# docs_fts_content

c1: EFTA00023709
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023709.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
(USANYS)"
,
)"
Cc:
"
(USANYS)"
Subject: RE: Epstein
Date: Fri, 30 Nov 2018 21:09:20 +0000
Importance: Normal
Will bring in five mins
From:
(USANYS)
Sent: Friday, November 30, 2018 15:57
To:
is
)
Cc:
(USANYS)
is
(USANYS)
Subject: Epstein
Bring us an opening memo today if you can.
Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
t.
EFTA00023709


c1: EFTA00024249
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024249.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Epstein Letter to the Editor
Date: Tue, 26 Nov 2019 14:25:32 +0000
For those who may have missed it, a notable letter to the editor in Sunday's NYT...
https://www.nytimes.com/2019/11/24/opinion/letters/jeffrey-epstein-prisons.html
EFTA00024249


c1: EFTA00024815
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024815.pdf
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c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Subject: RE: Agenda
Date: Fri, 06 Nov 2020 20:03:36 +0000
Same here, thank you. And thanks for the agenda!
From:
Sent: Friday, November 06, 2020 2:16 PM
To:
Cc:
(USANYS)
Subject: RE: Agenda
I'm open other than the two calls we have on the calendar for this case.
From:
Sent: Friday, November 6, 2020 2:13 PM
To:
Cc:
(USANYS)
Subject: Re: Agenda
What time works for everyone on Wednesday afternoon?
Sent from my iPhone
On Nov 6, 2020, at 2:12 PM,
wrote:
Thanks very much,
This all looks right to me and makes sense. If we are pushing this past Monday, I'd ask that it
be Wednesday afternoon, or anytime Thursday, please. I've got a lengthy grand jury presentation to make on Tuesday.
From:
Sent: Friday, November 6, 2020 2:09 PM
To:
is
(USANYS)
Subject: Agenda
Team,
In preparation for our call (which we can reschedule to a time following the discovery deadline), I wanted to send
around a list of topics to discuss for potential next steps. I'm sure I've missed some items, but this is a starting point at a
least.
For context, I think we currently expect to call at least the following witnesses at trial:
EFTA00024815

=== Page 2 ===
*Records custodian from
*Records custodian from
*Court reporter(s) from
*We haven't identified/spoken to these witnesses yet, so that's on the trial prep to-do list as well.
The following are some potential next steps - either individuals to interview or re-interview, records to search
for/identify, and so forth.
Relativity review of GM emails
Identify an
employee (likely retired) who managed donor relations with Epstein/can authenticate
documents
Identify a PBPD detective who can authenticate items recovered from search of PB house
Talk to
to make sure
has searched all her emails for relevant communications
Potentially interview
client
Potentially re-interview
Meet with
Interview
Interview
Interview
Re-interview
Interview
Review victim interview notes and interview any outcry witnesses we haven't spoken to yet, including
Interview
Investigate immigration records/travel records re:
Re-interview
(with counsel)
Interview
Review deposition transcripts for GM (keeping in mind SOL is approaching)
Tip-line leads that
flagged
Assistant United States Attorney
Southern District of New York
EFTA00024816


c1: EFTA00025227
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025227.pdf
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=== Page 1 ===
From:
To:
Subject: RE: accidentally forwarding
Date: Thu, 26 Sep 2019 17:36:43 +0000
Thank you. The only way I could get the Epstein victim calls to you and the team was to have Outlook search for a certain
string in the subject that included my telephone. This was someone responding to a voice message I left earlier. The
subject of the email he received included my number.
From:
Sent: Thursday, September 26, 2019 1:10 PM
To:
Subject: accidentally forwarding
I think I might be getting your emails accidentally forwarded (along with the Epstein team). This happened a few
weeks ago as well. No worries, but I wanted to let you know.
Assistant United States Attorney
Southern District of New York
EFTA00025227


c1: EFTA00025551
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025551.pdf
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=== Page 1 ===
UNITED STATES COURT OF APPEALS
FOR THE
SECOND CIRCUIT
At a Stated Term of the United States Court of Appeals for the Second Circuit, held at the
Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the
2nd day of June, two thousand twenty-one.
Before:
Pierre N. Leval,
Raymond J. Lohier, Jr.,
Richard J. Sullivan,
Circuit Judges.
United States of America,
ORDER
Appellee,
Docket Nos. 21-58(L), 21-770(Con)
V.
Ghislaine Maxwell, AKA Sealed
Defendant 1,
Defendant - Appellant.
Appellant renews her request for pretrial release. In the alternative, she requests that the
Court remand this matter to the district court to conduct an evidentiary hearing on the conditions
of her confinement. The Government opposes the motion.
IT IS HEREBY ORDERED that the motion is DENIED.
For the Court:
Catherine O'Hagan Wolfe,
Clerk of Court
UNITED STATES
SECOND
Catherine
CIRCUIT
OF
EFTA00025551


c1: EFTA00024311
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024311.pdf
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=== Page 1 ===
Signature Page Summary
Montpelier Trust
Account Number and Description
Signature Requirement
RMA Domestic - Trust
Client Relationship Agreement
RMA Domestic - Trust
Client Relationship Agreement
RMA Domestic - Trust
Client Relationship Agreement
de 0055 688 1375 11/14/2018
Package ID: 0265007453
1
EFTA00024311

=== Page 2 ===
Intentionally Left Blank
de 0055 688 1376 11/14/2018
EFTA00024312

=== Page 3 ===
Client Information
Client Information
Client Information
Montpelier Trust
Trust Information
U.S. Federal law requires us
Trust Type
Irrevocable Trust
to obtain, verify and record
information that identifies
Name
Montpelier Trust
each person or entity
Jurisdiction
US Trust
that opens an Account with
us. When you open an
Date Established
07/31/2018
Account, we will ask for
Name of All Trustees
your name, street address,
date of birth and a tax
Christine Yvonne Malina-Maxwell
identification number, such
as a Social Security number.
Jeffrey W. Roberts
We may also ask to see a
Scott Borgerson
driver's license or other
documents that will allow
Name of All Grantors
us to identify you.
Ghislaine Maxwell
Please review and verify all
of the information that you
provided to us when you
Client Contact Information
opened your Account. If
you have changes,
corrections or additions,
Residential Address
ATTN: Nutter McClennen & Fish
notify your Financial Advisor
LLP
as soon as possible.
City, State, Zip Code
Boston, MA 02210-2698
If you share assets with
Home Phone
another person, the net
worth figure here shows
E-mail Address
your portion only, based
upon instructions you
Net Worth Information
provided.
Annual Income
Range from $200,000 $499,999
Investment Information:
This section reflects answers
Liquid Assets (cash and marketable securities)
Range from $10,000,000 AND ABOVE
you provided related to
Net Worth (excluding primary residence)
Range from $10,000,000 AND ABOVE
your investment experience,
market knowledge and
Federal Marginal Tax Rate
37% and above
other assets and is used to
ensure our investment
You have indicated that you do not derive a substantial amount of your income / wealth (over 50%) from a
recommendations are
country outside of the United States.
suitable for your situation.
Investment Information
Years you have held investment accounts
None
Individual Stocks
None
Equities
None
Bonds
None
Futures
None
Options-Buy
None
Options-Sell
None
Knowledge of investments
None
Percentage of total investable assets held at UBS
More than 80%
Affiliations
Affiliated with securities firms or broker/dealer?
No
You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly
traded corporation.
3
3
EFTA00024313

=== Page 4 ===
Client Information
Client Information
Christine Yvonne Malina-Maxwell
Personal Information
U.S. Federal law requires us
Name
Christine Yvonne Malina-Maxwell
to obtain, verify and record
information that identifies
Citizenship
United States
each person or entity
Gender
Female
that opens an Account with
us. When you open an
Date of Birth
Account, we will ask for
Marital Status
Married
your name, street address,
date of birth and a tax
identification number, such
as a Social Security number.
Client Contact Information
We may also ask to see a
driver's license or other
Residential Address
documents that will allow
us to identify you.
City, State, Zip Code
Dallas, TX 75206-4307
Please review and verify all
Home Phone
of the information that you
E-mail Address
provided to us when you
opened your Account. If
you have changes,
Net Worth Information
corrections or additions,
notify your Financial Advisor
You have indicated that you do not derive a substantial amount of your income / wealth (over 50%) from a
as soon as possible.
country outside of the United States.
If you share assets with
another person, the net
Investment Information
worth figure here shows
Years you have held investment accounts
7
your portion only, based
upon instructions you
Individual Stocks
None
provided.
Equities
None
Investment Information:
Bonds
None
This section reflects answers
you provided related to
Futures
None
your investment experience,
market knowledge and
Options-Buy
None
other assets and is used to
Options-Sell
None
ensure our investment
recommendations are
Knowledge of investments
You have indicated you have a good understanding
suitable for your situation
of financial markets and market investments.
Percentage of total investable assets held at UBS
None
Affiliations
Affiliated with securities firms or broker/dealer?
No
You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly
traded corporation.
4
4
EFTA00024314

=== Page 5 ===
Client Information
Client Information
Jeffrey W. Roberts
Personal Information
U.S. Federal law requires us
Name
Jeffrey W. Roberts
to obtain, verify and record
information that identifies
Citizenship
United States
each person or entity
Gender
Male
that opens an Account with
us. When you open an
Date of Birth
Account, we will ask for
Marital Status
Married
your name, street address,
date of birth and a tax
identification number, such
as a Social Security number.
Client Contact Information
We may also ask to see a
Residential Address
driver's license or other
documents that will allow
City, State, Zip Code
Wenham, MA 01984-1464
us to identify you.
Home Phone
Please review and verify all
E-mail Address
of the information that you
provided to us when you
opened your Account. If
Net Worth Information
you have changes,
corrections or additions,
You have indicated that you do not derive a substantial amount of your income / wealth (over 50%) from a
notify your Financial Advisor
country outside of the United States.
as soon as possible.
Investment Information
If you share assets with
another person, the net
Years you have held investment accounts
12
worth figure here shows
your portion only, based
Individual Stocks
None
upon instructions you
Equities
None
provided.
Bonds
None
Investment Information:
This section reflects answers
Futures
None
you provided related to
Options-Buy
None
your investment experience,
market knowledge and
Options-Sell
None
other assets and is used to
ensure our investment
Knowledge of investments
You have indicated you are an experienced investor
recommendations are
in financial markets and market investments.
suitable for your situation.
Percentage of total investable assets held at UBS
None
Affiliations
Affiliated with securities firms or broker/dealer?
No
You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly
traded corporation.
5
5
EFTA00024315

=== Page 6 ===
Client Information
Client Information
Scott Borgerson
Personal Information
U.S. Federal law requires us
Name
Scott Borgerson
to obtain, verify and record
information that identifies
Citizenship
United States
each person or entity
Gender
Male
that opens an Account with
us. When you open an
Date of Birth
Account, we will ask for
Marital Status
Single
your name, street address,
date of birth and a tax
identification number, such
as a Social Security number.
Client Contact Information
We may also ask to see a
Residential Address
driver's license or other
documents that will allow
City, State, Zip Code
Boston, MA 02108-1433
us to identify you.
Home Phone
Please review and verify all
E-mail Address
of the information that you
provided to us when you
opened your Account. If
Net Worth Information
you have changes,
corrections or additions,
You have indicated that you do not derive a substantial amount of your income / wealth (over 50%) from a
notify your Financial Advisor
country outside of the United States.
as soon as possible.
Investment Information
If you share assets with
another person, the net
Years you have held investment accounts
22
worth figure here shows
your portion only, based
Individual Stocks
None
upon instructions you
Equities
None
provided.
Bonds
None
Investment Information:
This section reflects answers
Futures
None
you provided related to
Options-Buy
None
your investment experience,
market knowledge and
Options-Sell
None
other assets and is used to
ensure our investment
Knowledge of investments
You have indicated you are an experienced investor
recommendations are
in financial markets and market investments.
suitable for your situation.
Percentage of total investable assets held at UBS
None
Affiliations
Affiliated with securities firms or broker/dealer?
No
You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly
traded corporation.
6
6
EFTA00024316

=== Page 7 ===
Client Information
Client Information
Ghislaine Maxwell
Personal Information
U.S. Federal law requires us
Name
Ghislaine Maxwell
to obtain, verify and record
information that identifies
Citizenship
United States
each person or entity
Gender
Female
that opens an Account with
us. When you open an
Date of Birth
12/25/1961
Account, we will ask for
Marital Status
Single
your name, street address,
date of birth and a tax
identification number, such
as a Social Security number.
Client Contact Information
We may also ask to see a
driver's license or other
Residential Address
documents that will allow
us to identify you.
City, State, Zip Code
Boston, MA 02114-3252
Please review and verify all
Mobile
of the information that you
E-mail Address
provided to us when you
opened your Account. If
you have changes,
Employment Information
corrections or additions,
notify your Financial Advisor
Employment Status
Employed
as soon as possible.
Occupation
Other
If you share assets with
Occupation Industry
Other
another person, the net
worth figure here shows
Employer Name
The TerraMar Project
your portion only, based
Business Address
116 E 65th Street
upon instructions you
provided.
City, State, Zip Code
New York, NY 10065 7007
Investment Information:
This section reflects answers
Net Worth Information
you provided related to
Annual Income
Range from $200,000 $499,999
your investment experience,
market knowledge and
Liquid Assets (cash and marketable securities)
Range from $10,000,000 AND ABOVE
other assets and is used to
ensure our investment
Net Worth (excluding primary residence)
Range from $10,000,000 AND ABOVE
recommendations are
Federal Marginal Tax Rate
37% and above
suitable for your situation.
You have indicated that you do not derive a substantial amount of your income / wealth (over 50%) from a
country outside of the United States.
Investment Information
Years you have held investment accounts
23
Individual Stocks
None
Equities
23
Bonds
23
Futures
7
Options-Buy
12
Options-Sell
12
Knowledge of investments
You have indicated you are an experienced investor
in financial markets and market investments.
Percentage of total investable assets held at UBS
Less than 20%
Other
Own Home or Rent?
Own
Affiliations
Affiliated with securities firms or broker/dealer?
No
You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates.
7
7
EFTA00024317

=== Page 8 ===
Client Information
You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly
traded corporation.
Client Information
8
8
EFTA00024318

=== Page 9 ===
Account Information
Account Information
Account Information
RMA Domestic TRUST
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Montpelier Trust
Advisor immediately if you
have any changes or
ATTN: Nutter McClennen & Fish
Account Address
corrections.
LLP
City, State zip
Boston, MA 02210-2698
For more information, please
refer to the UBS Deposit
Account Sweep Program
Disclosure Statement
Cards and Checks for this account, if requested, will
ATTN Nutter McClennen
be mailed to this address:
and Fish LLP
Please note: the account risk
Boston, MA 02210-2695
profile and investment
objective below are specific only
Primary Account Holder
Montpelier Trust
to this account: other accounts
may have different account risk
UBS will not disclose your name, address and security
profiles and investment
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
objectives.
Account.
Your Account Risk Profile for
Margin
No
this particular account is defined
as:
If you did not choose Margin when you opened this account, you may ask to establish margin by
Aggressive Willing to accept
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
high risk to principal and high
Account Opening Process package will govern your use of margin in this account and all other
volatility to seek high returns over
time.
accounts you have now or may open in the future.
Different accounts may have
different risk profiles
Cost Basis Method
First In,First Out
Your Investment Objective,
Features and Services
Achieve Capital Appreciation:
Investments seeking growth of
Premier- RMA / BSA
principal rather than the
generation of income.
Account Objectives and Risk Profile
A senior political official is
Account Risk Profile
Aggressive/Speculative
defined as a President or Vice
Your answers to our profiling questions:
President, Cabinet Member,
Risk Tolerance
Supreme Court Justice,
High Risk
member of the Joint Chief's
Investment Objective
Achieve capital appreciation (emphasis on growth of
Staff, Member of Congress or
capital, not on income)
a Parliament, Chairperson,
Head or Senior Leader of a
Risk/Return Objectives
Higher Fluctuations, Higher Returns
major religious organization,
or the like.
Investment Time Horizon
Longer than 10 years (through several market cycles)
Short-Term Liquidity Needs
No
Sweep Account Election
Primary Sweep Fund
RMA GOVERNMENT MONEY MARKET FD
Sweep Cap Election
No
You have indicated that all beneficiaries for this trust are individuals (natural persons) or not-for-profit
organizations.
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Other Income Source
transfer
9
9
EFTA00024319

=== Page 10 ===
Account Information
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Account Information
Conditions of this service.
E-mail Address
Anticipated Activity
According to our records, you have indicated the following expected activity in your account.
Anticipate depositing funds from third parties into account
No
Anticipate withdrawing from account to pay / transfer to third parties
No
10
10
EFTA00024320

=== Page 11 ===
Account Information
Account Information
RMA Domestic TRUST
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Montpelier Trust
Advisor immediately if you
have any changes or
ATTN: Nutter McClennen & Fish
Account Address
corrections.
LLP
City, State zip
Boston, MA 02210-2698
For more information, please
refer to the UBS Deposit
Account Sweep Program
Disclosure Statement
Cards and Checks for this account, if requested, will
ATTN Nutter McClennen
be mailed to this address:
and Fish LLP
Please note: the account risk
Boston, MA 02210-2695
profile and investment
objective below are specific only
Primary Account Holder
Montpelier Trust
to this account other accounts
may have different account risk
UBS will not disclose your name, address and security
profiles and investment
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
objectives.
Account.
Your Account Risk Profile for
Margin
No
this particular account is defined
as:
If you did not choose Margin when you opened this account, you may ask to establish margin by
Aggressive Willing to accept
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
high risk to principal and high
Account Opening Process package will govern your use of margin in this account and all other
volatility to seek high returns over
time.
accounts you have now or may open in the future.
Different accounts may have
different risk profiles
Cost Basis Method
First In,First Out
Your Investment Objective,
Features and Services
Achieve Capital Appreciation:
Investments seeking growth of
Premier- RMA / BSA
principal rather than the
generation of income.
Account Objectives and Risk Profile
A senior political official is
Account Risk Profile
Aggressive/Speculative
defined as a President or Vice
Your answers to our profiling questions:
President, Cabinet Member,
Risk Tolerance
High Risk
Supreme Court Justice,
member of the Joint Chief's
Investment Objective
Achieve capital appreciation (emphasis on growth of
Staff, Member of Congress or
capital, not on income)
a Parliament, Chairperson,
Head or Senior Leader of a
Risk/Return Objectives
Higher Fluctuations, Higher Returns
major religious organization,
or the like.
Investment Time Horizon
Longer than 10 years (through several market cycles)
Short-Term Liquidity Needs
No
Sweep Account Election
Primary Sweep Fund
RMA GOVERNMENT MONEY MARKET FD
Sweep Cap Election
No
You have indicated that all beneficiaries for this trust are individuals (natural persons) or not-for-profit
organizations.
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Other Income Source
transfer
11
11
EFTA00024321

=== Page 12 ===
Account Information
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Account Information
Conditions of this service.
E-mail Address
Anticipated Activity
According to our records, you have indicated the following expected activity in your account.
Anticipate depositing funds from third parties into account
No
Anticipate withdrawing from account to pay / transfer to third parties
No
12
12
EFTA00024322

