== Page 1 ===
From:
"
To:
Cc:
Subject: Epstein
Date: Tue, 23 Jul 2019 14:30:06 +0000
Importance: Normal
Attachments: TEXT.htm; 2019_07_23_10_29_05.pdf
Please attached:
Captain
Metropolitan Correctional Center
150 Park Row
New York, NY 10007
Office:
Blackberry
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=== Page 1 ===
UNITED STATES GOVERNMENT
MEMORANDUM
METROPOLITAN CORRECTIONAL CENTER
New York, NY 10007
July 28, 2019
REPLY TO
ATTN OF:
,
M/W Operations Lieutenant
SUBJECT: Daily Activity Report
TO:
, Warden
,
Associate Warden (0)
,
Associate Warden (P)
,
Executive Assistant
,
Captain
Lieutenants
Departments Heads
Daily Activity as communicated or documented by the Operations
Lieutenant for July 27, 2019, was received and/or reviewed. The
following information was noted.
Morning Watch Shift:
Lt.
reported Fire Watch in Progress. Correctional
assignments Sanitation Officer, unassigned due to a shortage of staff.
Day Watch Shift:
Lt.
reported Fire Watch in progress. Correctional
assignments Search officer, SHU #3, SHU #4, 10-South #2
unassigned, due to a shortage of staff.
Evening Watch Shift:
Lt.
reported Fire Watch in progress. Correctional
assignment SHU #4, unassigned due to a shortage of staff.
CONFIDENTIAL
SDNY_00012210
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=== Page 2 ===
INMATES IN OUTSIDE HOSPITAL/SUICIDE WATCH/FURLOUGH/DRY CELL:
I/M Epstein #76318-054 on Psych Observation w/inmate companion
NEW ADMISSIONS TO MCC New York:
None
RELEASED FROM MCC NEW YORK:
None
ADMISSIONS TO THE SPECIAL HOUSING UNIT:
None
TOTAL NUMBER OF CELLS IN SHU THAT ARE PRESENTLY TRIPLE BUNKED:
None
MISSING FIRE AND SECURITY REPORT:
None
MISSING EQUIPMENT INVENTORY FORM:
None
CONFIDENTIAL
SDNY_00012211
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=== Page 3 ===
THE FOLLOWING LEAVE WAS UTILIUZED:
FURLOUGH: 00
ANNUAL LEAVE: 03
SICK LEAVE: 07
OFFICIAL TIME: 00
SUSPENSION: 00
FFLA: 00
FMLA: 00
COP: 02
AWOL: 00
ADVANCE LEAVE: 00
LWOP: 01
ADMIN LEAVE: 00
COMP TIME: 00
TRAINING: 00
GLYNCO: 00
LWOP (M) : 00
TOA: 02
EPO: 00
TRAVEL: 00
THE FOLLOWING OVERTIMES WERE HIRED:
E-1 OVERTIME:
Number of staff = 33
Hours = 234.00
E-1 COMPTIME:
Number of staff = 02
Hours = 16.00
60-Q OVERTIME (USM MEDICAL) :
Number of Staff = 00
Hours = 00.00
B-2 OVERTIME:
CONFIDENTIAL
SDNY_00012212
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=== Page 4 ===
Number of Staff = 00
Hours = 00.00
O9D OVERTIME (SPECIAL) :
Number of Staff = 00
Hours = 00.00
XXX OVERTIME (AIRLIFT) :
Number of Staff = 00
Hours = 00.00
87S OVERTIME (TREATY TRANS) :
Number of Staff = 00
Hours = 00.00
INSTITUTION TOTALS AT THE BEGINNING OF THE MORNING WATCH SHIFT:
07-27-2019 / 12:00 AM
UNIT B-A: 26
UNIT E-N: 87
UNIT E-S: 85
UNIT G-N: 70
UNIT G-S: 91
UNIT H-A: 01
UNIT I-N: 93
UNIT K-N: 89
UNIT K-S: 138
UNIT Z-A: 72
UNIT Z-B: 05
TOTAL:
767
CONFIDENTIAL
SDNY_00012213
EFTA00034755


c1: EFTA00035205
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00035205.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
DEPARTMENT OF JUSTICE
LEVERAL BUREAU OF OFFICIALITY
UNITED STATES GOVERNMENT
MEMORANDUM
Metropolitan Correctional Center, New York, New York
DATE: August 12, 2019
TO: Warden
FROM: S/O/S
SUBJECT: Passed information from Special Housing Unit
On Friday August 9, 2019 at approximately 1:50 p.m, I S/O/S
passed on to oncoming staff
member Officer
and present shift staff S/O/S
and Officer
That Inmate Reyes
#85993-054 was going WAB and possibly may not return. Also that Inmate Epstein #76318-054 will be
needing a cell mate upon arrival from his attorney visit.
EFTA00035205