=== Page 13 ===
Account Information
Account Information
RMA Domestic TRUST
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Montpelier Trust
Advisor immediately if you
have any changes or
ATTN: Nutter McClennen & Fish
Account Address
corrections.
LLP
City, State zip
Boston, MA 02210-2698
For more information, please
refer to the UBS Deposit
Account Sweep Program
Disclosure Statement
Cards and Checks for this account, if requested, will
ATTN Nutter McClennen
be mailed to this address:
and Fish LLP
Please note: the account risk
Boston, MA 02210-2695
profile and investment
objective below are specific only
Primary Account Holder
Montpelier Trust
to this account other accounts
may have different account risk
UBS will not disclose your name, address and security
profiles and investment
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
objectives.
Account.
Your Account Risk Profile for
Margin
Yes
this particular account is defined
as:
You have agreed that the Margin Agreement in the Completing Your Account Opening Process
Moderate Willing to accept
some risk to principal and tolerate
package governs your use of margin in this account and all other accounts you have now or any
some volatility to seek higher
accounts that you may open in the future. As described in the Margin Agreement, certain securities
returns.
in your Account may be loaned to UBS or to other persons or entities.
Different accounts may have
different risk profiles
Cost Basis Method
First In,First Out
Your Investment Objective,
Produce a Combination of
Features and Services
Income and Capital
Appreciation: Investments
Premier- RMA / BSA
seeking both the generation of
income and growth of principal.
In accounts with conservative
Account Objectives and Risk Profile
or moderate risk profiles,
investment eligibility
Account Risk Profile
Moderate
considerations help us
Your answers to our profiling questions:
identify whether you may be
Risk Tolerance
Moderate Risk
eligible to invest in certain
higher risk securities as a
Investment Objective
Produce a combination of income and capital
portion of your portfolio.
These investments offer
appreciation
additional diversification.
Risk/Return Objectives
Moderate Fluctuations, Moderate Returns
A senior political official is
Investment Time Horizon
7 10 years
defined as a President or Vice
President, Cabinet Member,
Short-Term Liquidity Needs
No
Supreme Court Justice,
Sweep Account Election
member of the Joint Chief's
Staff, Member of Congress or
Primary Sweep Fund
RMA GOVERNMENT MONEY MARKET FD
a Parliament, Chairperson,
Head or Senior Leader of a
Sweep Cap Election
No
major religious organization,
or the like.
You have indicated that all beneficiaries for this trust are individuals (natural persons) or not-for-profit
organizations.
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Other Income Source
transfer
13
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Account Information
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Account Information
Conditions of this service.
E-mail Address
Anticipated Activity
According to our records, you have indicated the following expected activity in your account.
Anticipate depositing funds from third parties into account
No
Anticipate withdrawing from account to pay / transfer to third parties
No
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=== Page 15 ===
UBS CLIENT RELATIONSHIP AGREEMENT
Terms and Conditions of your current and future Accounts
UBS Client Relationship Agreement
This Client Relationship Agreement, as well as the Agreements and Disclosures booklet and the
This column contains important definitions
agreements for the products and services offered by UBS, any other agreements and
applicable to our Agreement with you
disclosures that we make available to you and amendments thereto, and any other UBS forms
you sign outlines the terms and conditions of your relationship with us. These documents are
We refer to the Client Relationship
collectively referred to as "Agreement" and incorporated by reference herein and form the
Agreement together with all other
entire agreement between us with respect to your Accounts. Copies of these documents are
agreements and disclosures that we make
available at www.ubs.com/accountdisclosures
available to you, and any amendments, as
our "Agreement" with you for your
Accounts.
By maintaining your Account(s) at UBS, you agree to the terms and conditions in the
Agreement.
"Accounts" refers to all securities accounts,
brokerage accounts, margin accounts,
To confirm that our records are accurate, after you open an Account we will send you a record
deposit accounts, or other accounts you
of the information you provided to us.
open with UBS Financial Services Inc. or
UBS Financial Services Incorporated of
Please retain these documents for future reference since they contain important information
Puerto Rico now or in the future.
regarding your Accounts.
This Agreement applies to all of your Accounts including your existing Accounts and
We also refer to the "Completing Your
any Accounts you may open in the future at UBS Financial Services Inc., UBS Financial
Account Opening Process" package, which
Services Incorporated of Puerto Rico or any other introducing broker-dealer that has a clearing
includes Signature Pages, optional forms
agreement with UBS Financial Services Inc. As a result, some of the information in the
and other required documents.
Agreement may not apply to you now.
"Signature Page* includes both the
You may be able to open additional Accounts or add services and features without signing
Signature Page in the Completing Your
Account Opening Process Package and the
additional agreements. In such instances, upon approval of your Accounts, features and/or
Account Application and Agreement
services, we will confirm your requests in writing and send you any updates or amendments to
Signature Page.
the Agreement and any disclosures you have not already received. Any authorization of
features and services you give us will remain in effect until a reasonable time after you notify
Please have all named account holders sign
us to terminate the feature or service.
the Signature Page and return it to us.
Your initial acceptance of the Agreement and your continued use of your UBS Accounts will
"You," "your" and "yours" refer to you as a
serve as your agreement to the application of the Agreement including any updates and
client of UBS. "UBS," "we," "us," "our" and
amendments to all of your Accounts.
"ours" refer to UBS Financial Services Inc.
and unless we indicate otherwise in this
The accounts and services we offer may change over time. We may change our Agreement
Agreement, its successor firms, subsidiaries,
with you at any time by sending you a written notice of the change, and the changes will be
correspondents and Affiliates, including its
effective on the date of the notice unless we specify a later date. We also may cease to offer
parent company, UBS AG.
services at any time without prior notice. Your continued use of your Accounts and our
"Affiliates" refers to UBS Financial Services
products and services constitutes your acceptance of the new terms and conditions. If you do
Incorporated of Puerto Rico (which clears
not agree to the terms and conditions, you may cancel the applicable feature or service or
through UBS Financial Services Inc.), UBS
close your Account. All changes by you to the Agreement will become effective only if offered
Bank USA, UBS Credit Corp., and their
in writing and signed by us.
insurance agency affiliates and subsidiaries
and all other subsidiaries and affiliates.
Your UBS Accounts do not permit you to engage in certain types of transactions such as those
involving a commodity interest or options, unless and until you complete additional
agreements with us specifically permitting those transactions.
Your Relationship with Us
As a wealth management firm providing services to clients in the United States, UBS Financial
Services Inc. is registered with the U.S. Securities and Exchange Commission (SEC) as a
broker-dealer and an investment adviser, offering both brokerage and investment advisory
services.
de 0055 695 1389 11/14/2018
When we act as a broker-dealer, we will effect transactions for your brokerage Accounts only as
instructed by you, and neither UBS nor your Financial Advisor will have any discretion over your
Accounts.
When we act as an investment adviser, we have a fiduciary relationship with you under the
Investment Advisers Act of 1940. Separate rules and regulations apply to fiduciaries of
retirement accounts under the Employee Retirement Income Security Act of 1974 (ERISA), or the
Internal Revenue Code of 1986, as amended (Code). Information on whether we have a
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=== Page 16 ===
UBS Client Relationship Agreement
fiduciary relationship to your retirement accounts under ERISA or the Code in your brokerage or
advisory accounts and other important disclosures are provided at
www.ubs.com/retirementplandisclosures. Your Financial Advisor will provide a paper copy of
this information to you at no charge upon request. Please also review the Conducting Business
with UBS section in the Agreements and Disclosures Booklet.
Representations
By your signature agreeing to this Client Relationship Agreement and/or your maintaining
If you have received a Completing Your
Account(s) at UBS, you make the following representations:
Account Opening Process Package, please
8 You are at least 18 years old or have reached the age of majority according to the
review and verify the information about
laws of the jurisdiction in which you reside and the laws of the State of New York.
you and your Accounts. If you have
questions, changes or corrections, please
8
You have notified us, as required by law, if you, your spouse, your immediate family
call your Financial Advisor.
or any beneficial owner of the Account(s) are or become employed by or affiliated
with any of the following: a member firm of FINRA or other exchange, or securities
or commodities exchange, self-regulatory organization, financial institution or any
of their affiliated organizations or UBS's independent auditor. You agree to notify
us promptly of any changes. You agree that UBS may provide duplicate account
statements or confirmations to such entity.
8 You and any other individuals who sign on behalf of the named account holder
have the authority to open the Account and effect all transactions and other
investments for the Account. If you sign the Client Relationship Agreement as a
guardian, executor, trustee or on behalf of an entity, you further represent that you
have the authority to execute such an Agreement. If we receive conflicting or
inconsistent instructions from any persons authorized on the Account, you agree
that we may refrain from taking any action with respect to the Account until the
conflict is resolved, as determined in our sole discretion.
8 If you are an entity, that the entity is duly authorized to conduct business in the
jurisdiction from which it transacts business.
8 No one other than you, and the individuals identified to UBS in connection with the
opening of the Account, has or will have an interest in your Account unless you
notify us in writing and UBS Financial Services Inc. agrees to continue to carry the
Account.
8 All of the personal and financial information you have provided to UBS is true and
accurate, and you will notify UBS promptly of any material changes, particularly the
information regarding your residence, financial situation, investment objectives or
tax status.
8 You understand that UBS provides financial and investment services only and does
not provide legal or tax advice.
8
You represent that all reporting and tax associated obligations, including
compliance with foreign investment and exchange control rules, have been and will
continue to be fulfilled by you and all beneficial owners in the relevant jurisdictions,
as applicable, with respect to any assets deposited or held in the Accounts.
8
If you are acting as executor, trustee, conservator, guardian, custodian or other
fiduciary such as an employer of an employer-sponsored SEP or SIMPLE Plan.
-
You understand that you are a fiduciary on behalf of the beneficial owners of
the Account(s) and that you have a duty to use the services and features
provided through the Account for the benefit of the beneficial owners of the
Account and not for your own benefit.
de 0055 695 1390 11/14/2018
-
You acknowledge that you will make an independent determination that any
activity in the Account is suitable, complies with any investment restrictions or
guidelines under applicable law and is appropriate for the beneficial owners
and that the compensation we receive is reasonable.
-
You will not use the UBS Account statement as a substitute for any accounting
or other information you are required to send to the principal, grantors,
beneficial owners or to others.
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=== Page 17 ===
Fees and Charges
As a client of UBS, you agree to pay all fees and charges relating to your Accounts for any
Please refer to the Fees and Charges
transactions or services you receive from us, such as annual service fees, brokerage fees for
section of the Agreements and Disclosures
securities transactions, fees for specific services you request, IRA custodial account fees and
booklet and the Understanding our fees,
fees or charges by a third party that we incur in the course of providing services to you.
charges and other compensation brochure
which is available at
UBS Client Relationship Agreement
www.ubs.com/accountdisclosures for more
All fees and charges are subject to change at any time. Fees and charges will be charged to
information about fees and charges. If you
your Accounts and may be satisfied, along with any other amounts you owe us, from free
have questions, please contact your
credit balances, margin and other assets in any of your Accounts. We may sell assets in your
Financial Advisor.
Account to satisfy debit balances for any amounts due, including those resulting from unpaid
fees and charges.
Joint Accounts
For joint accounts, each person or entity named on the Account has full power and authority
over the Account, and the account holders are jointly and severally liable for all obligations
with respect to the Account. Please refer to the "Joint Accounts" section of the General Terms
and Conditions of the Agreements and Disclosures booklet for more information about the
terms and conditions that apply to joint accounts.
International Accounts
Please note that not all products and services are available in all countries and may be changed
The features and fees of your International
from time to time.
Resource Management Account are more
fully described in the Agreements and
In connection with a certification regarding purchases made in reliance on Regulation S,
Disclosures booklet.
including off-shore mutual fund purchases, the definition of a U.S. Person is: 1) any resident of
the United States; 2) any partnership or corporation organized in or under the laws of the
United States; 3) any estate or trust in which the executor, administrator or trustee is a U.S.
person and/or if the income from the estate or trust is subject to U.S. federal income taxation
(regardless of the source of the income); 4) any corporation, partnership, estate, trust or other
entity that is directly or indirectly controlled by one or more of the above categories of U.S.
Persons; 5) any agency or branch of a foreign entity that is located in the U.S.; 6) any
non-discretionary account (other than an estate or trust) held by a dealer or other fiduciary for
the benefit or account of a U.S. Person; 7) any discretionary account (other than an estate or
trust) held by a dealer or fiduciary that is a U.S. Person, not including those held for the benefit
of a non-U.S. Person; 8) certain partnerships or corporations that are organized or
incorporated under the laws of any non-U.S. jurisdiction that have formed principally for the
purpose of investing in securities not registered under the U.S. Securities Act of 1933; and 9)
any other person or entity considered a U.S. Person for purposes of Regulations under the U.S.
Securities Act of 1933.
Individual Retirement Accounts
The Agreements and Disclosures booklet contains the UBS IRA Custodial Agreements and the
The features and fees of your IRA are fully
IRA Disclosure Statements that apply to any Traditional, Roth, SEP or SIMPLE Individual
described in the Agreements and
Retirement Accounts (IRAs) you open with us now or in the future. If we make changes to the
Disclosures booklet.
UBS IRA Custodial Agreement and the IRA Disclosure Statement, we will notify you of the
updates and you agree to be subject to those updated terms and conditions.
Please note: UBS does not extend margin
for Individual Retirement Accounts.
According to the UBS IRA Custodial Agreements, UBS Financial Services Inc. is named as the
custodian of your IRA when we accept the Account.
Employers with a SEP IRA or SIMPLE IRA
Beneficiaries must be named in writing. You may apply your written beneficiary designation to
plan for their businesses must sign a
your future IRA accounts, and in that case, we will confirm your designation. If you do not
separate plan document. We accept any
designate beneficiaries, or your beneficiary designation does not effectively dispose of the
approved plan documents, known as
assets, your beneficiary with respect to the IRA or any part of the IRA not effectively disposed
prototypes, whether they were produced
of, will be your surviving spouse, or your estate if you do not have a surviving spouse. If you
by UBS, an IRS model or a document from
de 0055 696 1391 11/14/2018
designate a spouse as your beneficiary, the subsequent divorce or termination of the marriage
another provider. If you would like to use a
will automatically revoke the designation. You can designate your former spouse as
UBS prototype, please ask for a copy of the
beneficiary by completing a new change of beneficiary form.
SEP IRA Plan or SIMPLE IRA Plan prototype
document from your UBS Financial Advisor.
If your IRA account is funded via transfer from another financial institution, you represent that
all transfers to such Account originate from: (1) an IRA in the same name and of the same type
(e.g. traditional, Roth); (2) an inherited IRA in the same name and of the same type; or (3) a
qualified plan account that you were entitled to rollover to an IRA.
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=== Page 18 ===
UBS Client Relationship Agreement
You agree that if you roll over assets of a qualified plan to a UBS IRA now or in the future, you
are responsible for reviewing the options available and evaluating the investment and
non-investment considerations (including fees and costs of a UBS IRA) described in the
Agreements and Disclosures Booklet and for making an independent decision with respect to
whether or not to rollover qualified plan assets to a UBS IRA.
Insurance-Only Accounts
We offer non-brokerage accounts to maintain or permit the purchase of insurance
products and services ("Insurance Accounts"). If you open an Insurance Account, you will
not have access to UBS brokerage account features including bank sweeps and trading
ability. By signing the Signature Page for your non-brokerage insurance account, you
accept the Client Relationship Agreement and the other documents referred to here, and
as a result, you may be able to open brokerage accounts with us in the future without
having to sign additional agreements.
Trustee Certification and Agreement
Representation of a Trust Agreement in Effect
For trust accounts, each Trustee certifies, represents and warrants that the trust to which this
The *UBS Client Relationship Agreement",
certification applies is in full force and effect and that the information you have supplied to
plus the additional information, terms and
UBS is true and accurate, as we rely on that information to service your Accounts.
conditions, and disclosures pertaining to
the accounts and services you have
requested UBS to establish for the Trust,
Unless we are updated subsequently by the trustees, UBS will rely on this certification, which
govern the overall relationship between the
includes the information you provide on the Signature Page or a separate Trustee Certification,
Trust and UBS.
to service your Accounts and Accounts you may open in the future for the same trust. In this
Trustee Certification and Agreement, you agree that:
00 Each trustee (or a corporate officer if the trustee is a corporate trustee) agrees to
this Trustee Certification and Agreement.
8 You have full power under the trust agreement and applicable law to submit valid
orders and other instructions relative to the trust Account(s).
8 The trust agreement authorizes you to make distributions and transfers from the
trust including transfers to the trustee(s).
8 You have received the Agreement and agree to be bound by those terms and
conditions for all Accounts opened on behalf of the trust.
00 As trustee(s), you have broad investment powers under the trust and applicable
law. You have noted any restrictions on your power as trustee(s) on the Signature
Page for the first trust account you open or on a separate Trustee Certification, and
agree that the powers and restrictions listed are accurate and complete.
Trustee's Ability to Bind the Trust
Unless you indicate otherwise on the Signature Page or on a separate Trustee Certification, you
agree that any individual trustee may independently exercise any of the trust's powers. This
means that UBS is authorized to take instructions from and accept any document on behalf of
the trust (including but not limited to agreements to arbitrate all disputes involving the trust
account) signed by any one of the trustees. You agree that UBS may, in its discretion, require
de 0055 696 1392 11/14/2018
the joint action of all trustees whenever UBS deems such joint action to be necessary or
appropriate.
In this UBS Trustee Certification and Agreement, you agree that:
8 Unless you have noted otherwise, you have the authority to pledge, mortgage,
assign or subject to a security interest or lien in favor of UBS, any property of the
trust as security for any liability of the trust or third parties (in each case, with no
limitations as to amount).
8 You have the authority under the trust agreement and applicable law to execute
any and all relevant documents and bind the trust to any agreements entered into
with respect to such activities.
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=== Page 19 ===
8
You understand that, if you have requested margin privileges on behalf of
the trust, UBS holds securities in margin-eligible trust accounts as a lien
against the amounts borrowed by the trust, and you agree to maintain
sufficient collateral in the account to meet margin calls we might issue.
Trustee's Acknowledgement
UBS Client Relationship Agreement
In this UBS Trustee Certification and Agreement, you agree that:
8
It is binding on the trust and all future trustees.
8 UBS may assume without further inquiry and is not required to confirm your power
and authority as trustee(s) or to verify instructions for the delivery of any money or
property to you as trustee(s).
8 UBS is not required to confirm that you are properly exercising your power and
authority.
Liability and Indemnification
In this UBS Trustee Certification and Agreement, you agree that:
8
UBS is acting in reliance on this certification and is not liable for Account activities
and transactions that are consistent with the representations and documentation
you have provided.
8
UBS is not required to inquire whether any transaction represents a proper exercise
of the trustees' power or authority, unless it is demonstrated that UBS had actual
knowledge that either the transaction's proceeds were being improperly used for
the trustees' benefit or that the transaction exceeded or was in breach of the
trustees' powers or authorities.
8
You fully hold UBS harmless and indemnify UBS from all losses, liabilities, damages,
claims, costs and expenses, including attorney fees resulting from UBS acting in
reliance on this certification.
8
As trustees, you are each jointly and severally liable for performing your obligations
under the UBS Trustee Certification and Agreement.
8 Your obligations and the indemnification above remain in effect if the trust is
terminated or its Accounts are transferred and shall bind all your successors and
assigns.
Duty to Update
You agree to provide UBS an updated Trustee Certification if there is any amendment to the
trust, any change in the composition of the trustees, or any other event that materially alters
the facts which you have certified and upon which we are relying to service the trust
Account(s).
If we are uncertain of the authority conferred by this certification, its continuing effectiveness,
or any other certification of the trustees, we may refrain from taking any action with respect
to the Account(s) until we are satisfied as to the authority of the trustee(s). You agree to hold
us harmless and indemnify us from any claims, demands, expenses, losses or damages if we
refrain from acting for these reasons.
Authority to Appoint/Hire Investment Adviser or Other Third Party
In this UBS Trustee Certification and Agreement, you agree that:
de 0055 697 1393 11/14/2018
8 Unless you have indicated otherwise on the Signature Page or a separate Trustee
Certification, you have the power under the trust agreement and applicable law
to appoint or hire an investment advisor or other third party to advise, manage and
have discretion with respect to the trust's assets and liabilities, and to appoint or
delegate your powers to an agent and that, in the event you appoint or hire an
investment adviser or third party or appoint an agent, you agree to provide
additional documentation to UBS as we request.
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=== Page 20 ===
UBS Client Relationship Agreement
8 You have the authority to open the trust account(s), place assets in the trust
account(s), make each and every representation and warranty set forth in this UBS
Trustee Certification and Agreement, engage in each of the actions on behalf of the
trust set forth in this certification and agreement, and execute this certification and
agreement.
8 All investment advisers or other third parties you appoint or hire to manage and/or
have discretion with respect to the trust's assets and liabilities or other agent that
you have appointed or to whom you have delegated your powers are bound by
your acknowledgements, agreements, representations and warranties in this
certification and agreement, and the obligations you have undertaken.
8 Unless you have indicated otherwise on the Signature Page or a separate Trustee
Certification, that the beneficiaries of the trust are individuals (natural persons) or
not-for-profit organizations.
Power to Amend and Revoke - Revocable Trusts Only
In this UBS Trustee Certification and Agreement, you agree that either:
8 You are the grantor of a revocable trust and you have full power and authority
under the trust agreement and applicable law to freely amend and revoke the trust,
OR
8 As a non-grantor trustee, you represent that the grantor has full power and
authority under the trust agreement and applicable law to freely amend and revoke
the trust.
Grantor Authorization for Credit Disclosure
By signing a UBS Trustee Certification and Agreement, each grantor agrees and authorizes UBS
to obtain a credit report or other verbal or written credit references about your credit history
or to verify or update credit information given to UBS.
Introduced Accounts
Accounts opened with UBS Financial Services Incorporated of Puerto Rico or any other
broker-dealer under a clearing agreement with UBS Financial Services Inc. are "introduced" to
UBS Financial Services Inc. and will be carried by UBS Financial Services Inc. in your name.
Please refer to the section titled "Introduced Accounts" in the General Terms and Conditions
of the Agreements and Disclosures booklet for a description of the services provided by your
introducing broker and by UBS Financial Services Inc.
Puerto Rico Residency Representation
If Puerto Rico investments are purchased and/or held in a UBS Financial Services Incorporated
of Puerto Rico account, each account owner, or for an account of an entity, each authorized
person(s), certifies its understanding and agreement of the following:
You may hold or purchase certain investments in your Account, including, but not limited to,
closed-end and open-end mutual funds, preferred stock and debt securities that are not
registered under the U.S. Securities Act of 1933 or the U.S. Investment Company Act of 1940
and are exempt from registration under the U.S. Securities Act of 1933 and/or the U.S.
Investment Company Act of 1940 ("Puerto Rico Investments"), based in part, on the
de 0055 697 1394 11/14/2018
requirement that they be offered or sold only to individuals who have their principal residence
in Puerto Rico and to entities whose principal office and place of business are in Puerto Rico
(*Puerto Rico Residents"), as disclosed in the respective prospectuses or offering materials. You
are aware that certain Puerto Rico Investments may not be suitable for all investors as they
may be designed primarily for long-term investors.
Accordingly, if you acquire or propose to acquire Puerto Rico Investments, you hereby
represent that:
8
You have acquired or propose to acquire Puerto Rico Investments for your own
Account and will be the beneficial owner of those assets.
8
If you propose to acquire Puerto Rico Investments for the Account of a retirement
plan that is the beneficial owner of the assets, you acknowledge that UBS may limit,
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=== Page 21 ===
in part or in total, the amount of any such purchase, whether or not the retirement
plan is subject to ERISA.
8 As of the date of this agreement: (i) you are an individual whose principal residence
is in Puerto Rico; or (ii) if organized as a non-business trust, the trust has its principal
office and principal place of business within Puerto Rico and the trustee and all
beneficiaries of the trust are Puerto Rico Residents; or (iii) if organized as a trust, the
UBS Client Relationship Agreement
trustee and all beneficiaries of the trust are Puerto Rico Residents; or (iv) if
organized as a corporation, partnership or other form of business organization, the
entity has its principal office and principal place of business within Puerto Rico and
has not been organized for the purpose of acquiring Puerto Rico Investments.
8 If you cease to be a Puerto Rico Resident, you will: (i) notify us within 30 days of
ceasing to be a Puerto Rico Resident; (ii) liquidate your holdings in any Puerto Rico
Investment when such liquidation becomes economically feasible; and (iii) not
acquire additional Puerto Rico Investments.
80 You acknowledge that if at the time of your acquisition of Puerto Rico Investments
you are not a Puerto Rico Resident, UBS may declare such acquisition null and void.
To the extent that you seek to avail yourself of any tax treatment or seek qualification under
any tax incentive program such as, for example, the Puerto Rico Export Services Act ("Act 20")
or the Puerto Rico Act to Promote the Relocation of Individual Investors ("Act 22* and
together with Act 20, collectively, the "Acts") based on Puerto Rico residency, you hereby
acknowledge that:
80 You are solely responsible for complying with all of the applicable rules and
requirements pertaining to your residency for federal and Puerto Rico tax purposes
and that neither UBS Financial Services Incorporated of Puerto Rico nor UBS AG or
any of its affiliates are making any representation as to your compliance with any
such rules and requirements or with respect to your residency for federal and
Puerto Rico tax purposes, or providing any tax advice.
8 UBS Financial Services Incorporated of Puerto Rico is relying solely on your residency
representations and shall not make any independent determination as to your
residency for federal and Puerto Rico tax purposes or any qualification under the
Acts or any other tax incentive program, or with respect to any tax benefits that
may be available under the Acts or any other federal or Puerto Rico law or
regulation.
8 While UBS Financial Services Incorporated of Puerto Rico may propose to you certain
investments that are deemed to generate Puerto Rico source income for federal and
Puerto Rico tax purposes, it is your responsibility to determine together with your
tax advisor whether these investments provide you the tax benefits you may be
seeking.
Accounts with Cash Management Features and Verbal Authorization to
Upgrade or Add Cash Management Features to an Account
UBS offers a variety of accounts with cash
management features, including the
The Agreements and Disclosures booklet contains the terms and conditions that apply to the
Resource Management Account® (RMA),
cash management features you may select. All requests to enroll in cash management features
Business Services Account BSA® (BSA) and
are subject to UBS approval.
International Resource Management
Account® (IRMA).
We may accept verbal requests to upgrade or add cash management features to your existing
Account(s) or any Account(s) you may open in the future. Generally, we permit any authorized
Cash management features available for
person to provide verbal instructions to upgrade or add services to your Account unless you
eligible accounts include:
instruct us otherwise. In some circumstances, we may ask for additional information or require
00 Check writing
you to sign additional documents.
00 Debit cards
00 Credit cards
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There are important differences in the cash management features and other services that are
00 Rewards programs
available to U.S. residents through UBS accounts and those that are available to clients who
00 Bill Payment
reside outside the U.S. The International RMA and certain of its cash management features
00 Electronic Funds Transfer
and other services are not available in all countries and may be changed at any time. We also
00 Margin Loans
have different Card programs for these accounts. This Agreement and the Agreements and
00 Sweep Features
Disclosures booklet describe which programs apply to which types of accounts.
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UBS Client Relationship Agreement
Check writing
If you enroll in the check writing feature for your Account, you authorize us and our Check
"Check Provider" is the provider and
Provider to honor checks that bear your signature(s) and unsigned drafts that are presented on
processor we have appointed to handle
the basis of separate written authorization from you to the payee. These checks may be used
payment of your checks and drafts. We
only in conjunction with your Accounts and only up to the Account's "Withdrawal Limit" as
reserve the right to change check providers
defined in the General Terms and Conditions in the Agreements and Disclosures booklet. We
from time to time.
will deduct funds from your Accounts and reimburse the Check Provider in federal funds when
checks or drafts are presented to the Check Provider. We may delay or deny payment if there
are insufficient available assets in your Account to cover payment on the day you write the
check or authorize the draft through the day on which we deduct funds from your Accounts
to pay the check or draft.
Bill Payment and Electronic Funds Transfer Services
If you enroll in the Bill Payment and Electronic Funds Transfer services, you authorize UBS and
The Bill Payment and Electronic Funds
its processing bank to effect the types of transactions described in the Bill Payment and
Transfer Service Agreement is provided in
Electronic Funds Transfer Service Agreement. This service agreement also applies to other
the Agreements and Disclosures booklet.
electronic transfers to or from your Accounts, including transfers made with the UBS
CashConnect feature and certain payments made through the Automated Clearing House
Bill payments are only available to payees
("ACH") system, even if you do not enroll in this service.
located in the U.S.
Transfers through the ACH system are only
available to and from accounts at financial
institutions and banks within the U.S.
UBS Visa Debit Card for RMA or BSA
If you choose to enroll for the UBS Visa Debit Card (Card) whether either verbally or in writing,
"Card Issuer" means UBS Bank USA, its
and for International RMA accounts, if you are eligible for the Card under applicable laws and
successors and assigns, or the issuer of UBS
UBS policies, you will be issued one or more Card(s) by the Card Issuer. UBS and the Card
Cards we appoint in our sole discretion.
Issuer will approve transactions you initiate using the Card(s) up to your Account's
"Withdrawal Limit" or such other amount as described in the Agreements and Disclosures
Your UBS Visa Debit Card(s) will be mailed
booklet.
to you under separate cover after your
Account has been approved.
You agree to maintain sufficient available assets in your account to make payment in full, and
transactions may be denied if there are insufficient assets in your Account to make full
payment for any Card transactions as they are processed. As your Card cash withdrawals are
processed, we will deduct funds from your Account to reimburse the Card Issuer. Once each
business day, we will deduct from your Account the amount of purchases made with the Card
that have been received by the Card Issuer but not yet deducted from your Account. The Card
Issuer may suspend or cancel Cards if there are insufficient assets to cover transactions. Your
use of the Card constitutes your agreement to the terms and conditions in the UBS Visa Debit
Card Cardholder Agreement, which is included in the Agreements and Disclosures booklet.
UBS Credit Card for RMA or BSA
You may apply for a UBS Visa Signature credit card or UBS Visa Infinite credit card (Credit
Your UBS Credit Card(s), if approved for
Card) either verbally or in writing. If your application is approved by the Card Issuer, you will be
issuance by the Card Issuer, will be mailed
issued one or more Credit Cards. We will bill transactions made with your Credit Card
to you under separate cover after your
separately from your eligible brokerage account. You may pay your Credit Card balance
Account has been approved.
automatically each month from your eligible brokerage account, or you may pay the bill from
other sources or allow a balance to revolve. The Credit Card terms and conditions describe
Express Delivery: If you are approved for an
rates, fees and other costs for the Credit Card. The Card Issuer will issue and manage your
account and your card was requested next
Credit Card according to Utah law and the UBS Credit Card Cardholder agreement (Credit
de 0055 698 1396 11/14/2018
day delivery, your card will be sent the next
Card Agreement). The Card Issuer will include the Credit Card Agreement with your Credit
day after your account is opened if the
Card.
request is made before 3:00 p.m. Eastern
time of that day. A signature is required for
Your use of the Credit Card constitutes your agreement to the terms and conditions in the
Express Delivery.
Credit Card Agreement, which may change occasionally. The Credit Card is not subject to the
General Terms and Conditions of this UBS Client Relationship Agreement. To fulfill your
application for a Credit Card, we will share the personal information the Card Issuer requires to
The UBS Credit Card is not available with
open your Credit Card Account, with affiliates and third parties with which we are permitted
the International RMA.
to share such information, and we similarly share your personal information such as application
data, approval status and transaction information on a regular basis to update your UBS
The Credit Card terms and conditions
describe the fees for the UBS Credit Card.
monthly account statement and our records.
When you request a Credit Card, the Card Issuer will obtain a credit report as part of your
application and after it establishes your Credit Card account, to administer your Credit Card
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account and report its credit experience with you to others. At your request, the Card Issuer
will provide the name and address of each consumer reporting agency from which it obtained
a report about you. After your Credit Card account is open, you will have the opportunity,
where legally required, to select how the Card Issuer can use or share information about you
for marketing or Credit Card account maintenance purposes.
UBS Client Relationship Agreement
Any disputes you may have with the Card Issuer will be resolved by binding Arbitration. For
more information regarding Arbitration, please consult the UBS Credit Card Agreement.
By requesting a Credit Card, you agree with the following statements:
8
I (we) am at least 18 years old and a permanent resident of the United States.
8
I (we) have reviewed and agree to the Important Information about the UBS Credit
Card Account Terms and Conditions that was provided with this Client Relationship
Agreement.
8
All information provided to UBS and the Card Issuer was truthful and complete.
Our Sweep Options and Your Sweep Election
As a service to you, we offer the automatic investment or deposit ("sweep") of available cash
Sweep Options" refers to the options made
balances in your Account to a Sweep Option.
available by UBS for the automatic
investment or deposit ("sweep") of
You authorize and direct us to deposit or invest your available cash balances on each business
available cash balances in your Account.
day in your Sweep Option or Secondary Sweep Option as applicable and to withdraw your
funds from, or liquidate your shares in your Sweep Option or Secondary Sweep Option, as
Sweep Options are subject to eligibility
described in the Agreements and Disclosures booklet, and any amendments. Such
requirements and include: the UBS Bank
authorization applies to all of your Accounts at UBS, including any Accounts you may open in
Sweep Programs (which include
the future.
"Secondary Sweep Options*), the UBS FDIC
Insured Deposit Program, the Sweep Funds,
the Puerto Rico Short Term Investment
If we have not received such authorization from you, under applicable law we will not be
Fund, Inc. ("Puerto Rico Fund") and any
permitted to begin sweeping your available cash balances into your Sweep Option. If available
other sweep investments that we may
cash balances in your Account are not swept for any reason, available cash balances will not be
offer from time to time for eligible
invested, and we are not required to pay interest on available cash balances in your Account.
accounts.
We may change or discontinue our sweep services at any time, including changing the terms
The "UBS Bank Sweep Programs"
and conditions of any sweep service and adding or discontinuing specific Sweep Options. We
collectively refers to the UBS Deposit
may establish eligibility criteria for Sweep Options offered to different clients, including, but
Account Sweep Program (the "Deposit
not limited to, establishing minimum asset requirements for clients to qualify for specific
Program") and the UBS Business Account
Sweep Options. We may move your balances to an eligible Sweep Option in the event that you
Sweep Program (the "Business
become ineligible for an existing Sweep Option.
Program"), which sweep available cash
balances to UBS Bank USA as more fully
described in the UBS Bank Sweep Programs
The yields for each Sweep Option will be different and may vary. Current yields may be
Disclosure Statement available at
obtained from your Financial Advisor or from:
www.ubs.com/accountdisclosures.
www.ubs.com/us/en/wealth/misc/accountsweepyields Each Sweep Option is subject to
different risks and account protection features.
UBS Bank USA (Member FDIC) ("Bank
USA*) is an FDIC-member bank affiliate of
UBS.
UBS Bank Sweep Programs
"Sweep Funds" refers to one or more of
Most clients will be eligible for one of the UBS Bank Sweep Programs. Unless you select
the UBS money market funds made
another available Sweep Option, if any, you consent to having available cash balances in
available as a Sweep Option or a
eligible Accounts deposited in FDIC-insured deposit accounts at UBS Bank USA through one of
Secondary Sweep Option for the UBS Bank
the UBS Bank Sweep Programs. Accounts that are not eligible for the UBS Bank Sweep
Sweep Programs as described in the
Programs include: (1) any Account owned by a financial institution; (2) Accounts opened for
prospectus for each money market fund.
Plans with pooled structures (including Accounts for Participants); (3) any Account owned by
an irrevocable trust; (4) any Account owned by a revocable trust if all beneficiaries are natural
Available cash balances are swept to a
persons and/or not-for-profit entities; and (5) any Account identified as a 403(b)(7) account.
"Secondary Sweep Option" once funds on
deposit reach the "Bank USA Sweep Cap".
de 0055 699 1397 11/14/2018
Funds on deposit at Bank USA are eligible for deposit insurance from the FDIC up to $250,000
"Secondary Sweep Option" in the UBS
(including principal and accrued interest) for each insurable capacity in which you own your
Bank Sweep Programs refers to deposit
Account (e.g., individual, joint, corporate, IRA). If you have more than one Account you own
accounts at AG Stamford Branch, the
in the same insurable capacity that sweeps to Bank USA, the amount deposited at Bank USA
Puerto Rico Fund, or one of the available
may exceed the amount covered by FDIC insurance. You are responsible for monitoring
Sweep Funds. UBS AG, Stamford Branch
the total amount of deposits to determine the extent of FDIC deposit insurance
("AG Stamford Branch") is a US branch of
UBS AG, a Swiss Bank. UBS Group AG is
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UBS Client Relationship Agreement
coverage available to you. Please refer to the UBS Bank Sweep Programs Disclosure
the parent company of UBS AG, UBS Bank
Statement for more detailed information regarding the program and FDIC insurance.
USA, UBS Financial Services Inc. and UBS
Financial Services Incorporated of Puerto
Available cash balances will be deposited in Bank USA up to a "sweep cap* which is generally
Rico.
$250,000 per owner per Account. Available cash balances in excess of the sweep cap will be
deposited in deposit accounts at AG Stamford Branch as a Secondary Sweep Option unless you
"Investment Advisory Account" refers to an
select a different Secondary Sweep Option, if available. Funds in deposit accounts at AG
Account enrolled in any of the following
investment advisory programs: Managed
Stamford Branch are not eligible for FDIC insurance or protection by SIPC or any other
Accounts Consulting Program, Portfolio
government agency. Sweep Funds are not FDIC-insured, not guaranteed by a bank,
Management Program, ACCESS, Managed
are sold by prospectus only and may lose value.
Portfolio Program, UBS Strategic Wealth
Portfolio, UBS Strategic Advisor, and
If your Account is not eligible to sweep to deposit accounts at AG Stamford Branch, your
Private Wealth Solutions and such other
Secondary Sweep Option will be a Sweep Fund. Sweep Funds are not available to non-U.S.
programs as UBS may add from time to
residents. The Secondary Sweep Options for certain Investment Advisory Accounts will differ.
time.
Please refer to the UBS Bank Sweep Programs Disclosure Statement.
"Plans" refers to employee benefit plans
You may change your Secondary Sweep Option to an available alternative Secondary Sweep
qualified under Section 401(a) of the
Internal Revenue Code of 1986, as
Option at any time by contacting your Financial Advisor. By instructing us to change your
Secondary Sweep Option, you are authorizing and directing us to redeem your Sweep Fund
amended, or under any other employee
retirement or welfare plan subject to the
shares, or withdraw funds from the deposit accounts at AG Stamford Branch and transfer the
Employee Retirement Income Security Act
funds to your new Secondary Sweep Option.
of 1974, as amended (ERISA). "Participant"
refers to a participant in a Plan who has
Accounts that are not eligible for the UBS Bank Sweep Programs may be eligible to have
established a Securities Account for
available cash balances swept to deposit accounts through the UBS FDIC-Insured Deposit
purposes of participation in the Plan.
Program, a Sweep Fund or to other Sweep Options that we may make available from time to
time (subject to eligibility requirements).
UBS FDIC-Insured Deposit Program
Accounts owned by a revocable or irrevocable trust are eligible for the UBS FDIC-Insured
Deposit Program as long as no trust beneficiary is a for-profit business entity. Through this
program, available cash balances are swept to deposit accounts at participating banks -- up to
$249,000 at each participating bank. Bank USA is a participating bank. Deposits are insured by
the FDIC up to applicable limits and subject to FDIC rules. You are responsible for monitoring
the total amount of deposits to determine the extent of FDIC deposit insurance coverage
available to you. The program is more fully described in the UBS FDIC-Insured Disclosure
Statement, which is part of the Agreements and Disclosures booklet and also available at
www.ubs.com/accountdisclosures.
Sweep Funds
Accounts that are not eligible for the UBS Bank Sweep Programs or the UBS-FDIC-Insured
Deposit Program may have available cash balances automatically invested in a Sweep Fund.
Eligible Accounts include (1) any Account owned by a financial institution; (2) Accounts opened
for Plans with pooled structures (including Accounts for Participants); (3) any Account owned
by an irrevocable trust if one or more beneficiaries is a for-profit business entity. The Sweep
Funds are subject to eligibility requirements as described in the prospectus for each Sweep
Fund. UBS Asset Management (Americas) Inc. is the investment advisor for all of the Sweep
Funds. You may also own shares of a Sweep Fund as a Secondary Sweep Option through the
UBS Bank Sweep Programs or if all participating banks in the UBS FDIC-Insured Deposit
Program.
Accounts for Plans with a pooled structure (and the Accounts of its Participants) will sweep to
the UBS Liquid Assets Government Fund. Generally, other Accounts that are not eligible for the
de 0055 699 1398 11/14/2018
UBS Bank Sweep Programs or the UBS FDIC-Insured Deposit Program will sweep to the UBS
RMA Government Money Market Fund.
In connection with the Sweep Funds, UBS receives: (1) service fees from certain of the Sweep
Funds via payments by their principal underwriter; (2) transfer agency related delegated service
fees from the transfer agent for those same Sweep Funds; and (3) revenue sharing payments
for the same Sweep Funds from UBS Asset Management (Americas) Inc. (UBS AM) related to
assets in the Sweep Funds. Service fees are paid monthly at an annual rate of up to 0.25% of
a Sweep Fund's average daily net assets. Revenue sharing payments for the Sweep Funds are
paid to UBS by UBS AM.
An investment in a money market fund is not insured or guaranteed by the FDIC or
any other government agency. Although each fund seeks to preserve the value of
your investment at $1.00 per share, it is possible to lose money by investing in a
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=== Page 25 ===
money market fund. Money market funds are sold by prospectus, which includes
more complete information on risks, charges, expenses and other matters of interest.
Investors should read the prospectus carefully before investing in a fund.
The Sweep Funds are Not FDIC insured. May lose value. No bank guarantee.
UBS Client Relationship Agreement
A prospectus for each Sweep Fund may be found at
usmoneymarketfunds.com/all-funds.html. You may also contact your Financial
Advisor for a copy of a prospectus.
Please see the Account Protection section in the Additional Disclosures Section of the
Agreements and Disclosures Pages for more information.
Automatic Exchanges of Certain Sweep Funds
Different Sweep Funds may be offered to clients who have Marketing Relationship assets with
UBS of $25 million or more or who otherwise meet requirements established by UBS in its sole
discretion. If you meet this asset threshold and own shares of the UBS RMA Government
Money Market Fund through any of the UBS sweep programs, you will become eligible for the
UBS Select Government Capital Fund and we will liquidate your shares in the UBS RMA
Government Money Market Fund and purchase shares in the UBS Select Government Capital
Fund without direction from, or prior notice to, you. Thereafter, the UBS Select Government
Capital Fund will be your Sweep Option (or Secondary Sweep Option, as the case may be).
Once a first purchase has been made into the fund, the UBS Select Government Capital Fund
will remain your Sweep Option (or Secondary Sweep Option) even if your Marketing
Relationship assets cease to meet the minimum asset thresholds for the UBS Select
Government Capital Fund.
Your eligibility for the UBS Select Government Capital Fund will be determined at the end of
each month, based on the value of your Marketing Relationship assets as determined in the
sole discretion of UBS. If the value of your Marketing Relationship assets reaches the minimum
asset threshold at any time other than the end of the month, you will not be eligible for the
UBS Select Government Capital Fund.
The Puerto Rico Fund
The Puerto Rico Fund is offered as a Sweep Option (and Secondary Sweep Option) exclusively
to residents of Puerto Rico as defined in that fund's prospectus and is not available as a Sweep
Option for tax-deferred accounts such as IRAs and Plans and Participants. The Puerto Rico
Fund is not a money market fund registered under the U.S. Investment Company Act
of 1940, as amended, does not comply with rules applicable to U.S. registered funds
and presents a higher degree of risk than those funds. The Puerto Rico Fund is not
FDIC insured, may lose value and has no bank guarantee. The Puerto Rico Fund is sold
by prospectus only, which may be found at
www.ubs.com/us/en/wealth/misc/puertoricofunds or from your Financial Advisor.
Margin Agreement and Margin Requirements
All Accounts that you open now or in the future will be established with margin, if eligible,
If you do not want to establish margin for
unless you instruct us that you do not want margin privileges for specific Accounts. By signing
your current accounts or any accounts you
the Signature Page for any Account except for an ERISA Plan, you agree that the Margin
open in the future, please contact your
Financial Advisor.
Agreement governs your use of margin in all of your current Accounts and any eligible
Accounts that you may open in the future.
Please note: UBS does not extend margin
for the following accounts:
Therefore, if you do not establish margin privileges when you open an Account and later
decide to use margin, you may be able to do so without signing additional forms. Likewise, if
00 Individual Retirement Accounts
you cancel your margin privileges on an Account, your Margin Agreement with us will remain
8
ERISA Plans
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in effect and you may request to use margin again at any time. In either event, we will confirm
00 Coverdell Education Savings
your request.
Accounts
00 403(b)(7) Accounts
When you use your margin privileges, we hold your securities in your Account as collateral
00 UGMAs
against the amounts you borrow, and your securities may be loaned to UBS or to others as
00 UTMAs
described in the Margin Agreement. In addition, margin-eligible Accounts are subject to
00 Estates
applicable statutes, rules, regulations, procedures or industry customs. We may deem it
00 529 Plan Accounts
necessary or advisable to establish additional requirements for margin accounts. You agree to
maintain sufficient assets to satisfy all applicable statutes, rules or regulations, or as we deem
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UBS Client Relationship Agreement
necessary or advisable. You also agree to maintain sufficient assets in your Account to satisfy
Hypothecation is the pledging of securities
any and all margin calls issued in connection with the Account.
or other assets to secure a loan such as a
debit balance in a margin account.
As long as your Account is a margin account, you authorize UBS in the usual course of
business to lend, pledge as collateral, hypothecate, relend or repledge any Property we carry
"Property" includes, but is not limited to,
for you on margin, whether separately or together with Property of others, either to ourselves
securities, securities entitlements,
or to others. This authorization remains in effect until we receive payment for such Property.
investment property and financial assets,
including without limitation, money, stocks,
options, bonds, notes, futures contracts,
When you use your margin privileges, as permitted by law, we may use certain securities in
commodities, commercial paper, deposits,
your Account for, among other things, settling short sales and lending securities for short
certificates of deposit and other
sales. We may receive and retain compensation in connection with such transactions. If you are
obligations, contracts, all other property
engaged in short selling a security, you may incur a charge due to certain borrowing costs for
usually and customarily dealt in by
that particular security.
brokerage firms and any other property
that can be recorded in or credited to any
Subject to applicable rules and regulations, we may amend the requirements applicable to your
of your Accounts, as well as the Accounts
margin account at any time in our sole and absolute discretion, including, without limitation,
themselves.
changing the level of credit available to you and applicable maintenance requirements; all
without notice to you. A prior demand or call, or prior notice of the time and place of such
Please refer to the UBS Statement of Credit
Practices for additional information.
sale or purchase shall not be considered a waiver of our right to sell or buy without demand or
notice as described herein. For additional terms, please refer to the section "Liquidation of
Collateral or Account" below.
We have the right to satisfy a margin call or to require or obtain full or partial payment of a
margin loan at any time without a demand for margin or additional margin or other notice. To
satisfy a margin call or to obtain full or partial payment of the margin loan, in addition to all
rights provided by law, we have the right to:
1. require additional collateral,
2. sell any Property in any of your Accounts with us, whether carried individually or
jointly with others,
3. buy any Property which may be held short in your Account,
4. cancel any open orders and close any or all outstanding contracts, or
5. liquidate any of your Accounts with us.
We may also exercise these rights at any time in our sole and absolute discretion.
If you are an individual (including an individual acting as trustee of a trust) residing in or
located in any country in the European Economic Area: you represent and warrant that you do
not intend to use any part of a margin loan, and will not now or in the future use any part of a
margin loan, for the acquiring or retaining of property rights in land or in an existing or
projected building, or for the renovation of residential property.
You understand that there are substantial risks involved in trading securities on
margin, using leverage as a liquidity source or as part of your investment strategy, or
otherwise pledging your securities in order to obtain credit. Please review the Loan
Disclosure Statement included in the Agreements and Disclosures booklet carefully
for a detailed discussion of these risks.
Security Interest
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As security for the payment of all liabilities or indebtedness presently outstanding or to be
"UBS Entity" refers to UBS Financial
incurred under this or any other agreement between you and any UBS Entity, including but not
Services Inc. and each of its Affiliates.
limited to any loans, credit lines, promissory notes or tax obligations, you hereby grant to each
UBS Entity a security interest in and lien on any and all Property held or carried by any UBS
"Securities Intermediary" means: 1) a
Entity for you or on your behalf in or credited to any UBS Account(s) (other than qualified plan
clearing corporation; or 2) a person,
or IRA accounts or other accounts where doing so would be a prohibited transaction or
including a bank or broker, that in the
ordinary course of business maintains
violation of applicable law or regulation) and in any other Account with any UBS Entity in
securities accounts for others and is acting
which you may have any legal, equitable or other interest.
in that capacity, as such terms are
interpreted under Section 8-102(a)(14) of
All such Property will be subject to such security interest as collateral for the discharge of your
the United States Uniform Commercial
obligations to any UBS Entity, wherever or however arising and without regard to whether or
Code.
not we made loans with respect to that Property. In enforcing our security interest, we have
the discretion to determine the amount, order and manner in which the Property will be sold
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=== Page 27 ===
and have all the rights and remedies available to a secured party under the Uniform
Commercial Code (UCC) in addition to all other rights provided in this Agreement or by law.
You will not cause or allow any of the Property held in any of your UBS Accounts, whether
owned now or acquired later, to be or become subject to any liens, security interests,
mortgages or encumbrances of any nature other than our security interest, without our prior
written consent. Each UBS Entity shall act as agent for and on behalf of each UBS Entity for
UBS Client Relationship Agreement
purposes of perfecting, maintaining and enforcing the security interests granted hereunder or
by operation of law. Each UBS Entity acting in the capacity of a deposit bank, securities
intermediary or commodities intermediary, agrees to follow the instructions and entitlement
orders of every other UBS Entity with respect to the Property as a secured party without
further consent by you. You hereby authorize and direct each UBS Entity to follow the
instructions and entitlement orders of every other UBS Entity.
Liquidation of Collateral or Account
We may satisfy any and all amounts you owe us in connection with any of your Accounts
or agreements with us, or any other agreement between you and any UBS Entity, including
but not limited to any loans, credit lines, promissory notes or tax obligations, from Property
we hold or carry in any of your Accounts with us (other than qualified plan or IRA accounts
or other accounts where doing so would be a prohibited transaction or violation of
applicable law or regulation). Additionally, we may sell any or all Property held in any of
your Accounts with us and cancel any open orders for the purchase or sale of any Property
without notice in the event of your death or dissolution, bankruptcy or whenever in our
sole and absolute discretion we deem it necessary for our protection. In these instances,
we may also borrow or buy-in all Property held in any of your Accounts required to make
delivery against any sale initiated for you. These sales or purchases may be public or private
and may be made without advertising or notice to you and in the manner we determine in
our sole discretion. You waive diligence, presentment, protest, demand for payment and
notice of nonpayment and further waive all other notices and formalities to which you may
be entitled under applicable law or otherwise, to the extent the waiver of such notices and
other formalities is permissible under applicable law. Your waiver will not be invalidated by
any demands, calls, tenders or notices that we may make. At any sale, we may purchase
the Property or any portion thereof free of any right of redemption and you will remain
liable for any deficiency in any of your Accounts, plus any accrued interest on the
deficiency at our then customary rate, if applicable, or at the maximum rate allowable by
law. We will not be liable to you in any way for any losses or adverse tax consequences
resulting from a liquidation of your Property.
Restrictions on Trading and Disbursements
You acknowledge that we, in our sole discretion, with or without prior notice to you, may
prohibit or restrict trading of any securities held in your Account, prohibit or restrict
disbursements from your Account, and refuse to enter into any purchase or sale
transaction with you regarding any securities that we deem high risk from a regulatory
perspective, even if those securities were purchased by you through us. In addition, you
understand that we maintain the right not to custody any such securities and deliver these
securities to you at your expense.
USA Patriot Act
To help the government fight the funding of terrorism and money laundering activities,
Federal law requires all financial institutions to obtain, verify and record information and
documentation identifying each account holder. Therefore, when you open an Account,
we ask for your name, address, date of birth and other identifying information about you.
We may ask to see your driver's license or other identifying documents. We may also
screen your name against various databases to verify your identity. If we are unable to
de 0055 701 1401 11/14/2018
verify your identity, we may take any of the actions described under "Termination of your
Account" in the General Terms and Conditions in the Agreements and Disclosures booklet.
Please see the UBS Client Privacy Notice in
the Agreements and Disclosures booklet
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UBS Client Relationship Agreement
Your Privacy
for further information, including how to
opt out of certain information sharing.
At UBS, we are committed to safeguarding your personal information. Please refer to the UBS
Client Privacy Notice in the Agreements and Disclosures booklet, which describes the personal
information we collect about you and how we handle and protect it.
Subject to any applicable financial privacy laws and regulations, you acknowledge that we
share such personal financial data regarding you and your Accounts with our affiliates and
non-affiliates as is necessary or advisable to effect, administer or enforce transactions
requested or authorized by you, or to service, process or maintain your Accounts and all
transactions related to or in connection with your Accounts.
Credit Report
You grant us permission to obtain a credit report when you open an Account with us and to
obtain updated credit or similar reports at any time during the time your Account remains
open. You grant us permission to check and verify your credit references and update all credit
information we have obtained on you. We may provide any such credit report or other credit
information we have obtained on you to our Card Issuers, Check Providers or to our affiliates,
as permitted by law to enable them to provide additional products or services that may be of
interest to you and to otherwise assist us in servicing, administering and maintaining your
Account and evaluating your financial needs.
Disclosure of Beneficial Ownership
The issuers of securities held in your Accounts may request your name, address and security
position so that they may contact you directly for proxy voting and other shareholder
communications. You may instruct us not to supply this information, in which case you will
receive information regarding those securities from UBS instead of the issuers.
Your current instructions with respect to such disclosure are reflected on the Account
Information pages of the Completing Your Account Opening Process package. If you would
like to change your instructions, please call your Financial Advisor.
As described in the section "Foreign Securities" in the General Terms and Conditions of the
Agreement and Disclosure Booklet, we may share information about the beneficial ownership
of foreign securities in your Accounts with the issuers of those securities, foreign government
authorities and their agents, custodian banks or brokers and local or international securities
depositories to obtain reduced tax withholding rates, to comply with local law or to respond to
other lawful requests.
Alternate Contact Person
If you have provided UBS with an Alternate contact person, you authorize us to contact such
person in the event that we have concerns or questions about you, including but not limited to
your health, well-being or whereabouts. You further authorize UBS to discuss our concerns
and disclose any necessary information about you including your Account information to your
alternate contact. You acknowledge that this authorization will apply to all Accounts currently
open and any account you open in the future in any capacity.
You understand that the decision as to whether, when or if to reach out to your alternate
contact(s) is at the sole discretion of UBS and that if you have provided multiple alternate
contact persons, UBS is under no obligation to reach out to any or all of them.
de 0055 701 1402 11/14/2018
Electronic Records
Any agreements accepted by facsimile or electronic means (such as clicks or other online
means) are legally binding and are considered to have been "signed" by you with the same
effect as manual signatures. Electronic records of an agreement that is made online will also be
considered to be "in writing". You agree not to dispute the validity or enforceability of any
agreements entered into electronically by you (or by anyone using your authentication devices,
such as a password or PIN).
28
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E-mail Communications
We discourage clients from transmitting personal or confidential information through e-mail as
these may be sent via unsecure servers and/or facilities which are easily accessible by third
parties (such as international public and private data transmission networks and internet service
providers) and are typically routed via (multiple) foreign jurisdictions. If you choose to send
UBS Client Relationship Agreement
personal and confidential information to us via e-mail, you understand and accept that e-mail
transmissions may entail a considerable amount of danger and risk including:
8
lack of confidentiality (e-mails and their attachments can be read and/or monitored
without detection);
8
manipulation or falsification of the sender's address or of the e-mail's (or
attachment's) content (e.g. changing the sender's address(es) or details);
8
system outages and other transmission errors, which can cause e-mails and. their
attachments to be delayed, mutilated, misrouted and deleted;
8
viruses, worms, Trojan horses etc. may be spread undetected by third parties and
may cause considerable damage; and
8
interception by third parties
and agree that we cannot be responsible for any loss or damages that occur as a result, such
as losses or damages arising from mistaken identity or unauthorized access and the use of the
information (for any purpose) by others who may intercept or otherwise access the
communications during and after transmission.
Electronic Delivery Agreement
UBS offers certain communications through electronic delivery. Categories of communications
you may enroll in for e-Delivery include:
8
Statements for your UBS Accounts, which include your UBS Visa Signature® credit
card statement from the Card Issuer; notices delivered on or with statements such
as our annual Client Privacy Notice; and messages about transactions and
payments.
8 Trade confirmations and notices regarding Account activity.
8
Shareholder communications, including annual and other shareholder reports,
preliminary and final prospectuses, proxy materials and information about other
corporate actions. Shareholder communications also includes all account documents
related to Investment Advisory accounts and fee-based financial planning services,
including Form ADV disclosure brochures, manager profiles, asset allocations,
performance reports and other disclosures, reports and notices related to advisory
accounts and fee-based financial planning services.
8 Quarterly performance reports.
8
UBS Equity Plan Advisory Services plan advices.
80 Tax reporting documents, including 1099s and other tax documents that are
available now or become available in the future.
8
Agreements and disclosures relating to the accounts, features and services we
offer.
Any member of your household may enroll any other household account in electronic delivery
Please see the section Householding of
of these periodic communications, except for tax reporting documents. By enrolling in
Statements and Other Communications
e-Delivery of any communications described above, you agree that we may also deliver similar
below for further information regarding
firm documents electronically that may be available now or in the future. When available,
how a household is established.
confirmations of your personal and account information may be included with related
de 0055 702 1403 11/14/2018
documents that are delivered electronically through UBS Online Services or any other secure
method.
Please note: These confirmations are sent periodically and to confirm certain changes to your
Account information. These confirmations may be viewable by other members of your
household through UBS Online Services or other secure methods. Contact your Financial
29
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=== Page 30 ===
UBS Client Relationship Agreement
Advisor if you prefer to receive private, paper versions of confirmations of personal and
Account information instead of electronic versions.
If you enroll in e-Delivery for any of the communications described above, the following terms
and conditions will apply to all of the UBS Accounts (current and future) in your UBS statement
household.
8
A valid e-mail address is required for our e-Delivery services and you are responsible
for notifying UBS when your e-mail address changes; you may update your e-mail
address online through UBS Online Services or by calling your Financial Advisor.
8 Access to UBS Online Services is required for e-Delivery of documents that contain
any personal information; we may, however, deliver such documents by other
secure means in the future.
8
Enrollment in e-Delivery is effective immediately and may be cancelled at any time,
either by changing your elections online or by contacting your Financial Advisor; we
confirm cancellations and other changes to your delivery preferences by e-mail or
regular mail whether they were initiated by you or UBS.
8 Enrollment for any e-Delivery services for any of your Accounts will automatically
apply to any accounts that you open in the future at UBS, subject to certain system
limitations.
8 You may request paper copies of any document we are required to deliver to you at
any time for no additional charge by contacting your Financial Advisor.
8
We notify you by e-mail when a new document is available; to protect your
information, the electronic message generally includes a link to a secure UBS
website where the document can be viewed and downloaded.
8
If your e-mail address fails, we will mail paper copies of documents or a paper
notice that a document is available with instructions on how to access it.
8
By enrolling in e-Delivery, you confirm that you have access to a printer or other
device to print or save documents you may wish to retain.
8 We do not charge for e-Delivery, but your Internet access provider may have
separate charges.
Householding of Statements and Other Communications
As a convenience to you, we may consolidate periodic communications for certain accounts
If you do not want your statements to be
with the same address. This practice, called "householding", applies to account statements,
bundled by household, please contact your
trade confirmations, remittance transfer receipts, personal and financial information required
Financial Advisor.
to be sent by regulation, preliminary and final prospectuses and Summary of Accounts
statements, which provide consolidated information for all of the Accounts in your household.
For more information regarding electronic
delivery of periodic communication for your
Account, please refer to the Electronic
Households are determined as follows:
Delivery Agreement herein.
8
Accounts that share the same name, address and Social Security or Tax ID Number
are automatically placed in the same household.
00 Accounts that share only the same address will be placed in the same household
de 0055 702 1404 11/14/2018
only with the express consent of all the Account holders.
We mail househeld communications in a single envelope (if you receive paper delivery) or, if
you receive electronic delivery, we make them available through UBS Online Services or other
electronic delivery method. Any member of your household who is enrolled in UBS Online
Services can have access to view all Accounts in the household.
The composition of a household will change as clients move away from the household mailing
address, and the addressee for househeld mailings may also change over time. Where owners
of joint accounts live at different addresses, househeld mailings will be sent to at least one
Account owner's address and may be included with mailings for other Accounts at that
address under the conditions described above.
30
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=== Page 31 ===
Periodically we are required by industry regulators to send records of certain personal
and financial information to our clients. Because we deliver these records with your
account statements, other members of your household may have access to these
records unless you instruct us to send them to you separately.
If you do not want your statements and other periodic communications from us to be bundled
by household, please contact your Financial Advisor and ask to receive individual mailings in
UBS Client Relationship Agreement
separate envelopes or delivered separately via electronic means.
Non-Primary Residence Address for Mailing Purposes
Unless you notify us otherwise in writing, you authorize us to use the Account address you
provided to mail all notices, correspondence and for the disbursement of Property, even if it is
not your primary residence. Based upon this authorization, we will not telephone you to
confirm receipt of property or require a signed written confirmation from you acknowledging
transmittal of property. If you would like to designate an alternative mailing address for the
Account, please contact your Financial Advisor to provide the necessary authorization. Even
when you have provided a mailing address for the Account, some correspondence may be
delivered to your legal residence address only based upon operational considerations.
Applicable Law
This Agreement, including the Arbitration provisions below, and its enforcement, is governed
by the laws of the State of New York, without giving effect to such State's choice of law or
conflict of laws provisions. The Agreement is binding on you and on UBS Financial Services Inc.
and UBS Financial Services Incorporated of Puerto Rico provided that there is no inconsistency
with the Federal securities laws or the Federal or State banking laws. In connection with any
Card issued, the respective Cardholder Agreement shall be governed by Federal law and the
law designated by the Card Issuer in that Cardholder Agreement.
In the event that any of the Arbitration provisions below are found to be unenforceable, you
submit to the exclusive jurisdiction of the courts of the State of New York and the Federal
courts sitting in the Southern District of New York for the purpose of determining all matters
with regard to the Agreement. You also consent to service of process by certified mail to your
Account's address of record, and you waive any objection to the venue and any claims that an
action or proceeding has been brought in an inconvenient forum. If any provision of the
Agreement is held to be invalid, void or unenforceable, the remaining provisions will remain in
full force and will be construed to the fullest extent permitted by law, to give effect to the
intent of any provision that has been called into question.
Arbitration
This Agreement contains a predispute arbitration clause. By signing an arbitration agreement
This Arbitration Agreement represents
the parties agree as follows:
standard industry practice and binds you
and UBS Financial Services Inc. or UBS
8
All parties to this Agreement are giving up the right to sue each other in court,
Financial Services Incorporated of Puerto
including the right to a trial by jury, except as provided by the rules of the
Rico to arbitrate any disagreements that
arbitration forum in which a claim is filed.
may arise between the parties.
"The parties" for purposes of this
8 Arbitration awards are generally final and binding; a party's ability to have a court
arbitration agreement, are UBS Financial
reverse or modify an arbitration award is very limited.
Services Inc. or UBS Financial Services
Incorporated of Puerto Rico and you,
8
The ability of the parties to obtain documents, witness statements and other
including on behalf of your heirs,
discovery is generally more limited in arbitration than in court proceedings.
executors, administrators and assigns.
8
The arbitrators do not have to explain the reason(s) for their award, unless, in an
eligible case, a joint request for an explained decision has been submitted by all
parties to the panel at least 20 days prior to the first scheduled hearing date.
de 0055 703 1405 11/14/2018
8 The panel of arbitrators will typically include a minority of arbitrators who were or
are affiliated with the securities industry.
8 The rules of some arbitration forums may impose time limits for bringing a claim in
arbitration. In some cases, a claim that is ineligible for arbitration may be brought in
court.
31
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UBS Client Relationship Agreement
8 The rules of the arbitration forum in which the claim is filed, and any amendments
to them, shall be incorporated into this Agreement.
By opening an account at UBS, and by UBS Financial Services Inc. or UBS Financial Services
Incorporated of Puerto Rico by accepting your application and carrying your Account, you, UBS
Financial Services Inc. and UBS Financial Service Incorporated of Puerto Rico agree as follows:
8 To resolve any controversy, claim or issue in any controversy that may arise between
you and UBS Financial Services or UBS Financial Services Incorporated of Puerto Rico
by arbitration, whether it happened before or after, or at the time this Agreement
was executed, including but not limited to controversies, claims or issues in any
controversy concerning any account, transaction, dispute or the construction,
performance or breach of this Agreement or any other agreement.
8 Any arbitration under this Agreement shall be governed by the Federal Arbitration
Act and shall be conducted before an arbitration panel convened by the Financial
Industry Regulatory Authority (FINRA) or any other national securities exchange's
arbitration forum, upon which UBS Financial Services Inc. or UBS Financial Services
Incorporated of Puerto Rico is legally required to arbitrate the controversy with you,
including, where applicable, the Municipal Securities Rulemaking Board.
8 Such arbitration shall be governed by the rules of the organization convening the
panel.
8 The arbitrators shall resolve any controversy in accordance with applicable law.
8 The arbitrators will apply state and federal statutes of limitation the same as if the
claim were brought as a civil action in court.
8 The award of the arbitration panel is not subject to appeal and judgment upon the
award may be entered in any court of competent jurisdiction.
8 No person shall bring a putative or certified class action to arbitration nor seek to
enforce any pre-dispute arbitration Agreement against any person who has initiated
in court a putative class action; or who is a member of a putative class who has not
opted out of the class with respect to any claims encompassed by the putative class
action until:
- the class certification is denied; or
- the class is decertified; or
- the customer is excluded from the class by the court. Such forbearance
to enforce an agreement to arbitrate shall not constitute a waiver of any
rights under this agreement except to the extent stated herein.
00 You expressly agree that service of process in any action shall be sufficient if served
by certified mail, return receipt requested, at your last address known to UBS.
8
You expressly waive any defense to service of process as set forth above.
de 0055 703 1406 11/14/2018
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=== Page 33 ===
Trust Signature Page
For Your Records
All trustees must sign this document.
By signing below, I acknowledge that I understand and agree with the terms and conditions of the UBS Client Relationship Agreement, the Agreements
FOR YOUR RECORDS
and Disclosures booklet and addendum, and if applicable, the Agreements and Disclosures for IRAs, and the Retirement Plan Disclosures available at
www.ubs.com/retirementplandisclosures that is enclosed or that I have previously received. I agree that the representations in these documents are
accurate and that I will be bound by the terms and conditions in these documents.
Trustee Certification
By signing below, I represent that I have reviewed the Trust Agreement and any other documents governing the trust. As trustee, I have full power under the
Trust Agreement to make this Trust Certification and have consulted with my legal counsel, if necessary.
Investment and Other Powers and Restrictions We represent and warrant that, except as indicated below, we have broad investment and other powers
under the trust agreement and applicable law to enter into transactions and to trade, buy, sell, sell short or otherwise acquire, receive, deliver, assign,
endorse for transfer, hold or dispose of all manner of securities, futures, currencies and commodities (including options or warrants on securities, futures,
currencies or commodities) or to purchase and surrender insurance policies and annuity contracts or interests in any of the foregoing in whatever form they
may take, and whether by direct ownership or by interests in funds, partnerships, pools or other forms of collective ownership, except the types of
investments specifically listed below:
Loans and Other Credit Transactions We represent and warrant that we have broad powers under the trust agreement and applicable law to engage in
borrowing and other loan and credit transactions with or through UBS for investment and non-investment purposes, including margin loans, other loans,
pledges, mortgages, hypothecations, repurchase and reverse repurchase transactions, letters of credit, credit facilities, and guarantees of the obligations of
third parties to UBS (in each case, with no limitations as to amount). We have the authority to pledge, mortgage, assign or subject to a security interest or lien
in favor of UBS any property of any sort of the trust as security for any liability of the trust or third parties (in each case, with no limitations as to amount). We
have the authority to execute any and all relevant documents and bind the trust in respect of any agreements entered into pursuant to this paragraph, except
the types of borrowing or other loan or credit transactions listed below:
If the trust has multiple trustees or officers, can one trustee or officer act independently?
yes
No
If No, specify the number of signatures required:
(specify number or "all")
If trustees do not have authority to hire an investment advisor or other third party, check here
-
The person identified below is authorized to act as a successor trustee in the event of the death, resignation or removal of all of the current trustees:
Name:
Title:
Address:
Margin Agreement
I agree that the Margin Agreement in the Client Relationship Agreement applies to all of my margin-eligible accounts opened now or in the future. This
means that if I use margin privileges, UBS will hold the securities in the margined accounts as collateral against the amounts borrowed. I agree to keep
sufficient positions in margined accounts to meet any margin calls UBS may issue. I also understand that securities in any margined account may be loaned
to UBS or other persons or entities as described in the Margin Agreement.
I understand that the Margin Agreement is not applicable to retirement accounts or any other accounts that are not eligible for margin
privileges at UBS (including IRAs, ERISA plans, Coverdell Education Savings Accounts, 403(b)(7) Accounts, UGMA/UTMA, Estate or 529
Accounts).
Electronic Delivery Consent
As requested, I received my Agreements and Disclosures booklet and other account-related documents electronically at jroberts@nutter.com which is the
e-mail address of record for all owners of these accounts. I understand that the information is also available at www.ubs.com/accountdisclosures or by
request to my Financial Advisor at 1-212-821-7000.
de 0055 704 1407 11/14/2018
Continued on next page.
33
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=== Page 34 ===
FOR YOUR RECORDS
Montpelier Trust
For Trust Accounts:
ENTER TIN FOR TRUST:
X X - X X X X X X X
ENTER SSN HERE
Check here if you have been notified by the IRS that you
are subject to backup withholding, and therefore have
crossed out paragraph 2 in the Certification below.
Exempt Payee Code (if any)
If your organization is tax exempt please enter the appropriate code
(codes 1 through 13 in the W9 instructions)
Exemption from FATCA reporting code (if any):
W-9 Form Certification
Under penalties of perjury, I certify that: (1) the number shown on this form is my correct taxpayer identification number
The Client Relationship
(or I am waiting for a number to be issued to me), and 2) I am not subject to backup withholding because: (a) I am
Agreement contains a
exempt from backup withholding, or (b) I have not been notified by the Internal Revenue Service (IRS) that I am subject to
pre-dispute arbitration
clause located in the final
backup withholding as a result of a failure to report all interest and dividends, or (c) the IRS has notified me that I am no
section under the title
longer subject to backup withholding, and (3) I am a U.S. citizen or other U.S. person (defined in the instructions), and (4)
"Arbitration."
The FATCA code(s) entered on this form (if any) indicating that I am exempt from FATCA reporting is correct.
Certification Instruction: You must cross out item (2) above if you have been notified by the IRS that you are currently
subject to backup withholding because you have failed to report all interest and dividends on your tax return.
SIGN AND
X
DATE HERE
Jeffrey W. Roberts
Date
SIGN AND
X
DATE HERE
65007453_0055
Scott Borgerson
Date
SIGN AND
X
DATE HERE
Christine Yvonne Malina-Maxwell
Date
Address of Record
ATTN: Nutter McClennen & Fish
LLP
Boston, MA 02210-2698
Email Address of Record
de 0055 704 1408 11/14/2018
34
65007453_DE00055_00055
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=== Page 1 ===
Event: Epstein pre-meet
Start Date: 2019-04-08 13:30:00 +0000
End Date: 2019-04-08 14:00:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2019-04-06 18:39:06 +0000
Date Modified: 2019-04-06 18:39:06 +0000
Priority: 5
DTSTAMP: 2019-04-06 18:28:16 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00026444