c1: EFTA00035618
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00035618.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Fwd: Client Jeffrey Epstein
Date: Tue, 06 Aug 2019 19:25:44 +0000
Importance: High
Attachments: TEXT.htm
Good afternoon all,
Below please find complaints from Epstein's attorneys. Can you check to see if he has toilet paper and that his CPAP is
plugged in?
I am less concerned regarding his complaint of having had two calls, but they were on unmonitored lines, so there is no
recording of them. Is his phone account set up so he can get a call on the ITS when 30 days has elapsed?
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
p:
f:
>>> Mariel Colon <
>
8/6/2019 3:20 PM >>>
Good afternoon
Our client, Jeffrey Epstein, has informed us that he has no toilet paper in his cell. His CPap machine was not plugged in last
night, so he was unable to use it.
Also, since his arrival at MCC, he has only been able to make two fifteen minute phone calls. Both times, the calls were on
speaker phone, with officers present.
Thank you in advance for your help.
Best,
Mariel Colon Miro, Esq.
Law Offices of Michael Lambert
EFTA00035618

=== Page 2 ===
New York, NY 10016
NOTICE: This message may contain information that is privileged or confidential. If you receive
this transmission in error, please notify the sender by reply e-mail and delete the message and
any attachments.
EFTA00035619


c1: EFTA00035279
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00035279.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Re: Suicide Watch/Psych Observation Update
Date: Sat, 27 Jul 2019 13:41:51 +0000
Importance: Normal
Attachments: TEXT.htm
Good morning,
You assessed inmate Epstein today?
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
>
Date: 7/27/19 6:08 AM (GMT-05:00)
To:
Subject: Suicide Watch/Psych Observation Update
>>>
07/27/2019 06:08 >>>
Suicide Watch
None
Psych Observation
1. Epstein #76318-054
EFTA00035279

=== Page 2 ===
Thank you,
EFTA00035280


c1: EFTA00035740
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00035740.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
OFFICIAL RECORD
FD-1036 (Rev. 10-16-2009)
Document participarts digitally signed
UNCLASSIFIED
a
certified information
FEDERAL BUREAU OF INVESTIGATION
Import Form
Form Type: OTHER - Other
Date: 09/25/2019
Title: (U) MCC Annual Refresher Training
Approved By: SSA
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Synopsis: (U) On August 13, 2019, OIG SA
provided the
MCC Annual Refresher Training forms and records for 2019.
+
UNCLASSIFIED
SDNY_00017804
EFTA00035740


c1: EFTA00035486
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00035486.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
>
Subject: Epstein, Reg. No. 76318-054
Date: Sat, 10 Aug 2019 22:14:05 +0000
Importance: Normal
Attachments: TEXT_1.htm; 2019_08_10_18_12_55.pdf;
Psych Ops discontinued on 7/30/18 at 8:15 am
Associate Warden
MCC New York
New York, NY 10007
EFTA00035486


c1: EFTA00034217
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00034217.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
COMMENT VELERN BUREAU OF OF justice
U.S. Department of Justice
Federal Bureau of Prisons
Office of the Warden
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
(646) 836-6300. (646) 836-7751 (Fax)
MEMORANDUM FOR ROCCO LUPO, FOOD SERVICE ADMINISTRATOR
FROM:
,
Cook Supervisor
SUBJECT:
Authorization to Feed Meals in the Attorney Conference
Room
On July 23, 2019 I was informed by Cook Supervisor
that
Inmate Epstein was being fed inside attorney conference. I never
stated to anyone that my supervisor instructed me to feed Inmate
Epstein inside attorney conference.
CONFIDENTIAL
SDNY_00010540
EFTA00034217


c1: EFTA00035791
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00035791.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Fox News Tucker Carlson Segment
January 25, 2023
Summary
Tucker Carlson: So you would think as the Attorney General (referring to Bill Barr) his first concern would
be finding out what actually happened but instead his first concern was worried that the public might jump
to unapproved conclusions about what happened. And in some ways, Bill Barr was right to worry. Many
Americans did not believe that Jeffrey Epstein had killed himself given the strange circumstances of his
death-stranger than most people understood at the time. It was going to take a sustained public relations
campaign to convince Americans that Jeffrey Epstein killed himself, but Bill Barr was willing to make the
effort. 2 days later, he flew to New Orleans, gave a speech, and said this:
/ was appalled and indeed the whole Department was, and frankly, angry, to learn of the MCC's
failure to adequately secure this prisoner. We are now learning of serious irregularities at this
facility that are deeply concerning and demand a thorough investigation. The FBI and the Office of
Inspector General are doing just that. We will get to the bottom of what happened, and there will be
accountability.
Tucker Carlson: 3.5 years after Jeffrey Epstein died, no one has gotten to the bottom of what happened
that day and there has been no accountability for it. The only people ever punished for the grotesque
malfeasance surrounding Epstein's death were two low-level guards who fell asleep on duty that night.
Both pleaded guilty to falsifying government records. But last year, with no real explanation, an Obama-
appointed judge dropped all charges against both of them. One of the guards may still work for the federal
government. As for getting to the bottom of what happened-despite many promises from many various
officials-not to the FBI nor the Justice Department's Office of Inspector General has ever issued a report
explaining how Jeffrey Epstein died not a word. So, once again, 3.5 years after one of the most widely
covered deaths of our time, there's still no answers and there's still no accountability. Why is that?
Tucker Carlson quotes from Bill Barr's memoir regarding the medical examiner. Tucker Carlson questions
why reporters never questioned Bill Barr's assessment of Epstein's death. Tucker Carlson resumes
discussing the initial medical examiner's assessment, and then discusses NYC's chief medical examiner
Barbara Sampson's declaration of Epstein's death of suicide. Tucker Carlson then begins discussing
Epstein's cell and surrounding inmates, saying BOP wouldn't provide Carlson with the inmate's names on
Epstein's tier.
Tucker Carlson: This week, we've called virtually every person involved in the story surrounding Epstein's
death. With very few exceptions, none of them would speak to us. Some hung up immediately. Others
declined all comment. One of them, the DOJ case officer supposedly assigned to investigate Epstein's
death, refused even to acknowledge that he worked for the federal government. "I'm not going to confirm
or deny that" said Mr. Lyeson Daniel when we reached him on his cell phone. "Why is that?" we asked him.
"I'm not going to confirm or deny that" he repeated.
Tucker Carlson then begins discussing Jeffrey Epstein's denial of an alleged suicide attempt on July 23,
1
EFTA00035791

=== Page 2 ===
2019. Carlson also asks wants to know if the cell's on Epstein's tier were locked the entire night he was
killed and says a source claims they weren't. He also wants to know who moved Epstein's body, re-dressed
Epstein's corpse, and intubated it.
Tucker Carlson: We dutifully called the Department of Justice to ask them to explain some of this, they
refused on the grounds that there is quote "an active investigation in progress." But that is a lie. There is
no investigation into Jeffrey Epstein's death. We're moving on 4 years now, there has never been an
investigation into Jeffrey Epstein's death the death of an American citizen. We can only speculate as to
why that is, but all the explanations are bad and ominous. Maybe someone in the new Republican
Congress should look into all of this. Not because Jeffrey Epstein was an American hero, but because for
once, it'd be nice to see the federal government forced to tell the truth about something.
2
EFTA00035792


c1: EFTA00035508
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00035508.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES GOVERNMENT
MEMORANDUM
METROPOLITAN CORRECTIONAL CENTER
New York, NY 10007
July 28, 2019
REPLY TO
ATTN OF:
,
M/W Operations Lieutenant
SUBJECT: Daily Activity Report
TO:
, Warden
Associate Warden (0)
,
Associate Warden (P)
,
Executive Assistant
, Captain
Lieutenants
Departments Heads
Daily Activity as communicated or documented by the Operations
Lieutenant for July 27, 2019, was received and/or reviewed. The
following information was noted.
Morning Watch Shift:
Lt.
reported Fire Watch in Progress. Correctional
assignments Sanitation Officer, unassigned due to a shortage of staff.
Day Watch Shift:
Lt.
reported Fire Watch in progress. Correctional
assignments Search officer, SHU #3, SHU #4, 10-South #2
unassigned, due to a shortage of staff.
Evening Watch Shift:
Lt.
reported Fire Watch in progress. Correctional
assignment SHU #4, unassigned due to a shortage of staff.
EFTA00035508

=== Page 2 ===
INMATES IN OUTSIDE HOSPITAL/SUICIDE WATCH/FURLOUGH/DRY CELL:
I/M Epstein #76318-054 on Psych Observation w/inmate companion
NEW ADMISSIONS TO MCC New York:
None
RELEASED FROM MCC NEW YORK:
None
ADMISSIONS TO THE SPECIAL HOUSING UNIT:
None
TOTAL NUMBER OF CELLS IN SHU THAT ARE PRESENTLY TRIPLE BUNKED:
None
MISSING FIRE AND SECURITY REPORT:
None
MISSING EQUIPMENT INVENTORY FORM:
None
EFTA00035509