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: for new victim witness services website, for the Maxwell case
Date: Wed, 08 Jul 2020 15:51:15 +0000
Of course, will do.
Sent from my iPhone
On Jul 8, 2020, at 11:30 AM,
wrote:
Could we please create a new Victim & Witnesses Services page for the Maxwell case, similar to what we did for the
Epstein case last year? The header can be the same format as Epstein, with the top two lines as:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
If you believe you were a victim of Ghislaine Maxwell or have information about the allegations in the Indictment,
please call 1-800-Call-FBI
And then for the first entry, a "July 8, 2020 update", could we please post the following, along with a link to the PDF of
the indictment:
On July 2, 2020, the United States Attorney's Office announced the unsealing of federal felony charges against
GHISLAINE MAXWELL on charges of enticement of a minor to engage in illegal sex acts, transportation of a minor to
engage in illegal sex acts, conspiracy, and perjury. These crimes are alleged to have occurred in locations including, but
not limited to, New York, Florida, New Mexico, and the United Kingdom.
If you believe you are a victim of GHISLAINE MAXWELL, from during any time period and in any location, please contact
the Victim / Witness specialists at the U.S. Attorney's Office listed below.
The charges are contained in Indictment 20 Cr. 330 (AJN). You may view a copy of the Indictment here.
Updates regarding the progress of this case will be posted on this site.
The United States Attorney's Office for the Southern District of New York is committed to protecting the rights of crime
victims. If you believe you are a victim of the offense charged, our Victim/Witness Unit can make sure that you are
notified of important stages of the case to help you exercise your rights. In addition, our Victim/Witness Unit can help
refer you to agencies that provide other services to witnesses, such as compensation (under certain circumstances) and
counseling. If you believe you are a victim, of if you would like information or assistance with referrals, please contact:
Victim/Witness Coordinator
United States Attorney's Office
EFTA00024770