=== Page 3 ===
THE FOLLOWING LEAVE WAS UTILIUZED:
FURLOUGH: 00
LWOP: 01
ANNUAL LEAVE: 03
ADMIN LEAVE: 00
SICK LEAVE: 07
COMP TIME: 00
OFFICIAL TIME: 00
TRAINING: 00
SUSPENSION: 00
GLYNCO: 00
FFLA: 00
LWOP (M) : 00
FMLA: 00
TOA: 02
COP: 02
EPO: 00
AWOL: 00
TRAVEL: 00
ADVANCE LEAVE: 00
THE FOLLOWING OVERTIMES WERE HIRED:
E-1 OVERTIME:
Number of staff = 33
Hours = 234.00
E-1 COMPTIME:
Number of staff = 02
Hours = 16.00
60-Q OVERTIME (USM MEDICAL) :
Number of Staff = 00
Hours = 00.00
B-2 OVERTIME:
Number of Staff = 00
Hours = 00.00
O9D OVERTIME (SPECIAL) :
Number of Staff = 00
Hours = 00.00
XXX OVERTIME (AIRLIFT) :
Number of Staff = 00
Hours = 00.00
87S OVERTIME (TREATY TRANS) :
Number of Staff = 00
Hours = 00.00
INSTITUTION TOTALS AT THE BEGINNING OF THE MORNING WATCH SHIFT:
EFTA00035510

=== Page 4 ===
07-27-2019 / 12:00 AM
UNIT B-A: 26
UNIT E-N: 87
UNIT E-S: 85
UNIT G-N: 70
UNIT G-S: 91
UNIT H-A: 01
UNIT I-N: 93
UNIT K-N: 89
UNIT K-S: 138
UNIT Z-A: 72
UNIT Z-B: 05
TOTAL:
767
EFTA00035511


c1: EFTA00034348
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00034348.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES GOVERNMENT
MEMORANDUM
METROPOLITAN CORRECTIONAL CENTER
New York, NY 10007
August 11, 2019
REPLY TO
ATTN OF:
,
M/W Operations Lieutenant
SUBJECT: Daily Activity Report
TO:
, Warden
,
Associate Warden (0)
,
Associate Warden (P)
,
Executive Assistant
, Captain
Lieutenants
Departments Heads
Daily Activity as communicated or documented by the Operations
Lieutenant for August 10, 2019, was received and/or reviewed. The
following information was noted.
Morning Watch Shift:
Lt.
reported Correctional assignment Sanitation
vacated, due to, a shortage of staff. Control Center Fire Panel
remains inoperative.
Day Watch Shift:
Lt.
reported I/M Epstein #76318-054 found unresponsive in
Special Housing escorted to the outside hospital for treatment.
Evening Watch Shift:
Lt.
correctional assignment 10 South #2 vacated, due to,
a shortage of staff.
CONFIDENTIAL
SDNY_00010765
EFTA00034348

=== Page 2 ===
INMATES IN OUTSIDE HOSPITAL/SUICIDE WATCH/FURLOUGH/DRY CELL:
I/M
on Suicide Watch w/inmate companion
I/M
on Suicide Watch w/inmate companion
I/M
pending bed space (SHU)
NEW ADMISSIONS TO MCC New York:
NONE
RELEASED FROM MCC NEW YORK:
NONE
ADMISSIONS TO THE SPECIAL HOUSING UNIT:
NONE
TOTAL NUMBER OF CELLS IN SHU THAT ARE PRESENTLY TRIPLE BUNKED:
None
MISSING FIRE AND SECURITY REPORT:
NONE
MISSING EQUIPMENT INVENTORY FORM:
NONE
CONFIDENTIAL
SDNY_00010766
EFTA00034349

=== Page 3 ===
THE FOLLOWING LEAVE WAS UTILIZED:
FURLOUGH: 00
ANNUAL LEAVE: 05
SICK LEAVE: 12
OFFICIAL TIME: 00
SUSPENSION: 00
FFLA: 00
FMLA: 00
COP: 02
AWOL: 00
ADVANCE LEAVE: 00
LWOP: 00
ADMIN LEAVE: 00
COMP TIME: 00
TRAINING: 00
GLYNCO: 00
LWOP (M) : 00
TOA: 00
EPO: 00
TRAVEL: 00
THE FOLLOWING OVERTIMES WERE HIRED:
E-1 OVERTIME:
Number of staff = 34
Hours = 263.00
E-1 COMPTIME:
Number of staff = 00
Hours = 00.00
60-Q OVERTIME (USM MEDICAL) :
Number of Staff = 00
Hours = 00.00
CONFIDENTIAL
SDNY_00010767
EFTA00034350