=== Page 2 ===
New York, New York 10007
*
*
Let us know if any questions or issues at all? And thanks very much as always.
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To: Christian Everdell
BOBBI C STERNHEIM
Laura Menninge
Jeff Pagliuca
Cc:
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - discovery and exhibits
Date: Fri, 29 Oct 2021 00:25:57 +0000
Attachments: 2021.10.28_Maxwell_Discovery_Letter.pdf;
2021.10.28_US_v_Maxwell_Government_Exhibit_Index_(Defense).pdf
Counsel,
We have an additional discovery production ready to send to you. Attached please find the accompanying cover letter.
The production will be made via USAfx. The materials on USAfx will include additional exhibits. Attached please find the
accompanying index.
We will send a CD with the materials to the MDC for Ms. Maxwell. If you would prefer that she receive the production on
a drive, we can either request that the MDC send us one of the drives back to load with the production, or we can load a
new drive if you would like to provide us with one.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
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=== Page 1 ===
From: Kendall Felder
To:
(USANYS) [Contractor]"
Cc:
(USANYS) [Contractor]"
,
i
(USANYS) [Contractor]"
i
,
)"
Subject: Re: 11:30 Call
Date: Thu, 08 Oct 2020 18:31:46 +0000
Attachments: Volume001.dat
On Thu, Oct 8, 2020 at 2:28 PM
(USANYS) [Contractor]
wrote:
Is the overlay file small enough to e-mail?
From: Kendall Felder
Sent: Thursday, October 8, 2020 2:21 PM
To:
(USANYS) [Contractor]
Cc:
>;
(USANYS) [Contractor]
>;
(USANYS) [Contractor]
>;
Subject: Re: 11:30 Call
How would you like me to share the update file with you?
On Thu, Oct 8, 2020 at 10:55 AM
(USANYS) [Contractor]
wrote:
Please use the following dial-in:
Pin:
From:
(USANYS) [Contractor]
Sent: Thursday, October 8, 2020 10:25 AM
To:
;
(USANYS) [Contractor]
(USANYS) [Contractor]
; Maurene R.
)
Subject: 11:30 Call
EFTA00026560