=== Page 4 ===
B-2 OVERTIME:
Number of Staff = 00
Hours = 00.00
O9D OVERTIME (SPECIAL) :
Number of Staff = 00
Hours = 00.00
XXX OVERTIME (AIRLIFT) :
Number of Staff = 00
Hours = 00.00
87S OVERTIME (TREATY TRANS) :
Number of Staff = 03
Hours = 00.00
INSTITUTION TOTALS AT THE BEGINNING OF THE MORNING WATCH SHIFT:
08-10-2019 / 12:00 AM
UNIT B-A: 26
UNIT E-N: 87
UNIT E-S: 81
UNIT G-N: 79
UNIT G-S: 80
UNIT H-A: 03
UNIT I-N: 85
UNIT K-N: 88
UNIT K-S: 138
UNIT Z-A: 77
UNIT Z-B: 05
TOTAL:
759
CONFIDENTIAL
SDNY_00010768
EFTA00034351


c1: EFTA00034729
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00034729.pdf
c6: pdf
c7: images
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=== Page 1 ===
To:
From:
5:35:12 PM
Subject: Epstein
TEXT.htm
The National Suicide Prevention Coordinator from Central Office,
,
contacted me today about
Epstein. He thought that housing him with another sex offender in SHU would be a good idea. I told him
I would speak with the executive staff about his suggestion. Also,
thought it wise that we keep
him down here for a bit (as is the plan already).
I am heading to the hospital in about a half an hour or so. If you need me for anything, feel free to call
my cell phone
Thank you.
Chief Psychologist
U.S. Department of Justice/
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
Office:
Fax:
E-mail:
CONFIDENTIAL
SDNY_00012167
EFTA00034729


c1: EFTA00035747
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00035747.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
OFFICIAL RECORD
FD-1036 (Rev. 10-16-2009)
Document participants digitally signed
UNCLASSIFIED
a
certified information
FEDERAL BUREAU OF INVESTIGATION
Import Form
Form Type: OTHER - Other
Date: 10/03/2019
Title: (U) Form 583 Report of Incident Regarding Jeffrey Epstein
Approved By: SSA
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Synopsis: (U) On August 14, 2019, OIG SA
provided the
Form 583 Report of Incident from August 10, 2019, regarding Jeffrey
Epstein.
UNCLASSIFIED
SDNY_00017811
EFTA00035747


c1: EFTA00034107
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00034107.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
To:
From:
Sent:
Fri 7/26/2019 6:57:21 PM
Subject:
Suicide Watch/Psych Observation Update
TEXT.htm
Suicide Watch
None
Psych Observation
1. Epstein #76318-054
Thank you,
CONFIDENTIAL
SDNY_00010157
EFTA00034107


c1: EFTA00035481
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00035481.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
"
Subject: Documentation
Date: Sat, 10 Aug 2019 21:44:45 +0000
Importance: Normal
Attachments: 30_MINUTE_ROUNDS_8-8-19.pdf;_30_MINUTE_ROUNDS_8-9-19.pdf;,
30_MINUTE_ROUNDS_8-10-19.pdf_TRU-SCOPE_LOGS.pdf
EFTA00035481


c1: EFTA00035450
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00035450.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
FYI
>>>
> 8/12/2019 2:42 PM >>>
please thank the Warden for his prompt response to my letter.
Richard M. Berman
On Aug 12, 2019, at 2:37 PM,
> wrote:
fyi
Forwarded by
on 08/12/2019 02:37 PM
From:
Date: 08/12/2019 02:33 PM
Subject: Re: Jeffrey Epstein 19 cr 490
Good afternoon,
Attached please find Warden
response to Your Honor's inquiry. Please let us know if you need further
information.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
8/12/2019 12:47 PM
Please see attached letter from Judge Richard M. Berman.
(See attached file: Aug 12 letter.pdf)(See attached file: 2019_08_12_14_31_06.pdf)
<2019_08_12_14_31_06.pdf>
EFTA00035450


c1: EFTA00036124
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00036124.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
EMPLOYEE:
PP: 15
WORK HOURS: 80 DAYS OFF: Saturday/ Sunday
Week
Week
1
2
S
M
T
W
TH
FR
S
CODE
TYPE OF
CODE
S
M
T
W
TH
FR
S
DUTY
DATE
7/22
7/23
7/24
7/25
7/26
DATE
DATE
7/29
7/30
7/31
8/1
8/2
DATE
8
8
01/1
REGULAR /
01/1
8
8
SH1
01/2
REGULAR /
01/2
SH2
01/3
REGULAR /
01/3
SH3
04/1
SUNDAY / SH1
04/1
04/2
SUNDAY / SH2
04/2
04/3
SUNDAY / SH3
04/3
8
8
8
61
ANNUAL LV
61
62
SICK LV
62
8
62/62
SICK LEAVE
62/62
FFLA
61/66
TIME OFF
61/66
AWARD
64
COMP USED
64
21
OVERTIME
21
32
COMP EARNED
32
66/1
HOLIDAY
66/1
OFF/SH1
66/2
HOLIDAY
66/2
OFF/SH2
66/3
HOLIDAY
66/3
OFF/SH3
31/1
HOLIDAY
31/1
WRKD/SH1
31/2
HOLIDAY
31/2
WRKD/SH2
31/3
HOLIDAY
31/3
WRKD/SH3
67
COP- INJURY
67
LV
63
RESTORED LV
63
65
MILITARY LV
65
61/TC
VLTP
61/TC
DONATION
TRAINING
AUGMENTATION
(348)
LWOP
AWOL
EFTA00036124

=== Page 2 ===
TOTAL HOURS
80
OVERTIME DETAILS:
NOTES: Retired 7/31 Last Day
TIMEKEEPER
EMPLOYEE
SUPERVISOR
EFTA00036125


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0009/EFTA00035031.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Bureau of Prisons
Health Services
Clinical Encounter
Inmate Name: EPSTEIN, JEFFREY EDWARD
Reg #: 76318-054
Date of Birth: 01/20/1953
Sex:
M Race: WHITE
Facility: NYM
Encounter Date: 07/23/2019 06:20
Provider:
Unit:
H01
Injury Assessment - Non-work related encounter performed at Health Services.
SUBJECTIVE:
INJURY 1
Provider:
Date of Injury:
07/23/2019 01:27
Date Reported for Treatment:
07/23/2019 08:25
Work Related:
No
Work Assignment: UNASSG
Pain Location:
Pain Scale: 0
Pain Qualities:
Where Did Injury Happen (Be specific as to location):
Special Housing Unit Z05-Cell 124 L
Cause of Injury (Inmate's Statement of how injury occurred):
"I do not know. Just went to drink a little water and wake up snorting".
Symptoms (as reported by inmate):
None
OBJECTIVE:
Temperature:
Date
Time
Fahrenheit
Celsius
Location
Provider
07/23/2019
06:30 NYM
97.5
36.4
Oral
Pulse:
Date
Time
Rate Per Minute
Location
Rhythm
Provider
07/23/2019 06:30
92
Via Machine
Regular
Respirations:
Date
Time
Rate Per Minute Provider
07/23/2019
06:30 NYM
16
Blood Pressure:
Date
Time
Value
Location
Position
Cuff Size
Provider
07/23/2019
06:30 NYM
140/85
Right Arm
Sitting
Adult-regular
SaO2:
Date
Time
Value(%) Air
Provider
07/23/2019
06:30 NYM
96 Room Air
Exam:
General
Affect
Yes: Cooperative
Appearance
Yes: Appears Well, Alert and Oriented X 3
No: Appears Distressed, Lethargic, Dyspneic, Appears in Pain, Pallor, Cyanotic, Diaphoretic, Disheveled,
Generated 07/23/2019 09:05 by
Bureau of Prisons - NYM
Page 1 of 2
EFTA00035031