=== Page 2 ===
Hi everyone,
We are on for a call at 11:30 AM today to discuss a few questions regarding the hard drive sent up to us. I
will circulate the call-in information shortly.
Thanks,
Paralegal Specialist
U.S. Attorney's Office SDNY
Office:
Cell:
KENDALL FELDER
General Manager
E
I M
P
Melken Solutions, LLC
melken-solutions.com
Share Files with Me!
The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party,
without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake
does not occur in the future.
EFTA00026561

=== Page 3 ===
KENDALL FELDER
General Manager
E
I M
I
P
Melken Solutions, LLC
I
melken-solutions.com
ARR
Share Files with Me!
The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without
a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not
occur in the future.
EFTA00026562


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=== Page 1 ===
From:
To:
Cc:
Subject: Fwd: Voice Message Attached from
- name unavailable
Date: Thu, 21 Jan 2021 00:46:40 +0000
Attachments:
.wav; ATT00001.htm
Hi
,
The Florida State Attorney, Dave Aronberg, left me the attached message. I'm assuming this relates to the
Epstein case (though it's possible, given the timing of the call today, that it relates to WBTW). Since this is the
State Attorney himself, I wanted to check with you before calling back to see if you'd prefer to speak with him.
Thanks,
Sent from my iPhone
Begin forwarded message:
From:
Date: January 20, 2021 at 4:24:29 PM EST
To:
Subject: Voice Message Attached from
- name unavailable
Time: Jan 20, 2021 4:24:29 PM
Click attachment to listen to Voice Message
EFTA00025014


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=== Page 1 ===
Case 1:19-cv-03377-LAP Document 101 Filed 12/20/19 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
,
Plaintiff,
V.
ALAN DERSHOWITZ,
Civil Action No. 1:19-cv-3377 (LAP)
Defendant.
DECLARATION OF HALEY N.
PROCTOR
ALAN DERSHOWITZ,
Counterclaim Plaintiff,
V.
,
Counterclaim Defendant.
HALEY PROCTOR hereby declares pursuant to 28 U.S.C. § 1746 as follows:
1.
I make this declaration in support of Plaintiff
motion for leave
to file an Amended Complaint.
2.
Attached hereto as Exhibit A is a true and correct copy of the Amended Complaint
Plaintiff proposes to file.
3.
Attached hereto as Exhibit B is a true and correct copy of the proposed Amended
Complaint in which the non-formatting changes from the Complaint are identified in redline.
4.
Attached hereto as Exhibit C is a true and correct copy of a transcript of the
December 2, 2019, status conference held before the Court and referred to in the accompanying
memorandum of law.
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=== Page 2 ===
Case 1:19-cv-03377-LAP Document 101 Filed 12/20/19 Page 2 of 2
Dated: December 20, 2019
/s/ Haley N. Proctor
Haley N. Proctor
2
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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Date: Thu, 11 Jul 2019 00:58:08 +0000
Importance: Normal
I think there was a typo in the second paragraph of your email cutting off the sentence.
From:
Sent: Wednesday, July 10, 2019 8:57 PM
To:
Conlon
>; ; Roberta Kaplan
>; ; Jenna Dabbs
>; Alexandra Elenowitz-Hess
Cc:
is
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Hi all,
As you may already know, pursuant to the Crime Victims' Rights Act, specifically 18 U.S.C. 3771(a)(4), a crime victim has
the right to be reasonably heard at certain public proceedings in the district court, including proceedings involving
release. Accordingly, we wanted to be in touch consistent with our responsibilities and obligations-and your client's
rights-under that statute, to see whether your client would like to be heard in any fashion, whether through a
submission, a representation that we can include in our bail submission due Friday, or some other form. Of course no
requirement or obligation, but we would be happy to discuss it if that would be useful.
To the extent this information is useful in your consideration, I can say that while I don't want to prejudge the
Would it make sense to set up a brief call sometime tomorrow, if any of you want to discuss? I should be able to make
myself available whenever is convenient for you (and likely will be just me, as the remainder of the team will be traveling).
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00026677


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=== Page 1 ===
From:
Subject: RE: Tags for US V. Epstein Relativity Database
Date: Wed, 23 Sep 2020 16:48:13 +0000
Good Morning,
The tags have been created in the database under issue designation field. The batches have been created and you can
check out the batches as you see fit. Please let me know if there are any questions.
Thank you.
From:
Subject: Tags for US V. Epstein Relativity Database
Hi
We would like to use several tags as we conduct our review of documents in the "US V Epstein" database on Relativity.
For that database, would you please help us create the below tags?
Reviewed
Witness Statement
Produce As Is
Produce With Redactions
Produce As Confidential
Produce As Highly Confidential
Work Product (Do Not Produce)
Potential Brady
Hot Doc
For Further Review
Tech Issue
Please let me know if you have any questions or would like to discuss.
Thanks very much,
EFTA00023548


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=== Page 1 ===
From:
(USANYS)"
To: Christian Everdell
, "Mark S. Cohen"
BOBBI C STERNHEIM
"Laura Menninger"
, Jeff Pagliuca
Cc:
)"
)"
)"
Subject: US V. Maxwell - Letter Due Today
Date: Wed, 05 May 2021 18:12:49 +0000
Attachments: 2021-05-05_GM_letter_re_flashlight_checks_final.pdf
Counsel,
In accordance with Judge Nathan's Order dated April 29, 2021 (Dkt. No. 257), the Government is sharing its letter so you
can indicate if you believe any private medical information needs to be redacted before public filing. We do not believe
any redactions are necessary. Please let us know if you think any redactions are needed.
Thanks,
Lara
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
Tel:
EFTA00024931


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=== Page 1 ===
From:
To:
Subject: Re: Ghislaine Maxwell custody
Date: Fri, 03 Jul 2020 17:01:47 +0000
Thanks! Am I correct that this means Maxwell will be able to call both Chris and Mark today?
(And please tell
hi back!)
On Jul 3, 2020, at 12:47 PM,
wrote:
Done.
P.S.
says hi!
From:
Sent: Friday, July 3, 2020 12:42 PM
To:
Subject: RE: Ghislaine Maxwell custody
Terrific, thanks very much.
Both attorneys are partners at Cohen & Gresser LLP.
Chris Everdell's number is
Mark Cohen's number is
Thanks again,
From:
Sent: Friday, July 3, 2020 11:39 AM
To:
Subject: RE: Ghislaine Maxwell custody
is on it. Can I please have name of law firm and best contact number for each lawyer?
Thanks.
From
Sent: Friday, July 3, 2020 11:32 AM
To:
Subject: RE: Ghislaine Maxwell custody
EFTA00024543

=== Page 2 ===
Appreciate it, thank you.
From:
Sent: Friday, July 3, 2020 11:21 AM
To:
Subject: Re: Ghislaine Maxwell custody
I will call
and advise - he can be a little touchy.
Sent from my iPhone
On Jul 3, 2020, at 11:13 AM,
wrote:
Thanks. I think it's fine to speak with
about it, but my sense is that we would also need USMS approval, based on
the email from
If you think it would be ok, I'm happy to reach out to
directly to discuss.
From:
Sent: Friday, July 3, 2020 11:05 AM
To:
Subject: Re: Ghislaine Maxwell custody
I will try. Can I start with
he may be in the best position to get it done?
Sent from my iPhone
On Jul 3, 2020, at 10:23 AM,
wrote:
Thanks very much for passing this along. The permitted attorney contact on the list below only includes Vogelman
without reference to her New York counsel. Would it be possible to add her two New York attorneys-Chris Everdell
and Mark Cohen-to the list of people Maxwell can speak with on the phone, please?
Ideally, we would like to get them added today so that they can speak with their client over the weekend to facilitate
our discussions with them about next steps in the case.
Thanks,
From:
Sent: Thursday, July 2, 2020 3:47 PM
To:
Subject: Fwd: Ghislaine Maxwell custody
FYI
EFTA00024544

=== Page 3 ===
Sent from my iPhone
Begin forwarded message:
From:
Date: July 2, 2020 at 3:43:43 PM EDT
To: "NHD-SUPERVISORS (USMS)" <USMS-NHD-SUPERVISORS@usms.doj.gov>
Cc:
Subject: Ghislaine Maxwell custody
To all:
Below are the restrictions we have put in place regarding Ms. Maxwell during her stay at Merrimack DOC. I. If you
have any questions please feel free to call or email me.
Due to the high profile status of this case Inmate Maxwell will be closely monitored. The following
directives apply and shall not be deviated from without express permission from
myself or
1.
Inmate Maxwell will be housed in M1
2.
SRT personnel will be posted in medical and will only be relieved only by SRT personnel
3.
Staff will not converse with the inmate outside of the standard communication required related to the
inmate's health and safety
4.
Inmate Maxwell will remain on a 15 minute observation watch
5.
All rounds, and touch probe rounds will be conducted and documented in XJail
6.
Third Shift Supervisors will download the touch probe rounds and camera footage from the previous
day at 0000 hours each day. The video from the medical cell DVR will be downloaded onto a USB drive
and will be tracked via the designated tracking form provided. Supervisors are directed to deliver this
documentation and video to
Monday July 6th
7.
Inmate Maxwell will be authorized to communicate with her legal counsel, Lawrence Vogelman.
This contact is only authorized after Atty Vogelman provides the appropriate PIN
8.
Any and all requests from Inmate Maxwell are to be directed to
only
At no time are staff authorized to make statements to the press regarding this matter or our SOP regarding
this inmate.
Supervisory Deputy United States Marshal
District of New Hampshire
Concord, New Hampshire
office
EFTA00024545

=== Page 4 ===
This e-mail is property of U.S. Marshals Service. It is intended only for the person or entity to which it is addressed
and may contain information that is privileged, confidential, or otherwise protected from disclosure. Distribution or
copying of this e-mail or the information contained herein by anyone other than the intended recipient is
prohibited. If you have received this e-mail in error, please notify me immediately and destroy all electronic and
paper copies of this e-mail.
EFTA00024546


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=== Page 1 ===
From:
"
To:
Subject: Re: RE:
Date: Fri, 30 Nov 2018 19:39:42 +0000
Thank
Talk to you shortly.
Assistant Special Agent in Charge
New York Field Office
Original message
From:
Date: 11/30/18 2:38 PM (GMT-05:00)
To:
Cc:
X
i
Subject: RE: RE:
Yes, we can do that
From:
Sent: Friday, November 30, 2018 2:33 PM
To:
(USANYS)
i
Cc:
Subject: RE: RE:
Can you all can call my desk
(
)
from one conference room? If that won't work, l'll get a call in number and
put that out to everyone.
From:
(USANYS) [mailto:
Sent: Friday, November 30, 2018 2:10 PM
To:
is
Cc:
is
>;
Subject: RE: RE:
330 is good.
From:
Sent: Friday, November 30, 2018 1:39 PM
To:
Cc:
EFTA00023707

=== Page 2 ===
(USANYS)
is
Subject: Re: RE:
Either of those times work for me.
and I have a meeting at 2 so 3:30 would be better if possible.
Sent from my iPhone
On Nov 30, 2018, at 1:35 PM,
wrote:
All,
We've been able to gather some information on the Jeff Epstein matter and I'd suggest we have a call to determine the
way forward. Does 3:00 or 3:30 today work?
From:
(NY) (FBI)
Sent: Thursday, November 29, 2018 4:40 PM
To:
Subject: FW:
From:
Sent: Thursday, November 29, 2018 1:36 PM
To:
Cc:
Subject:
Have you seen this article?
https://www.miamiherald.com/news/local/article220097825.html
Have any insight? From the article is sounds like he cooperated in a financial fraud case and was non-prosd.
and I can chat whenever.
Thanks,
Assistant United States Attorney
Human Trafficking Co-Coordinator
Violent & Organized Crime
Southern District of New York
EFTA00023708


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
)"
Subject: FW: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Reply ISO Motions in
Limine]
Date: Thu, 28 Oct 2021 04:02:56 +0000
Attachments: Ms._Maxwell's_Reply_ISO_Motns_in_Limine.zip;, Govt_Reply_Brief_[unredacted].pdf
Inline-Images: image001.jpg
Hi Chiefs,
Attached is the defense reply brief and the final version of our brief.
Thanks,
From: Nicole Simmons
Sent: Wednesday, October 27, 2021 11:53 PM
To: 'Nathan NYSD Chambers'
Cc: Jeff Pagliuca
>; Laura Menninger
is
is
>;
is
(USANYS)
Subject: [EXTERNAL] U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Reply ISO Motions in Limine]
Dear Judge Nathan:
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Reply In Support of Her Motions in Limine and
supporting documents.
Regards,
Nicole Simmons
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
Denver, Colorado
www.hmflaw.com
EFTA00024232


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=== Page 1 ===
From:
"
)"
To:
(USANYS)"
Subject: Accepted: Call in Epstein FOIA
Date: Tue, 13 Apr 2021 14:58:19 +0000
Importance: Normal
Attachments: unnamed
EFTA00026915


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=== Page 1 ===
From:
To:
Subject: NPA
Date: Wed, 17 Feb 2021 22:52:35 +0000
Attachments: SDFL_privilege_log.pdf
Team,
In their motion on the NPA, the defense cites to this privilege log that SDFL filed in a civil case to support their assertion
that their investigation was coordinated with our office. On page 5 (see attached), there's an entry that reads:
File folder entitled
containing attorney
(
handwritten notes
I have no idea who this is, and a google search for this person yields no hits. No hits on the NY attorney registration page,
and no hits on SDNY ECF. Aside from emailing Ed to ask if he can find out if anyone with this name (or close to this name)
ever worked at SDNY, I'm not sure what other steps to take. Thoughts?
Thanks,
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
)"
(USANYS)"
(USANYS)"
,
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: Epstein 6(e) Order
Date: Fri, 20 Dec 2019 17:29:07 +0000
Attachments: 2019.12.20_Epstein_6(e)_Order_(signed).pdf
Judge Cote signed the 6(e) order, attached.
Note: anything we send to John Langbein has to comply with EOUSA secure shipping protocols (speak to
)
or EOUSA electronic encryption protocols (speak to IT services). We would look very bad if
any of this ended up someplace it shouldn't. Also give Langbein the necessary cautions.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
EFTA00027030


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=== Page 1 ===
From:
"
)"
To:
"
"
"
"
,
Subject: RE: Witness torpedoes Prince Andrew's denials about alleged Epstein sex slave I Toronto Sun
Date: Sat, 08 Feb 2020 19:44:05 +0000
Yeah thanks, I saw this -- one wonders if we had acquiesced to their insistence that we interview the client in person whether there
would have soon thereafter been an article about the meeting
Original Message
From:
)
Sent: Saturday, February 08, 2020 10:06
To:
i
Subject: Fwd: Witness torpedoes Prince Andrew's denials about alleged Epstein sex slave I Toronto Sun
Passing this along in case you didn't see it. Lisa Bloom's comment that her client is "cooperating" with our investigation is really
something.
V
>
https://torontosun.com/news/world/witness-torpedoes-prince-andrews-denials-about-alleged-epstein-sex-slave
>
>
> Sent from my iPhone
EFTA00023865