=== Page 2 ===
Inmate Name: EPSTEIN, JEFFREY EDWARD
Reg #: 76318-054
Date of Birth: 01/20/1953
Sex:
M Race: WHITE
Facility: NYM
Encounter Date: 07/23/2019 06:20
Provider:
Unit:
H01
Exam:
Acutely III
Pulmonary
Auscultation
Yes: Clear to Auscultation, Vesicular Breath Sounds Bilaterally
No: Crackles, Rhonchi, Wheezing
Exam Comments
Inmate for injury report as requested by Operational Lt.
He is ambulatory, oriented X 3. In not apparent distress, smiling during this clinical encounter. Alleges, that he does not
know what happened. Can not explain the marks on his neck. Responded: "I don't know".
He does not want to talk of the events leading to the marks on his neck.
He does not look in any distress or pain.
Has an circular line of erythema at the base of the neck. Reaching 2/3 of the neck circumference, 2 inches wide, sparing
the back of the neck. Has one section of this erythema in the front with marks of friction.
No inflammation, no deformities, no hematomas, no lacerations, no tenderness. Patient moving his neck without any
restriction. Denies having any pain or discomfort. Denies any respiratory problem.
Has another small erythema on left knee about 2cm in diameter(mild).
As per information from custody staff inmate Epstein was found in his cell with a rope around his neck and sitting on the
floor.
Inmate is currently placed on suicide watch.
ASSESSMENT:
Injury, unspecified, T1490 Current - R/O self inflicted injuries.
PLAN:
Disposition:
Follow-up at Sick Call as Needed
Placed on Suicide Watch
Follow-up in 2-4 Hours
Other:
For follow up with psychology service.
Patient Education Topics:
Date Initiated Format
Handout/Topic
Provider
Outcome
07/23/2019 Counseling
Access to Care
Verbalizes
Understanding
07/23/2019 Counseling
Plan of Care
Verbalizes
Understanding
Copay Required:
Cosign Required: Yes
Telephone/Verbal Order: No
Completed by
on 07/23/2019 09:05
Requested to be cosigned by
MD.
Cosign documentation will be displayed on the following page.
Generated 07/23/2019 09:05 by
Bureau of Prisons - NYM
Page 2 of 2
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UNITEL TATES GOVERNMENT
DEPARTMENT OF JUSTICE
Memorandum
FEDERAL BUREAU OF PRISONS
FEDERAL BUREAU OF
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
July 23, 2019
MEMORANDUM FOR ALL CONCERNED
FROM:
Operations Lieutenant
SUBJECT:
Possible Suicide Attempt
On July 23, 2019 at approx. 1:27 a.m., a call for assistance on the Special Housing Unit
was announced by the Control Center. Upon my arrival I was informed that an inmate
had attempted suicide and proceeded to cell, Z05-124LAD. I observed inmate
Epstein, Jeffrey #76318-054 lying in the fetal position on the floor of his cell wearing a
t-shirt and boxers. He was breathing heavily and was snoring. I called out to inmate
Epstein and observed him flicker his eyes and continue snoring. His neck was red
with no abrasions. I observed no further injuries to his person. An attempt was made
to get the inmate to stand on his own with negative results. The inmate was placed in
hand restraints and staff was directed to retrieve the stretcher. As inmate Epstein was
being placed on the stretcher by responding staff, he would open his eyes and observe
staff. When staff made eye contact with him, he would hurriedly shut his eyes. The
inmate was taken to HA-Unit, dressed in the suicide smock and placed on suicide
watch. While awaiting the arrival of an inmate companion, inmate Epstein sat on the
edge of the bed and began moving forward as if he was attempting to fall over head
first. When I looked away, he straightened up. As I turned to look at him again, he
attempted the same act. I laid him down on the bed and directed him to cease his
action or he would be placed in restraints for his safety. At that moment, he stated,
"Okay, I won't do it again," and gave the thumbs up. Because of his unpredictable
behavior, the decision was made to have a staff member observe inmate Epstein. I
left HA-Unit in order to make staff notifications. Moments later, I spoke with Officer
Clarke who stated that inmate Epstein was alert and had indicated that his cellmate,
had attempted to kill him and had been harassing
him. He stated that the inmate had indicated that he'd informed his attorney of this
matter.
I photographed and spoke with inmate
who stated
that he was asleep with his headphones on when he felt something hit his legs and
said, "Jeff, what you're doing?" He didn't answer, so he got up, turned on the light and
saw him with a string around his neck. He stated that he then called the guards and
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they ran down. Upon questioning, inmate
Clated that he sleeps on
the bottom bunk, but gave it to inmate Epstein because he's old. He stated that he
sleeps on the floor on a mattress. He stated that when he got up, he couldn't
remember if he sat up or stood up to check on Epstein. He stated that Epstein was
sitting on the floor leaning to the side with his eyes opened, but wasn't responding. He
stated that the last time he saw him he was snoring really loud.
Inmate Epstein stated that he came in from a legal visit at approx. 8:00PM and staff
handed him a copy of the Daily News.