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=== Page 1 ===
From:
To:
Subject: Re: Epstein -- travel approval form
Date: Tue, 04 Feb 2020 18:01:51 +0000
No problem, I'm around whenever you're back.
On Feb 4, 2020, at 12:44,
wrote:
I may run late. Don't come till I call!
Sent from my iPhone
On Feb 3, 2020, at 5:45 PM,
wrote:
That works, thanks - just let me know if your schedule changes, otherwise l'Il come by at 1:00 tomorrow. Thanks again
and looking forward to it.
From:
Sent: Monday, February 03, 2020 16:07
To:
Subject: RE: Epstein -- travel approval form
Right now 1 p.m. looks open.
From:
Sent: Monday, February 3, 2020 1:33 PM
To:
Subject: RE: Epstein -- travel approval form
No problem at all, and I'm very flexible tomorrow afternoon - whatever time is good for you I can make work, so just
let me know and l'll put it in the calendar.
From:
Sent: Monday, February 03, 2020 13:31
To:
Subject: RE: Epstein -- travel approval form
So sorry for the delay. Maybe tomorrow? I have time in the afternoon.
From:
Sent: Friday, January 31, 2020 1:09 PM
EFTA00026969

=== Page 2 ===
To:
Subject: RE: Epstein -- travel approval form
Totally understand, and next week would be fine - let me know if it's helpful to set a time, and otherwise I'll touch
base midweek if we haven't connected by then.
And thanks very much re: the memo.
From:
Sent: Friday, January 31, 2020 12:53
To:
Cc:
Subject: RE: Epstein -- travel approval form
Already signed and sent upstairs
I will do my best to ensure signature immediately.
Re: this afternoon: it may be best to kick it to next week. If some time develops before 3, I'll let you know, but right
now it is iffy.
From:
Sent: Friday, January 31, 2020 12:21 PM
To:
Cc:
Subject: Epstein -- travel approval form
We dropped off the Sweden travel memo for you - we were unexpectedly significantly delayed in getting OIA approval,
but it finally came this morning, so with apologies for the short turnaround, hoping to get Office and final DOJ
approval this afternoon. Thank you!
And separately, if you still wanted to meet up today, l'll be around until about 3:00, but I'm also flexible next week if
that's easier.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00026970


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80811-CIV-
,
Plaintiff,
VS.
JEFFREY EPSTEIN and
.
Defendants.
/
PLAINTIFF'S NOTICE OF SERVING
SECOND AMENDED ANSWERS TO INTERROGATORIES
COMES NOW the Plaintiff,
"1 , by and through undersigned counsel, and
hereby files this Notice with the Court that Second Amended Answers to Interrogatories
propounded by the Defendant, JEFFREY EPSTEIN, on January 16, 2009, have been
furnished to the attorney for the Defendant.
I HEREBY CERTIFY that a true copy of the foregoing has been furnished by e-
mail this 28th day of October, 2009, to. See attached list of counsel.
JACK SCAROLA
Florida Bar No.: 169440
JACK P. HILL
Florida Bar No.: 0547808
Searcy Denney Scarola Barnhart & Shipley, P.A.
Attorney for Plaintiff(s)
s π EXHIBIT
Deponent MsAnlrins
Date 12/9/09 Rptr. OH
DEPOBOOK
EFTA00023624

=== Page 2 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
PLAINTIFF'S NOTICE OF SERVING
SECOND AMENDED ANSWERS TO INTERROGATORIES
3.
List all former names and when you were known by those names. State all
addresses where you have lived for the past 10 years, the dates you lived at
each address, your Social Security number, your date of birth, and, if you are or
have ever been married, the name of your spouse or spouses. List any children
by name, date of birth and the father's name and address. List the names and
address of your parents and any brother or sister.
ANSWER
Nickname-
Dates: July, 2007-Present
West Palm Beach, FL. 33417
Dates: February, 2004- July, 2007
West Palm Beach, FL.
Rome, Georgia
Dates: August, 2003-February, 2004
Dates: About 2 ½ years ago
West Palm Beach, FL. 33409
Dates: Approximately 1 year
West Palm Beach, FL. 33409
Dates: Unknown
Lake Park, FL
SSN-
DOB-
I have never been married.
Children:
Father:
Address:
West Palm Beach, FL. 33407
2
EFTA00023625

=== Page 3 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
Father:
Address: West Palm Beach, FL.
Parents:
Address Unknown
West Palm Beach, FL. 33417
Siblings:
)
West Palm Beach, FL. 33417
5.
Please provide the name, address, telephone number, place of employment and
job title of any person who has, claims to have or whom you believe may have
knowledge or information pertaining to any fact alleged in the pleadings (as
defined in Federal Rule of Civil Procedure 7(a) filed in this action, or any fact
underlying the subject matter of this action).
ANSWER
1.
c/o her attorneys:
Jack Scarola, Esq. and Jack P. Hill, Esq.
Searcy Denney Scarola Barnhart & Shipley, P.A.
West Palm Beach, FL 33409
Tel:
Richard Willits, Esq.
Richard H. Willits, P.A.
Lake Worth, FL 33461
Tel:
Subject matter:
Plaintiff.
3
EFTA00023626

=== Page 4 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
2.
Jeffrey Epstein
c/o his attorneys:
Robert Critton, Esquire
Burman Critton Luttier & Coleman LLP
West Palm Beach, FL 33414
Tel:
Jack A. Goldberger, Esquire
Atterbury, Goldberger & Weiss, P.A.
West Palm Beach, FL 33401
Tel:
Bruce E. Reinhart, Esquire
Bruce E. Reinhart, P.A.
West Palm Beach, FL 33401
Tel:
Subject matter:
Defendant
3.
's mother,
, and her brother,
c/o
's attorneys:
Jack Scarola, Esq. and Jack P. Hill, Esq.
Searcy Denney Scarola Barnhart & Shipley, P.A.
West Palm Beach, FL 33409
Tel:
Richard Willits, Esq.
Richard H. Willits, P.A.
Lake Worth, FL 33461
Tel:
Subject matter:
's involvement with Epstein.
4
EFTA00023627

=== Page 5 ===
C.M.A. VS. Epstein, et al.
Case No.: 08-CV-80811-CIV
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
4.
(Address unknown)
Subject matter: Defendant.
5.
Jane Doe (Case No.: 1:93-cv-01109-KAM)
c/o her attorney:
Theodore Leopold, Esquire
Leopold, Kuvin, P.A.
Palm Beach Gardens, FL 33410
Tel
Subject matter: Victim of Epstein.
6.
Jane Doe (Case No.: 502008CA020614)
c/o her attorney:
Isidro M. Garcia, Esquire
The Law Office of Brad Edwards & Associates, LLC
Subject matter: Victim of Epstein.
7.
Jane Doe #2 (Case No.: 9:08-cv-80119-KAM)
c/o her attorney:
Jeffrey M. Herman, Esquire
Herman & Mermelstein. P.A.
Subject matter: Victim of Epstein.
8.
Jane Doe #3 (Case No.: 9:08-cv-80232-KAM)
c/o her attorney:
5
EFTA00023628

=== Page 6 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
Jeffrey M. Herman, Esquire
Herman & Mermelstein. P.A.
Subject matter: Victim of Epstein.
9.
Jane Doe #5 (Case No.: 9:08-cv-80381-KAM)
c/o her attorney:
Jeffrey M. Herman, Esquire
Herman & Mermelstein, P.A.
Subject matter:
Victim of Epstein.
10.
Jane Doe #4 (Case No.: 9:08-cv-80380-KAM)
c/o her attorney:
Jeffrey M. Herman, Esquire
Herman & Mermelstein, P.A.
Subject matter:
Victim of Epstein.
11.
Jane Doe (Case No.: 9:08-cv-80804-KAM)
c/o her attorney:
Theodore Leopold, Esquire
Leopold, Kuvin, P.A.
Subject matter:
Victim of Epstein.
6
EFTA00023629

=== Page 7 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
12.
Jane Doe #7 (Case No.: 9:08-cv-80993-KAM)
c/o her attorney:
Jeffrey M. Herman, Esquire
Herman & Mermelstein, P.A.
Subject matter: Victim of Epstein.
13.
(Case No.: 502008CA025129XXXXMB AI
c/o her attorneys:
Jack Scarola, Esquire
Jack P. Hill, Esquire
Searcy Denney Scarola Barnhart & Shipley, P.A.
Tel:
Subject matter: Victim of Epstein.
14.
(Address unknown at this time)
Subject matter:
Jeffrey
.
15.
Palm Beach Police Department
Subject matter: Investigator.
7
EFTA00023630

=== Page 8 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-I
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
16.
Palm Beach County Prosecutors Office
West Palm Beach, FL 33401
Tel: (561) 355-7100
Subject matter:
Prosecutor.
17.
Detective
lead investigator
Palm Beach Police Department
Subject matter:
Investigator.
18.
Subject matter:
Former boyfriend of a victim of Epstein.
19. Sgt.
Palm Beach Police Department
Subject matter:
Investigator.
20.
Subject matter:
Plaintiff's former boyfriend.
21.
Tony Higgins, supervisor
Sanitation Bureau of the Town of Palm Beach
8
EFTA00023631

=== Page 9 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
Tel:
(
Subject matter:
The incident which is the subject matter
of this lawsuit. Discovery is ongoing.
22.
Palm Beach County Sheriff's Office
Subject matter:
Investigator.
23.
,
friend of
(Address will be provided upon receipt)
Subject matter:
Victim and friend of
24. Ghislane Maxwell c/o Ghislane Corp.
Subject matter:
Associate of Epstein.
25.
Parent Child Center
Subject matter:
Counselor at Parent Child Center.
26.
Detective
Palm Beach Police Department
Subject matter:
Investigator.
27. Chief
Palm Beach Police Department
9
EFTA00023632

=== Page 10 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
Tel:
Subject matter:
Investigator.
28.
(Address unknown at this time)
Subject matter:
Associate of Epstein who facilitated introductions
with various victims.
29.
(Address unknown at this time)
Subject matter:
Employee of Epstein.
30.
Detective
Palm Beach Police Department
Subject matter:
Investigator
31.
First Assistant U.S. Attorney
U.S. Dept. of Justice
Tel:
Subject matter:
Federal prosecutor.
32.
Federal Bureau of Investigation
Subject matter:
Investigator.
10
EFTA00023633

=== Page 11 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
33.
Address will be provided upon receipt
West Palm Beach
Subject matter:
's physician.
34.
Assistant U.S. Attorney
U.S. Dept. of Justice
Tel:
Subject matter:
Federal prosecutor.
35.
friend of
mother
(Address will be provided upon receipt)
Subject matter:
Friend of
mother.
36.
friend of
's mother
(Address will be provided upon receipt)
Subject matter:
Friend of
's mother
37.
, friend of
(Address will be provided upon receipt)
Subject matter:
Potential victim and friend of
38.
(Address unknown at this time)
Subject matter:
Associate of Epstein who may have been involved
in encounters between Epstein and
39.
, friend of
(Address unknown at this time)
11
EFTA00023634

=== Page 12 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
40.
(last name unknown), friend of
(Address unknown at this time)
7.
Were you suffering from physical infirmity, disability, disease, sickness, or
psychiatric/psychological condition at the time of the incident(s) described in the
complaint? If so, what was the nature of the infirmity, disability, or sickness?
ANSWER
8.
Did you consume any alcoholic beverages or take any drugs or medications
within 12 hours before the time of each incident(s) described in the complaint? If
so, state the type and amount of alcoholic beverages, drugs, or medication which
were consumed, and when (dates) and where you consumed them.
ANSWER
1. On one occasion I had taken "Morning Glory" and "Angel Trumpets". I
do not recall the date.
2. On more than one occasion I used cocaine powder. I do not recall the
dates.
3. On more than one occassion I used marijuana. I do not recall the dates.
11.
List the names and business addresses of each physician (including psychiatrist,
psychologist, chiropractor or medical provider) who has treated or examined you,
and each medical facility where you have received any treatment or examination
for the injuries for which you seek damages in this case; and state as to each the
date of treatment or examination and the injury or condition for which you were
examined or treated.
ANSWER
Date: I do not recall the date.
I would defer to the Doctor's records.
12
EFTA00023635

=== Page 13 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-I
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
Date: Since high school. Ongoing.
Date: I do not recall the dates,
15.
List all dates you allege you were at Mr. Epstein's home in Florida, include date,
time arrived and left, the name(s) of anyone who went with you to the home
when you were there, the time spent with Mr. Epstein and the name(s) and
address of any individuals who were present in the home with Mr. Epstein and
you.
ANSWER
From May or June of 2002 to August of 2003 I went to Mr. Epstein's home
on average 2 times a week. There were weeks when I would go 4 times a
week. All my visit dates were maintained by Jeffrey Epstein and his staff in
a phone message book kept on a table by the phone in the kitchen.
Please refer to #5 above and #16 below.
Discovery is ongoing.
16.
State in detail how you came to be at Mr. Epstein's home on each occasion, i.e.
did someone bring you or ask you if you would or wanted to go; if so, state the
name and address of that individual and what he/she told you and the purpose of
your visit.
ANSWER
I was introduced to Jeffrey Epstein by my friend
in 2002. I was to
give Jeffrey Epstein a massage. I continued to provide massages up until
August of 2003. I was transported to Jeffrey Epstein's house by Yellow
Cab, provided by Jeffrey Epstein,
ny ex- boyfriend
my mother
and my brother
I was also
transported via private car provided by Jeffrey Epstein.
(Address will be provided upon receipt)
13
EFTA00023636

=== Page 14 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
23.
State the names, addresses, ages, phone numbers and dates of all females
whom you claim were brought by you to Mr. Epstein's home to give him a
massage or for any other reason. As to each female, state the amount of money
you claim you were paid to bring each female.
ANSWER
Age: 22
I was paid $100.00
(last name unknown)
(Address unknown)
I was paid $100.00
(Address unknown)
I was paid $100.00
14
EFTA00023637

=== Page 15 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
Signature of Answering Party
STATE OF Florida
)
COUNTY OF
Palm Beach )
The foregoing instrument was acknowledged before me this
day of
February, 2009 by
who is personally known to me or who has
produced
(type of identification) as identification
and who did/did not take an oath.
Notary Public
State of Florida at Large
My Commission expires:
Commission No:
15
EFTA00023638

=== Page 16 ===
VS. Epstein, et al.
Case No.: 08-CV-80811-CIV-
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
COUNSEL LIST
Jack A. Goldberger
Atterbury, Goldberger & Weiss, P.A.
Phone:
Attorneys for Jeffrey Epstein
Bruce E. Reinhart, Esquire
Bruce E. Reinhart, P.A.
Phone:
Fax:
Attorneys for
Robert Critton
Burman Critton Luttier & Coleman LLP
Phone:
Fax:
Attorneys for Jeffrey Epstein
Richard H. Willits, Esquire
Richard H. Willits, P.A.
Phone:
Fax:
Attorneys for Party
16
EFTA00023639

=== Page 17 ===
VERIFICATION
being duly sworn, deposes and says that the foregoing answers to
interrogatories are true and correct to the best of her knowledge, information and belief.
STATE OF FLORIDA
)
) SS
COUNTY OF PALM BEACH
)
SWORN TO AND SUBSCRIBED before me this 20 day of October , 2009 by
who is personally known to me or has produced the following
identification
.
Notary Public State of Florida
Michael I Danchuk
My Commission DD910406
MICHAEL DANCHUK
Expires 10/03/2018
Notary - Print Name
(SEAL)
ndl
Notary - Signature
EFTA00023640


c1: EFTA00025378
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025378.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 20-3061 United States of America V. Maxwell "So-Ordered Scheduling Notification FILED"
Date: Wed, 16 Sep 2020 16:03:34 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 09/16/2020
Case Name:
United States of America V. Maxwell
Case Number: 20-3061
Document(s): Document(s)
Docket Text:
SO-ORDERED SCHEDULING NOTIFICATION, setting Appellant Ghislaine Maxwell Brief due date as
10/22/2020. Joint Appendix due date as 10/22/2020, FILED.[2932112] [20-3061]
Notice will be electronically mailed to:
Ty Gee,
Laura Menninger, -:
Adam Mueller, -:
Gerard Whidbee, Deputy Clerk:
Notice will be stored in the notice cart for:
Gerard Whidbee, Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: So_ordered_sched_notification
Original Filename:
/opt/ACECF/live/forms/GerardWhidbee_203061_2932112_So_Ordered_sched_notification_apt_308.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=09/16/2020] [FileNumber=2932112-0]
EFTA00025378

=== Page 2 ===
[8dbfe264d96f6f57f00d5e6d842a467232ebcfadd620b719de59f49f818ac8bba568ee82817f805353ba53e19499af
d8fa01fee8bcdc150a215764cd11f2ac22]]
Recipients:
Ty Gee, -
Laura Menninger, -
Adam Mueller, -
Quality Control 1
Gerard Whidbee, Deputy Clerk
EFTA00025379


c1: EFTA00024812
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024812.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Device spreadsheet
Date: Fri, 06 Nov 2020 00:09:07 +0000
Attachments: Spreadsheet_of_Epstein_Electronic_Devices_in_SWs.xlsx
Attached is the updated device spreadsheet. Certain highlighted items were added (they were the overall
parent machine NYC number). Give me a call if you have questions.
EFTA00024812


c1: EFTA00025556
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025556.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Bec: "USAHUB-USAJournal111"
Subject: FW: following up
Date: Tue, 15 Dec 2020 16:56:52 +0000
Embedded: FW:_following_up.msg
Sender:
Subject: FW: following up
Message-Id:
<SN5P110MB05421A9E7283195F234CE48E92C60@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM>
To:
To:
EFTA00025556


c1: EFTA00026443
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026443.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Epstein pre-meet
Date: Sat, 06 Apr 2019 18:28:18 +0000
Importance: Normal
Attachments: unnamed
EFTA00026443


c1: EFTA00026831
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026831.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
Cc:
"
Bcc: "USAHUB-USAJournal111"
Subject: Re: search terms for devices
Date: Sat, 10 Oct 2020 13:17:14 +0000
Embedded: Re:_search_terms_for_devices.msg
Sender:
Subject: Re: search terms for devices
Message-Id: <3E05EFD3-674F-4E63-ACB4-D867963FD22C@usa.doj.gov>
To:
Cc:
EFTA00026831


c1: EFTA00025137
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025137.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
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EFTA00025137
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c1: EFTA00026785
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026785.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Call with
counsel
Date: Thu, 20 Feb 2020 17:27:22 +0000
Importance: Normal
Attachments: unnamed
EFTA00026785


c1: EFTA00026583
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026583.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
,
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Brief for Bank
Date: Tue, 06 Oct 2020 13:16:41 +0000
Attachments: Government's_Brief_as_Filed.pdf
Same
From:
(USANYS)
Sent: Tuesday, October 06, 2020 8:56 AM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
Subject: RE: Brief for Bank
Hi
Attached is a brief filed today for the bank. Thank you!
From:
(USANYS)
Sent: Tuesday, September 29, 2020 1:16 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
;
(USANYS)
Subject: RE: Brief for Bank
Here's another. Thanks.
From:
(USANYS)
Sent: Tuesday, September 29, 2020 12:46 PM
To:
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
>;
(USANYS)
is
(USANYS)
Subject: Brief for Bank
Here is one we filed today. Thanks,
Assistant United States Attorney
Southern District of New York
Office:
Cell:
Email:
EFTA00026583

=== Page 2 ===
EFTA00026584


c1: EFTA00024903
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024903.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Phone Numbers Searched in Relativity
Date: Fri, 19 Nov 2021 23:05:09 +0000
Attachments: Phone_Checks_in_Relativity.docx
Good evening,
Attached is the updated document. I listed in RED where new info is provided.
Thanks,
From:
Sent: Thursday, November 18, 2021 6:24 PM
To:
(USANYS)
)
Cc:
(NY) (FBI)
(NYPD)
Subject: Phone Numbers Searched in Relativity
Good evening-
Regarding the list of numbers to be queried in Relativity I've completed the first 4. There are several "hits" but not all are
exact matches and need to be sorted through.
I organized the info in a Word Doc reflecting results under the first section US VS Epstein as "JE" and the second part with
the search warrants as "JE SW". Each positive match has the control number and a brief description of what it consists of.
As I continue to work on it I will send it with updated results.
Thanks,
EFTA00024903


c1: EFTA00026645
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026645.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
)"
,
)"
Subject: Epstein bail hearing
Date: Mon, 08 Jul 2019 20:41:21 +0000
Importance: Normal
Attachments: unnamed
EFTA00026645


c1: EFTA00026920
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026920.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
Subject: RE: Epstein FOIA Next Steps - Noel Team
Date: Tue, 13 Apr 2021 18:46:23 +0000
Don't change your plans. We'll make 10 am work to accommodate
important and busy schedule.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 2:13 PM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
I have plans this evening, but if 6pm is the only time, I can do it then.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 2:11 PM
To:
(USANYS)
V.
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
Have a proffer then, sorry.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 2:10 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
That window works for me.
?
From:
(USANYS)
Sent: Tuesday, April 13, 2021 2:09 PM
To:
(USANYS)
Cc:
(USANYS)
in
(USANYS)
Subject: Re: Epstein FOIA Next Steps - Noel Team
I'd have to move something but can do if nothing else works. I am wide open between 12 and 3 if there's anything good
during that time.
Sent from my iPhone
On Apr 13, 2021, at 1:26 PM,
(USANYS)
wrote:
Tomorrow morning fairly booked for me, but do have 10-10:30 if that's better for everyone.
EFTA00026920

=== Page 2 ===
From:
(USANYS)
Sent: Tuesday, April 13, 2021 1:26 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
This afternoon isn't ideal. I can do 6pm if absolutely necessary, but I would prefer any time tomorrow morning.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 1:10 PM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
Doesn't work for me. Could you do 6pm?
Original Appointment
From:
(USANYS)
Sent: Tuesday, April 13, 2021 1:09 PM
To:
(USANYS);
(USANYS);
(USANYS)
Subject: Epstein FOIA Next Steps - Noel Team
When: Tuesday, April 13, 2021 4:00 PM-4:30 PM (UTC-05:00) Eastern Time (US & Canada).
Where:
"
,
please let me know if this time doesn't work-Russell has availability tomorrow as well. Thanks.
Please use dial in
with passcode
EFTA00026921


c1: EFTA00025269
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025269.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
Cc:
Subject: RE: press release: Acting U.S. Attorney Announces Charges Against Correctional Officer
Who Demanded Bribe In The Form Of Sex From A Female Prison Visitor
Date: Thu, 01 Oct 2020 17:47:20 +0000
Inline-Images: image001.png
I thought they also participated in the interview of
which was done as part of the Epstein investigation, when he
took 5?
We probably should have included them. My fault. l'll call Guido and apologize.
From:
Sent: Thursday, October 1, 2020 11:23 AM
To:
is
is
(USANYS)
Cc:
Subject: RE: press release: Acting U.S. Attorney Announces Charges Against Correctional Officer Who Demanded Bribe In
The Form Of Sex From A Female Prison Visitor
Did
participate in the first interview of
before we got involved? I think that was it
From:
Sent: Thursday, October 1, 2020 11:17 AM
To:
i
V.
is
(USANYS)
Cc:
Subject: RE: press release: Acting U.S. Attorney Announces Charges Against Correctional Officer Who Demanded Bribe In
The Form Of Sex From A Female Prison Visitor
I'm not aware of any. They were included in the press release because they were going to provide some
assistance with the arrest.
From:
Sent: Thursday, October 1, 2020 11:12 AM
To:
is
is
is
(USANYS)
Cc:
Subject: RE: press release: Acting U.S. Attorney Announces Charges Against Correctional Officer Who Demanded Bribe In
The Form Of Sex From A Female Prison Visitor
Maybe I'm totally spacing something out, but which OIG agent worked on this?
From:
Sent: Thursday, October 1, 2020 11:10 AM
EFTA00025269

=== Page 2 ===
To:
i
>;
in
(USANYS)
Cc:
Subject: FW: press release: Acting U.S. Attorney Announces Charges Against Correctional Officer Who Demanded Bribe In
The Form Of Sex From A Female Prison Visitor
Just forwarding FYI.
From:
Sent: Thursday, October 1, 2020 11:03 AM
To:
>;
Cc:
Subject: press release: Acting U.S. Attorney Announces Charges Against Correctional Officer Who Demanded Bribe In The
Form Of Sex From A Female Prison Visitor
Good morning
I wanted to follow up on a press release from your office from earlier this week entitled, " Acting U.S.
Attorney Announces Charges Against Correctional Officer Who Demanded Bribe In The Form Of Sex From
A Female Prison Visitor."
The press release lists DOI OIG as a supporting law enforcement agency at the end of the release.
However, I spoke with our Special Agent in Charge in New York and we believe we should have been listed
as an announcing agency. Our contributions to this case were significant, and we'd ask that for future
press releases, you include our SAC as an announcing official. Please feel free to reach out with any
questions, I'm at 202-579-7511.
Thank you.
https://www.justice.gov/usao-sdny/pr/acting-us-attorney-announces-charges-against-correctional-officer-
who-demanded-bribe
DEPARTMENT
JUSTICE
.......
PHINE
Senior Public Affairs Specialist
U.S. Department of Justice
Office of the Inspector General
@JusticeOIG
@OversightGov
@COVID_Oversight
EFTA00025270


c1: EFTA00023506
c2: DataSet 8
c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
INVESTIGATIVE CASE MANAGEMENT
Collected Items for a Case
08/10/2007
RUN BY:
MM03-COLLECTED ITEMS FOR A CASE_31E-MM-108062-000001
EFTA00023506

=== Page 2 ===
08/10/07
Collected Items for a Case
ICMIPR05
15:15:35
Case ID: 31E-MM-108062
PAGE
1
Collected Item Type: All
Category Type: 18
Cat/Num
Acquired/
Charged Out To/
Contributor/
Barcode
Office and Storage Location
Type Chrged Out
Reason
Description
181
MM
G 08/28/2006
DET.
08/28/2006 COLLECTED
1) ONE PHONE MESSAGE BOOK
PBPD05-1024(1)
2) THREE PHONE MESSAGE BOOKS
(2)
3) ONE FILE FOLDER WITH TWO FILES
(3)
4) SHREDDED PAPER
(4)
5) ONE FILE FOLDER - ORANGE
(5)
6) BEIGE MASSAGE TABLE
(6)
7) BROWN MASSAGE TABLE
(7)
8) BLACK FRAMED PHOTO OF NUDE GIRL
(8)
9) NINE PICTURES IN FRAMES
(9)
10) EIGHT PHOTOS FROM OFFICE
(10)
11) TWO PHOTOS - SITTING ROOM
(11)
12) TWO PHOTOS - TABLE
(12)
13) TWO VHS TAPES - POOL AREA
(13)
14) TWO CDS - MARKED "HAPPY BIRTHDAY"
(14)
15) THREE FRAMED PHOTOS - CABANA
(15)
16) ONE MESSAGE PAD - 1ST FLOOR
(16)
17) ONE MESSAGE PAD - DESK
(17)
18) THREE CDS - DESK
(18)
19) ONE 8MM - DESK
(19)
20) UNFRAMED PHOTOS - DESK
(20)
21) TWO FRAMED PHOTOS - DESK
(21)
22) TWO FRAMED PHOTOS - TABLE
(22)
23) THREE SOAPS ON A ROPE
(23)
24) TWO VIBRATORS - "TWIN TORPEDO"
(24)
25) TWO SOAPS ON A ROPE
(25)
26) ONE LARGE FRAMED PICTURE MASTER BEDROOM
(26)
27) ONE HIGH SCHOOL TRANSCRIPT = AH
(27)
28) ONE BOTTLE OF JOY JELLY - MASTER BEDROOM
(28)
29) THREE VIDEO TAPES MASTER BEDROOM
(29)
30) SIX FRAMED PHOTOS MASTER BEDROOM, BATHROOM
(30)
MM03-COLLECTED ITEMS FOR A CASE_31E-MM-108062-000002
EFTA00023507

=== Page 3 ===
08/10/07
Collected Items for a Case
ICMIPR05
15:15:35
Case 10: 31E-MM-108062
PAGE
2
Collected Item Type: All
Category Type: 1B
Cat/Num
Acquired/
Charged Out To/
Contributor/
Barcode
Office and Storage Location
Type Chrged Out
Reason
Description
182
MM
G 08/28/2006
DET.
08/28/2006 COLLECTED
31) ONE GREEN MASSAGE TABLE
PBPD05-1024 (31)
32) ONE THRIFTY RENTAL AGREEMENT
(32)
33) NOTE FROM
(33)
34) ELEVEN CDS - OFFICE
(34)
35) MESSAGE BOOK - GUEST HOUSE
(49)
(36) ONE MESSAGE BOOK
(50)
(37) TWO COMPACT FLASH CARDS
(51)
(38) SIX CDS - GUEST HOUSE
(52)
(39) POWER CORD TO CPU - GUEST HOUSE
(54)
(40) CPU - OFFICE
(55)
41) ONE POWER CORD TO CPU - OFFICE
(56)
42) THREE CDS - OFFICE
(57)
43) ONE PEACH MASSAGE TABLE
(58)
44) ONE GREEN FRAMED PHOTO
(59)
MM03-COLLECTED ITEMS FOR A CASE_31E-MM-108062-000003
EFTA00023508

=== Page 4 ===
08/10/07
Collected Items for a Case
ICMIPR05
15:15:35
Case ID: 31E-MM-108062
PAGE
3
Collected Item Type: All
Category Type: 1B
Cat/Num
Acquired/
Charged Out To/
Contributor/
Barcode
Office and Storage Location
Type Chrged Out
Reason
Description
183
MM
G 08/28/2006
DET
08/28/2006 COLLECTED
1) TAPED CONVERSATION
PBPD 05-237(1)
2) AUDIO TAPE #1
PBPD 05-243(1)
3) AUDIO TAPE #2
(2)
4) COPY OF TAPE #1
(3)
5) MICRO TAPE
PBPD 05-256(1)
6) PHOTO LINE-UP
PBPD 05-257(1)
7) AUDIO TAPE
PBPD 05-294(1)
8) MICRO TAPE
(2)
9) CD
PBPD 05-295(2)
10) C-90 CASSETTE
PBPD 05-313(1)
11) A/X MAIL
PBPD 05-378(1)
12) WHITE PAPER
(2)
13) MESSAGE
(3)
14) WHITE PAPER J
(4)
15) MONTGOMERY COUNTY, MD
(5)
16) WHITE PAPER V.
PBPD 05-379(1)
17) WHITE PAPER FLIGHT INFO
(2)
18) THREE WHITE PAPERS PREMIO COMPUTER INC
(3)
19) WHITE PAPER PHONE #
PBPD 05-380(1)
20) YELLOW RECEIPT 04/04/05
(2)
21) WHITE PAPER
(3)
22) WHITE PAPER J.
(4)
23) WHITE PAPER FLIGHT 04/05/05
(5)
24) WHITE PAPER G.
(6)
MM03-COLLECTED ITEMS FOR A CASE_31E-MM-108062-000004
EFTA00023509

=== Page 5 ===
08/10/07
Collected Items for a Case
ICMIPR05
15:15:35
Case ID: 31E-MM-108062
PAGE
4
Collected Item Type: All
Category Type: 1B
Cat/Num
Acquired/
Charged Out To/
Contributor/
Barcode
Office and Storage Location
Type Chrged Out
Reason
Description
184
MM
G 08/28/2006
DET.
08/28/2006 COLLECTED
1) WHITE PAPER A.
PBPD 05-381(1)
2) WHITE PAPER JET BLUE RECEIPT
(2)
3) WHITE PAPER JU.
(3)
4) WHITE PAPER JO.
(4)
5) MESSAGE
(5)
6) WHITE PAPER
(6)
7) WHITE PAPER A.
(7)
8) WHITE PAPER
(8)
9) WHITE PAPER H.
(9)
10) WHITE PAPER ST. BARTHS
(10)
11) MESSAGE - G.
(11)
12) MESSAGE
(12)
13) WHITE PAPER - F.
(13)
14) MESSAGE S.
(14)
15) MESSAGE
(15)
16) MESSAGE
GIRL
(16)
17) WHITE PAPER . S.
(17)
18) WHITE PAPER #'S
(18)
19) WHITE PAPER - J.
(19)
20) WHITE PAPER - J.
(20)
21) WHITE PAPER (917)
(21)
22) WHITE PAPER
(22)
23) PHONE # PRINT OUT
(23)
MM03-COLLECTED ITEMS FOR A CASE_31E-MM-108062-000005
EFTA00023510

=== Page 6 ===
08/10/07
Collected Items for a Case
ICMIPR05
15:15:35
Case ID: 31E-MM-108062
PAGE
5
Collected Item Type: All
Category Type: 1B
Cat/Num
Acquired/
Charged Out To/
Contributor/
Barcode
Office and Storage Location
Type Chrged Out
Reason
Description
185
MM
G 08/28/2006
DET
08/28/2006 COLLECTED
1) FIVE MESSAGE PRINTOUTS
PBPD 05-382(1)
2) WHITE PAPER C. J.
(2)
3) MESSAGE
(3)
4) MESSAGE
(4)
5) MESSAGE A.
(5)
6) MESSAGE
(6)
7) MESSAGE T.
(7)
8) CLEAR PLASTIC STICK
(8)
9) TWELVE WHITE PAPER - EXPENDITURES
PBPD 05-383(1)
10) WHITE PAPER J.
(2)
11) WHITE PAPER D.
(3)
12) WHITE PAPER C.
(4)
13) WHITE PAPER J.
(5)
14) WHITE PAPER J.
(6)
15) WHITE PAPER
(7)
16) WHITE PAPER #
(8)
17) MESSAGE A.
PBPD 05-384(1)
18) WHITE PAPER T.
(2)
19) WHITE PAPER
(3)
20) WHITE PAPER F.
(4)
21) MESSAGE
(5)
22) MESSAGE #
(6)
23) MESSAGE
(7)
24) WHITE PAPER
(8)
25) WHITE PAPER (917)
PBPD 05-385(1)
26) WHITE PAPER A.
(2)
27) WHITE PAPER E.
(3)
28) WHITE PAPER
(4)
29) WHITE PAPER
(5)
30) FOUR WHITE PAPERS
(6)
MM03-COLLECTED ITEMS FOR A CASE_31E-MM-108062-000006
EFTA00023511

=== Page 7 ===
08/10/07
Collected Items for a Case
ICMIPR05
15:15:35
Case ID: 31E-MM-108062
PAGE
6
Collected Item Type: ALL
Category Type: 1B
Cat/Num
Acquired/
Charged Out To/
Contributor/
Barcode
Office and Storage Location
Type Chrged Out
Reason
Description
186
MM
G 08/28/2006
DET
08/28/2006 COLLECTED
1) MEDICAL SUPPLIES
PBPD 05-386(1)
2) 727 LETTERHEAD
(2)
3) INVOICE #42700
(3)
4) AMAZON.COM
(4)
5) WHITE PAPER
(5)
6) MESSAGE FROM J.
(6)
7) MESSAGE FROM
(7)
8) WHITE PAPER 2#S
(8)
9) WHITE PAPER (917)
(9)
10) MISC. DOCUMENTS - TRASH PULL
PBPD 05-874(1)
11) MISC. PAPERWORK TRASH PULL
PBPD 05-878(1)
12) TWO MAGAZINES TRASH PULL
PBPD 05-901(1)
13) PAPER WITH
TRASH PULL
PBPD 05-915(1)
14) VHS T-160 CASSETTE
PBPD 05-929(1)
15) SONY MICRO CASSETTE
(2)
16) SONY MICRO CASSETTE
(3)
17) SONY MICRO CASSETTE
(4)
18) SONY MICRO CASSETTE
PBPD 05-937(1)
19) SONY MICRO CASSETTE
(2)
20) SONY MICRO CASSETTE
(3)
21) SONY MICRO CASSETTE
(4)
22) MISC PAPERWORK - TRASH PULL
PBPD 05-941(1)
23) SONY MICRO CASSETTE
PBPD 05-942(1)
24) SONY MICRO CASSETTE
(2)
25) MISC PAPERS TRASH PULL
PBPD 05-943(1)
26) CLEAR PIECE OF PLASTIC
PBPD 05-944(1)
27) MISC PIECES OF PAPER TRASH PULL
(2)
28) SONY MICRO CASSETTE
PBPD 05-945(1)
29) SONY MICRO CASSETTE
(2)
MM03-COLLECTED ITEMS FOR A CASE_31E-MM-108062-000007
EFTA00023512

=== Page 8 ===
08/10/07
Collected Items for a Case
ICMIPR05
15:15:35
Case ID: 31E-MM-108062
PAGE
7
Collected Item Type: All
Category Type: 1B
Cat/Num
Acquired/
Charged Out To/
Contributor/
Barcode
Office and Storage Location
Type Chrged Out
Reason
Description
187
MM
G 08/28/2006
DET
08/28/2006 COLLECTED
1) SONY MICRO CASSETTE
PBDP 05-972(1)
2) SONY MICRO CASSETTE
(2)
3) SONY MICRO CASSETTE
(3)
4) MISC PAPERWORK - TRASH PULL
PBPD 05-1005(1)
5) THREE FLOOR PLANS
PBPD 05-1023(1)
6) DRAWING
PBPD 05-1025(1)
7) MISC PHONE MESSAGES - TRASH PULL
PBPD 05-1027(1)
8) T-160 VIDEO CASSETTE
PBPD 05-1052(1)
9) SONY MICRO CASSETTE
(2)
10) SONY MICRO CASSETTE
PBPD 05-1064(1)
11) THREE EMAIL FROM DMV/DL
(2)
12) VHS VIDEO CASSETTE
PBPD 05-1069(1)
13) VHS VIDEO CASSETTE
(2)
14) CD
PBPD 05-1079(2)
15) MINI DV TAPE
PBPD 05-1080(1)
16) VHS VIDEO TAPE...
(2)
17) MINI DV TAPE
(3)
18) SONY MICRO CASSETTE
PBPD 05-1087(1)
19) SONY MICRO CASSETTE
PBPD 05-1090(1)
20) SONY MICRO CASSETTE
PBPD 05-1092(1)
21) PHOTO LINE-UP
(2)
22) SONY MICRO CASSETTE
PBPD 05-1203(1)
MM03-COLLECTED ITEMS FOR A CASE_31E-MM-108062-000008
EFTA00023513

=== Page 9 ===
08/10/07
Collected Items for a Case
ICMIPR05
15:15:35
Case ID: 31E-MM-108062
PAGE
8
Collected Item Type: All
Category Type: 18
Cat/Num
Acquired/
Charged Out To/
Contributor/
Barcode
Office and Storage Location
Type Chrged Out
Reason
Description
188
MM
G 08/28/2006
DET
08/28/2006 COLLECTED
1) VHS TAPE OF SURVEILLANCE
PBPD 05-1205(1)
2) VHS TAPE OF SURVEILLANCE
(2)
3) VHS TAPE
(3)
4) VHS TAPE
(4)
5) VHS TAPE
(5)
6) VHS TAPE
(6)
7) VHS TAPE
(7)
8) SIXTEEN DVD-R DISCS PBSO
PBPD 05-1219(1)
9) CINGULAR ENVELOPE WITH SUBPOENA INFO
PBPD 05-1245(1)
10) CINGULAR WIRELESS CD
(2)
11) SONY MICRO CASSETTE
PBPD 06-21(1)
12) GREEN FOLDER A.
PBPD 06-24(1)
13) SONY MICRO CASSETTE
PBPD 06-39(1)
14) SONY MICRO CASSETTE
PBPD 06-59(1)
15) SONY MICRO CASSETTE
PBPD 06-95(1)
16) T-160 VIDEO CASSETTE
PBPD 06-120(1)
17) SONY MICRO CASSETTE
PBPD 06-182(1)
18) SONY MICRO CASSETTE
PBPD 06-348(1)
19) CD
PBPD 06-397(1)
189
MM
G 04/30/2007
04/30/2007 COLLECTED
1) BOOK - AN INVITATION TO POETRY
2) VICTORIA'S SECRET WHITE BRA AND PANTIES SET
1B10
MM
G 08/07/2007
08/07/2007 COLLECTED
ONE (1) BOOK-MASSAGE FOR DUMMIES
MM03-COLLECTED ITEMS FOR A CASE_31E-MM-108062-000009
EFTA00023514

=== Page 10 ===
08/10/07
Collected Items for a Case
ICMIPR05
15:15:35
Case ID: 31E-MM-108062
PAGE
9
Collected Item Type: All
Category Type: 18
Cat/Num
Acquired/
Charged Out To/
Contributor/
Barcode
Office and Storage Location
Type Chrged Out
Reason
Description
REPORT TOTAL:
10
MM03-COLLECTED ITEMS FOR A CASE_31E-MM-108062-000010
EFTA00023515


c1: EFTA00023974
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023974.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
90A-NY-3151227 Serial 8
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Evidence
Date: 08/14/2019
NYC023582
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) MCC-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Evidence NYC023582: One (1) Hitachi 500GB HDD,
HDS721050CLA662, S/N JP1572JE36MWNK, from MCC Nice Vision DVR2
Surveillance System (5 of 18).
Item Type
Description
1B Digital
(U) NYC023582: One (1) Hitachi 500GB HDD,
HDS721050CLA662, S/N JP1572JE36MWNK, from MCC Nice
Vision DVR2 Surveillance System (5 of 18).
Collected On: 08/10/2019 04:30 PM EDT
Seizing Individual:
Located By:
Device Type: Hard Drive
Designation: Original
Number of Devices Collected: 1
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00023974


c1: EFTA00025102
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025102.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event:
proffer (re abuse)
Start Date: 2019-12-04 19:00:00 +0000
End Date: 2019-12-04 22:00:00 +0000
Organizer:
Location: Winston & Strawn offices, 200 Park Ave
Class: X-PERSONAL
Date Created: 2019-11-27 17:28:21 +0000
Date Modified: 2019-11-27 17:28:21 +0000
Priority: 5
DTSTAMP: 2019-11-27 16:35:45 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00025102


c1: EFTA00024742
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024742.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
(NY) (FBI)"
)"
i
(USANYS)"
Subject: Re:
Date: Wed, 28 Oct 2020 16:18:34 +0000
Hi
,
Thanks- this attorney also represents
,
who we have wanted to follow up with as well, as soon as
we complete discovery. We will reach out to him in early to mid November about both witnesses.
Thanks,
Sent from my iPhone
On Oct 27, 2020, at 5:18 PM,
wrote:
Just met with
and his daughter. We could not find a good phone number for him but he does not live
that far from the city so we knocked on his door. His daughter advised us that his English is not good and she
would translate for him. I told him we would just like to speak to him about his former employer over video
conference. They acknowledged that they knew I was referring to Epstein. She told us he is currently
represented by Aitan Gohlman
and they prefer all communications go through him. Do you
guys wanna take it from here?
On Oct 27, 2020, at 13:14,
)
wrote:
I should add: if he prefers to meet in person and you want to do a field interview without us in the first
instance, that's fine. Thanks.
Sent from my iPhone
On Oct 27, 2020, at 12:38 PM,
wrote:
Also, if he's willing to come into our office would you guys be ok with doing that or do you still prefer
Webex?
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Offic
Cell:
Fax:
EFTA00024742

=== Page 2 ===
From:
Sent: Tuesday, October 27, 2020 12:30 PM
To:
)
is
(NY) (FBI)
Cc:
)
>;
(USANYS)
Subject: Re:
He currently lives on Long Island. I can reach out and see if he's willing to chat with us. Would you like to
provide us with a subpoena for him?
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Offic
Cell:
Fax:
From:
Sent: Wednesday, October 21, 2020 8:53 PM
To:
(NY) (FBI)
is
Cc:
is
(USANYS)
Subject:
,
What do you think of reaching out to
for an interview? Happy to discuss next time we
speak-can you check to see if he is in the area?
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00024743


c1: EFTA00023749
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023749.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Subject: filing
Date: Wed, 16 Sep 2020 20:52:58 +0000
Attachments: 2020-09-16_GM_ex-parte_discovery_letter.v4.docx
Here's the final version - can you take a last look? Thanks.
Assistant United States Attorney
Southern District of New York
EFTA00023749


c1: EFTA00026804
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026804.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
Subject: RE: Call re Epstein responsiveness review
Date: Tue, 13 Oct 2020 14:30:17 +0000
Hello
Please do not think I forgot about you as I am working on getting this hard drive out the door today. I will give you a call
back as soon as I can.
Thank you.
From:
Sent: Tuesday, October 13, 2020 9:35 AM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: Re: Call re Epstein responsiveness review
Thanks very much,
I'll call you at 10am.
On Oct 13, 2020, at 8:53 AM,
(USANYS) [Contractor]
wrote:
Good Morning
I am available for a call between 9 - 11 am this morning and between 12:30 and 2 PM today. Please let me know what
time works for you.
Thank you.
From:
Sent: Sunday, October 11, 2020 7:54 PM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: Call re Epstein responsiveness review
H
Hope you're having a nice weekend. Is there a time on Tuesday when you would be available for a call to discuss the
responsiveness review of the Epstein SW returns on Relativity, please?
I'm available the entire morning if there's a time that would work for you.
Thanks,
EFTA00026804