was on the floor reading the Daily News.
He stated that he had given it to him. He stated that
mentioned that he'd
been in court all day in Westchester and was carrying on. At that point, inmate
paused as if he was making the story up as he went along, and stated that
stated, "These fucking niggers. This place is inhumane, I wish I could
report it.
(Officer), that nigger hobbit mother fucker." He then turned to a page in
the Daily News that had his picture on it and stated that Epstein was worth seventy
seven million dollars. Epstein stated that he took his picture, balled it up and threw it in
the garbage. I asked inmate Epstein what happened prior to staff's arrival. He stated
that at approx. 1:00 AM, he'd gotten up to get a drink of water, as he gets up every
thirty minutes. He remember walking back to his bunk and waking up with staff there
in his cell. I asked if he'd waken up and seen staff, why didn't he respond when we
were calling out to him? He stated that he only remembered hearing himself making a
noise like snoring. When asked about the allegations against his cellmate, he stated
that he was told, if he hurt him, staff wouldn't care.
Duty medical,
was notified and briefed. It was determined no further
medical attention was needed. A medical assessment was not conducted at the time
of this incident, due to the fact, there was no medical staff available after 10:00 PM.
Upon the arrival of medical staff, inmate Epstein was examined and treated by, MLP
for a circular line of erythema at the base of the neck, one section on the front
with marks of friction and a small erythema on his left knee.
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Some changes were made and this is the latest. Please review and provide answers to the below - thanks.
Forwarded message
(1) Has Epstein's next of kin been notified?
(2) Did staff initiate life-saving measures when they first found Epstein at approximately 6:30 am in his cell?
(3) Did EMS or some sort of hospital staff come out to the institution, and if so, did they initiate life-saving measures at the institution?
And did EMS drive Epstein to the hospital or did BOP drive him to the hospital?
(4) Was Epstein pronounced dead by EMS (transporting folks) or instead hospital staff at 7:30 am at the hospital?
(5) Was the FBI notified? Is it being investigated as a suicide?
(6) What date did he first arrive at MCC NY on his PP37?
(7) What are his specific offense titles for which he is indicted? I believe generally the news calls it sex trafficking, but we should be as
specifically accurate based on Sentry (or the court order if we have it).
CONFIDENTIAL
SDNY_00010717
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=== Page 1 ===
To:
From:
Sent:
Sat 8/10/2019 7:43:35 PM
Subject: Fwd: Updated draft condolence letter
Updated draft condolence letter
CONFIDENTIAL
SDNY_00011141
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So far this is the documentation I have in my possession.
Associate Warden
MCC New York
150 Park Row
New York, NY 10007
NYM/AW-Programs-@bop.gov
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=== Page 1 ===
Thanks.
Associate Warden
MCC New York
New York, New York 10007
Office:
>>> NYM/InmateToPsychiatrist 8/15/2019 10:58 AM >>>
Hey AW, if you look below I have bolded and increased the size of my response
>>>
8/14/2019 4:14 PM >>>
How did you respond?
Associate Warden
MCC New York
New York, New York 10007
Office:
>>> NYM/InmateToPsychiatrist 8/14/2019 2:01 PM >>>
fyi
>>> ^!"
> 8/14/2019 11:32 AM >>>
To: OAKAFORD
Inmate Work Assignment: PLUMBING
***ATTENTION***
Please cut and paste the message indicator below into the subject line; only this indicator can be in the subject line.
b45cf89c-8580-4ec9-91a2-aaabdb84914d
Your response must come from the departmental mail box. Responses from personal mailboxes WILL NOT be delivered to
the inmate.
***Inmate Message Below***
Thats one thing you are good at...excuses not to do your job, I'm praying you're invovled with epsteins neglect and you get
fired.
Psychiatrist on 8/13/2019 2:32 PM wrote:
>
Per
I
you have been non compliant with your medication
although repeatedly educated about the importance of
medication compliance by members of the health services
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=== Page 2 ===
department whom dispense the medication. For the any
medication to be efficacious you must take it on a daily basis. As
is following your case, please reach out to medical through
sick call with any further issues. Good Day.
>>> ^!"
8/13/2019 10:46 AM >>>
To: OAKAFORD
Inmate Work Assignment: PLUMBING
I KEEP TELLING YOU PEOPLE THAT THE MEDICATION YOU GIVE ME DOESN'T WORK, THAT IT GIVES ME MIGRAINES AND
MAKES MY MOUTH TASTE LIKE METAL. YOU KEEP TELLING
WHAT TO GIVE ME, WHAT I WANT TO KNOW IS HOW YOU
DECIDE WHAT I TAKE IF YOU DONT SEE ME AND YOU DON'T TALK TO ME, YOU HAVE NO IDEA WHAT IM GOING THROUGH
BUT YOU DECIDE WHAT MEDICINE I GET,I HOPE YOU ARE INVOLVED WITH THE NEGLIGENCE OF EPSTEIN AND I HOPE YOU
ARE ONE OF THE PEOPLE FIRED YOU DESERVE IT, I DON'T SEE HOW YOU EVEN HAVE THE NERVE TO CALL YOURSELF A
DOCTOR.
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