=== Page 2 ===
EFTA00026805


c1: EFTA00023798
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023798.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Gary Bloxsome
To:
)"
Cc:
)"
)"
Daniel Cundy
"Jennifer
,
Richardson"
Subject: Re: Sensitive correspondence.
Date: Mon, 08 Jun 2020 13:55:54 +0000
Inline-Images: image001.jpg; image002.jpg; image989246.jpg; image958475.jpg
Dear
Thank you for your email of 5 June 2020.
Given the unfortunate history of this matter, already well documented, our view is that we cannot commit to a particular
form of cooperation until we are properly informed and assured as to what protections, including as to confidentiality and
use, are to pertain. Our ongoing concerns in this regard are only increased as a result of yesterday's leak to the world's
media regarding the existence of the MLA request. For that reason I ask you again to address the questions in my previous
communication.
Kind regards
Gary
Gary Bloxsome I Partner
RANKED IN
Chambers
LEGAL
UK
500
KINGDOM
2020
TOP TIER
Leading Firm
2020
Coronavirus - COVID-19 - A message to our clients and fellow professionals
All of the partners of the firm are still working and their contact details can be found on our website
at www.blackfords.com. In addition we have a team of key workers supporting us across all offices.
We continue to take instructions from existing and new clients.
EFTA00023798

=== Page 2 ===
As a consequence of the coronavirus pandemic and the need to ensure the safety of our staff, the
firm will be operated by a limited number of key personnel.
Family Court hearings and proceedings - - these are operating through video and telephone hearings.
Our family team is operating as normal.
Criminal and Regulatory hearings - most court and tribunal hearings are being adjourned but you
must please stay in contact with us to check hearing dates and deadlines until we have confirmation
that they have been moved or extended. For individuals held in custody, cases are being dealt with
where social distancing measures or electronic hearings can be implemented.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in ourPrivacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 5 Jun 2020, at 17:39,
)
wrote:
External email: is it safe to open attachments and links?
Gary,
Thank you for your email. We are prepared to respond to your questions in full, but before proceeding further, we want to
confirm that by "witness statement" you are referring to a live interview (to be conducted in person or via video
conference), at which your client will answer our questions and, in advance of which, will produce any documents,
including communications, relevant to the subjects to be covered at the interview.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Wednesday, June 3, 2020 3:17 PM
To:
Cc: Daniel Cundy
i
Jennifer Richardson
Subject: Sensitive correspondence.
Dear Ms Comey
The UK Central Authority (UKCA) has informed us that the United States has formally sought assistance in
interviewing our client.
The UKCA told us that we would have the opportunity to contact Mr
from the US Embassy to
explore whether, notwithstanding our concerns at the unfair treatment of the Duke by the United States
Attorney for the Southern District of New York and the failure by the DOJ to abide by its promise to provide an
appropriate level of confidentiality to him and us, it would be possible for the Duke to reach an agreement with
the DOJ and to provide a voluntary witness statement.
EFTA00023799

=== Page 3 ===
Unfortunately, it appears Mr
has no authority in the matter and has directed us to contact the U.S. case
team directly via your email address. With a view to progressing the request for assistance:
[1] Please confirm that any communications between us, with a view to providing the DOJ with a voluntary
witness statement from the Duke will be treated confidentially and in particular will not be the subject of DOJ
press statements or commentary.
[2] Please provide confirmation (given the reports of connections between the DOJ and US lawyers acting on
no win/no fee arrangements) that any voluntary witness statement will not be used for any purpose other than
the DOJ's criminal investigations.
[3] We would be grateful if you would confirm the areas of testimony that you would wish the Duke's witness
statement to cover.
Kind regards
Gary Bloxsome
Gary Bloxsome Partner
Coronavirus - COVID-19 - A message to our clients and fellow professionals
All of the partners of the firm are still working and their contact details can be found on our website at
www.blackfords.com. In addition we have a team of key workers supporting us across all offices. We
continue to take instructions from existing and new clients.
As a consequence of the coronavirus pandemic and the need to ensure the safety of our staff, the firm
will be operated by a limited number of key personnel.
Family Court hearings and proceedings - these are operating through video and telephone hearings.
Our family team is operating as normal.
Criminal and Regulatory hearings - most court and tribunal hearings are being adjourned but you
must please stay in contact with us to check hearing dates and deadlines until we have confirmation
that they have been moved or extended. For individuals held in custody, cases are being dealt with
where social distancing measures or electronic hearings can be implemented.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in ourPrivacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
EFTA00023800

=== Page 4 ===
RANKED IN
Chambers
UK
2020
Leading Firm
LEGAL
500
UNITED KINGDOM
TOP TIER
2020


c1: EFTA00024793
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024793.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To: Sigrid McCawley
Cc:
)"
Subject: Rule 412 Motion
Date: Thu, 28 Oct 2021 23:41:49 +0000
Attachments: Def_412_Mot._for_BSF_Redacted.pdf; 2021.10.28_order_re_November_1_Conference.pdf
Sigrid,
Attached please find a redacted version of the defense's memorandum of law in support of her Federal Rule of Evidence
412 motion. This was filed under seal by the defense. Any response is due on November 1, 2021. Likewise, any and all
responses will also be filed under seal and will not be docketed. The Court also ordered that any in camera hearing is
tentatively scheduled for November 5, 2021. We are happy to discuss tomorrow.
I'm also attaching the Court's Order about the November 1 in-person pretrial conference.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel:
EFTA00024793


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=== Page 1 ===
90A-NY-3151227 Serial 1
FD-1057 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Electronic Communication
Title: (U) Opening EC
Date: 08/12/2019
CC:
From: NEW YORK
NY-C19
Contact:
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Synopsis: (U) To open assign full investigation.
Details:
On Saturday, 8/10/2019, JEFFREY EPSTEIN was discovered unresponsive in
his jail cell at the Metropolitan Correctional Facility (MCC),
-
EPSTEIN was discovered with a fabricated noose around
his neck in what was an apparent suicide.
Preliminary investigation revealed a series of protocol failures by
MCC personnel, as well as technical failures/deficiencies within the MCC
at the time EPSTEIN was discovered.
As a result, a death investigation was initiated.
UNCLASSIFIED
EFTA00023973


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=== Page 1 ===
From
To
Subject: Accepted: Epstein Press Meeting
Date: Mon, 01 Jul 2019 02:57:06 +0000
Importance: Normal
Attachments: unnamed
EFTA00024820


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=== Page 1 ===
Event: Accepted: 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 23:25:18 +0000
Date Modified: 2021-03-10 23:25:18 +0000
Priority: 5
DTSTAMP: 2021-03-10 20:31:54 +0000
Attendee:
(USANYS)
EFTA00025212


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
Cc:
(USANYS) [Contractor]"
Subject: US V. Epstein
Date: Mon, 02 Nov 2020 20:42:56 +0000
Hello,
The password to the hard drive is
EFTA00024794


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c3: VOL00008
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=== Page 1 ===
From:
)"
To:
(USANYS)"
,
)"
Subject: Limiting instructions letter
Date: Sat, 20 Nov 2021 17:03:45 +0000
Attachments: 20cr330_Temp._Sealed_Mem_Op_&_Order_11.19.21.pdf
Hey team,
Per the attached order on MV-3, we owe Judge Nathan our views on the proposed limiting instructions. Can we add this
to the list for our call? I've written two responsive letters because I'm not sure exactly what she's going for with the
second instruction.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00024904


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Hi Please let me know as soon you have decided & booked
Date: Fri, 11 Oct 2019 19:32:23 +0000
For next week, could you please book me on the following flights, the first of which is New York to Florida, and then the
second one is Florida to Nashville, where I was already scheduled to take a work trip for a conference:
-
Tuesday, October 15: 6:00 a.m. (arriving 8:53 a.m.), LGA to FLL, JetBlue
-
Tuesday, October 15: 3:50 p.m. (arriving 5:10 p.m.), FLL to BNA, Southwest
Please let me know if any other information would be helpful, and thanks very much.
From:
Sent: Friday, October 11, 2019 12:14
To:
Cc:
Subject: Hi Please let me know as soon you have decided & booked
Traveler,
Each time you book a trip, you should check these links to see the maximum lodging allowed for your destination city & if
the office will be able to reimburse you for room taxes.
Click here Per diem Rates link - the maximum lodging reimbursable for your destination is Per diem Rates link
Misc. fees maybe considered part of the per night rate & may need to be factored into the total per night cost
Click here - is the city lodging tax exempt?
State/City tax exempt link https://usanet.usa.doj.gov/staffs/RMP/_layouts/15/WopiFrame2.aspx?
sourcedoc=/staffs/RMP/RMP%20Document%20Library/TravelStateTaxExemption.pdf&action=default
https://www.gsa.gov/travel/plan-book/state-tax-exemption-information-for-government-charge-cards
If applicable, print & submit form to hotel front desk Lodging taxes will no longer be reimbursed for cities that allow an
exemption.
PIV Card Driven Link - E2 Solutions, select USA identity provider OR Password Driven link - Click here to log back into the System.
You or your legal asst. should create an E2 travel auth. & book air, rail & or hotel in E2 E2 Solutions, today
Be sure to complete the process by clicking send to approver at the end,. This is the only way your request can reach
for approval.
Please email me a copy of your CWT air / rail e-ticket email & or hotel reservation confirmation
Rental Cars
Travelers must reserve rental cars via E2-E2 Solutions to ensure the rental car company is under the U.S. Government Car Rental Agreement.
Only Compact or Economy vehicles are authorized. Contact travel coordinator for acceptable justifications/ authorization for bother vehicle classes
Refueling charges charged by the rental car company cannot be reimbursed Be sure to gas up BEFORE you return the car
EFTA00025336

=== Page 2 ===
For travel to TDY sites that are less than 400 miles in distance, the GOV must be used when available. If the GOV is not available, the traveler
should then consider the least
costly economy rental vehicle
The traveler must decline insurance coverage within CONUS but accept the coverage when traveling in OCONUS and foreign locations areas.
Receipts/ Expense claims must be submitted the day after the trip is completed
From:
Sent: Friday, October 11, 2019 10:56 AM
To:
Cc:
Subject: RE: RE: travel approval request
approved
From:
Sent: Friday, October 11, 2019 10:47 AM
To:
Cc:
Subject: RE: travel approval request
We just found out yesterday that we're being sent to Florida for an FBI-arranged meeting with victims in the Epstein case,
so again in connection with that investigation (2018R01618), I'd like to please request permission to travel on Monday to
Florida and back. Unfortunately because of scheduling I expect l'Il need to fly down and back both on Monday (and back
in time to make an afternoon flight to Tennessee for a separate work obligation), but it's possible
may need to go if
we can't get the scheduling. In any event, we're requesting approval for travel for one person for either zero nights or one
night, and no need for a conference room for this trip.
thanks very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00025337


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein investigation
Date: Mon, 26 Oct 2020 19:41:16 +0000
H
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:
Cc:
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:
Cc:
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:
Cc:
Subject: RE: Epstein investigation
EFTA00024739

=== Page 2 ===
Following up on our conversation from yesterday, wanted to send a quick email as promised so you have my full contact
info - I'm reachable at this email address or by phone at
(office) or
(cell). Please don't
hesitate to reach out anytime day or night if we can provide any useful info, or if you have any questions at all, and we
appreciate you talking with us about the records information. Let us know if it makes sense to set up another call for
Friday or early next week to check in on the questions we had, and thanks very much for your help.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00024740


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=== Page 1 ===
From:
To:
)"
Subject: RE: another Maxwell issue
Date: Tue, 27 Apr 2021 16:42:41 +0000
Attachments: SDNY_PROD011_-_Overlay.zip
Hello
Attached is the overlay file that I got from the vendor. The overlay file contains the production number, file name and the
MD5 Hash. Please let me know if there are any questions.
Thank you.
From:
)
Sent: Monday, April 26, 2021 10:46 AM
To:
Subject: RE: another Maxwell issue
Thank you! The issue with production 11 is that defense counsel has expressed difficulty reviewing the metadata on the
images contained in the production. In particular, the FBI created the attached spreadsheet, which listed the metadata
the FBI was able to extract from the images, but defense counsel has indicated they have no way of knowing which bates
numbered image in the production corresponds with which row in the spreadsheet. I'm hoping there's something in the
production we can point them to that will help them match up each bates number with each row in the spreadsheet.
From:
Sent: Monday, April 26, 2021 10:33 AM
To:
Subject: RE: another Maxwell issue
3 PM would be fine. Please send me the conference call information.
Thank you.
From:
Sent: Monday, April 26, 2021 9:59 AM
To:
Subject: Re: another Maxwell issue
I'll be stuck in a meeting at 2pm. Would 3pm or later work, please?
On Apr 26, 2021, at 9:35 AM,
wrote:
How about 2 PM today? I can have the vendor on the call as well to discuss production 11. Do you have any
information regarding the issue with production 11?
EFTA00025179

=== Page 2 ===
Please send conference call information.
Thank you.
From:
Sent: Friday, April 23, 2021 6:31 PM
To:
Subject: RE: another Maxwell issue
How is Monday afternoon?
From:
Sent: Friday, April 23, 2021 12:14 PM
To:
Subject: RE: another Maxwell issue
Not a problem. Do you know what time you would like to meet and let me know what the issues are regarding the
production?
Thank you.
From:
Sent: Friday, April 23, 2021 12:10 PM
To:
Subject: another Maxwell issue
Hi
Would you have time for a call to address another question that has come up regarding the SDNY_PROD011 Maxwell
production, please?
Thanks,
EFTA00025180


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=== Page 1 ===
POLICE NATIONALE
CHARLES DE GAULLE 2
2 7 MAI 1982
POLICE
CHARLES DE GAULLE
2 6 OCT. 1983
FRANCE
A
A516
POLICE NATIONALE
CHARLES DE GAULLE 10
3 0 AVR. 1983
A 088 FRANCE
POLICE QUATIONALE
CHARLES DE GAULLE @
27 OCT. 1983
A 252 FRANCE
17


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
(USANYS)
[Contractor]"
(USANYS)"
Cc:
)"
)"
Subject: RE: Request for comment from Insider
Date: Thu, 08 Aug 2019 18:07:07 +0000
Thanks, l'Il handle it.
From:
Sent: Thursday, August 8, 2019 1:58 PM
To:
(USANYS) [Contractor]
is
(USANYS)
i
(USANYS)
Cc:
is
Subject: FW: Request for comment from Insider
FYI
From: Keenan Trotter
Sent: Thursday, August 08, 2019 13:54
To:
is
)
V.
Subject: Request for comment from Insider
Hello,
I'm a reporter at Insider, and I'm writing to you because I'm working on a story that discusses some
aspects of the federal criminal case against Jeffrey Epstein.
I specifically wanted to ask if any member of the prosecution or a spokesperson for them would be
willing to discuss the government's investigation of Epstein's potential ties to foreign governments, as
evidenced by its inquiries into his expired Austrian passport and his potential citizenship in other
countries. (This is in the context of a larger story about his travels to the Middle East.)
Would any of you be willing to talk to me about this aspect of the case?
My working deadline is Friday at noon, Eastern Time, but there is some flexibility if you need more
time. I'm happy to hop on the phone, too, if that's more convenient.
Thanks,
Keenan
EFTA00024358


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: You May disregard Re: Voucher for Trip 10643456-2 is late
Date: Tue, 08 Oct 2019 15:10:38 +0000
Got it, thanks!
Original Message
From:
(USANYS)
Sent: Tuesday, October 08, 2019 08:14
To:
Cc:
(USANYS)
Subject: You May disregard Re: Voucher for Trip 10643456-2 is late
Sent from my iPhone
> On Oct 7, 2019, at 12:03 AM, "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
wrote:
V
> Dear
V
> Your travel voucher for the trip below is now late based on your customer settings. Please submit your voucher
for this trip and mark it as Final if you have no additional expenses to claim.
>
> Trip ID: 10643456-2
> Traveler name:
> Destination: Santa Monica
> Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews Trip
> Dates: 2019-09-17 - 2019-09-20 Current status: Authorization Approved
>
> E2 Single Sign On Login (within DOJ Network Only):
>
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
V
> E2 Manual Login (User ID and Password):
>
https://e2.gov.cwtsatotravel.com
V
V
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
V
> Please note: Replies to this mailbox are not monitored.
V
> Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change
your email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
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V
> Reference ID# V0013
> This e-mail and any attachments may contain confidential and/or proprietary information. If you received this
e-mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00025344


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Ghislaine Maxwell
Date: Mon, 13 Jul 2020 22:34:43 +0000
Roger that, thank you.
Sent from my iPhone
On Jul 13, 2020, at 6:18 PM,
wrote:
Technically nobody will be in the courtroom - we'll all be remote, and then there's the in-person overflow room that will
apparently broadcast the video live, in the jury room of the courthouse. But the victims will be call-in, rather than in-
person.
From:
Sent: Monday, July 13, 2020 14:13
To:
Cc:
Subject: Re: Ghislaine Maxwell
Great letter! Will the victims be in the courtroom or be able to connect remotely?
Sent from my iPhone
On Jul 13, 2020, at 12:08 PM,
wrote:
No - victims can "be heard" at a bail hearing, either directly or through their attorney (or through us) but
yeah they don't testify.
Sent from my iPhone
On Jul 13, 2020, at 12:07,
wrote:
Also, for our edification, do victims or witnesses ever "take the stand" at an arraignment?
From:
Sent: Monday, July 13, 2020 11:58 AM
To:
Cc:
Subject: FW: Ghislaine Maxwell
EFTA00024504

=== Page 2 ===
FYI
(Also these questions are hilarious - yes of course, we'll tell journalists what we're going to argue a day in advance
and also identify the names of the victims - no problem!)
From: Palin, Megan <
Sent: Monday, July 13, 2020 12:01
To:
Cc:
Subject: Ghislaine Maxwell
Hi there,
I'm a senior journalist for News Corporation (The Sun, NY Post, Wall St Journal) covering the USA V
Ghislaine Maxwell case.
I'll be in court for the bail hearing tomorrow but wanted to put a few questions to your team in advance as I
know Tuesday will be extremely busy for everyone involved.
- What will the prosecution be arguing in court tomorrow?
- Will any alleged victims or witnesses be taking the stand on Tuesday? If so, how many (and who are
they)? What can the court expect to hear from them?
- Will any prosecutors, victims or witnesses be making a statement to the media outside the court before or
after the hearing? If so, could you please let me know a time and place if one is scheduled along with any
other relevant details?
- Anything to add?
Would you please also include me in any future emails/alerts etc to the media regarding this case?
Thank you.
Kind regards,
Megan Palin
"Please consider the environment before printing this e-mail"
This e-mail and any attachments are confidential, may be
legally privileged and are the property of News Corp UK & Ireland
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EFTA00024505

=== Page 3 ===
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News Corp UK & Ireland Limited and its titles are committed to abiding by
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EFTA00024506


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE:
- Epstein
Date: Mon, 08 Jul 2019 02:11:06 +0000
Importance: Normal
I'm free, but if possible can we do it a bit earlier, so we have time to brief the Florida approach agents? I think they fly out
Tuesday afternoon (but I could be wrong about that).
From:
Sent: Sunday, July 7, 2019 10:10 PM
To:
in
Subject: FW:
- Epstein
10:30 okay for you guys on Tuesday?
From:
Sent: Sunday, July 07, 2019 18:51
To:
Cc:
is
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
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza
4th Floor
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 7, 2019, at 4:04 PM,
)
wrote:
EFTA00026630

=== Page 2 ===
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 Ms.
if that's helpful. Or if you'd like to talk sooner, we could schedule a time later today, or check in
tomorrow about a possible afternoon discussion. Please let us know what you prefer, and we look forward to being in
touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Saturday, July 06, 2019 22:55
To:
)
Subject:
- Epstein
Begin forwarded message:
From:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
Cc:
Subject:
- Epstein
Mr.
My former partner,
, represented
(now known as
), prior to his passing in
2018. Agent
served Ms.
with a grand jury subpoena earlier today, and as
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 4th Floor
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
EFTA00026631


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=== Page 1 ===
Subject: FW: Query re: Epstein
Date: Thu, 13 Feb 2020 15:17:25 +0000
Just FYI.
Original Message
)
Sent: Thursday, February 13, 2020 10:16 AM
To: Kadhim Shubber <kadhim.shubber@ft.com>;
Subject: RE: Query re: Epstein
Thank you, Kadhim. Sorry, we cannot provide guidance. We'll decline to comment.
Original Message
From: Kadhim Shubber <kadhim.shubber@ft.com>
Sent: Thursday, February 13, 2020 10:13 AM
To:
Subject: Query re: Epstein
Hi
Hope you're both well!
I'm working with colleagues in London about a story that DOJ had passed information to the UK FCA about Jes
Staley's relationship with Epstein.
You might have seen this morning that Barclays disclosed the UK's FCA and PRA are investigating Staley's
statements about his links to Epstein.
I wanted to check if there was any steer or background you could give me on the information DOJ passed to the
UK authorities? And also if you had any comment?
Kadhim
Kadhim Shubber I Financial Times I +1 202 909 6430 (cell) I @kadhim
*This email was
sent by a company owned by Financial Times Group Limited ("FT Group <http://aboutus.ft.com/corporate-
information/#axzz3rajCSIAt>"),
EFTA00025082

=== Page 2 ===
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Registered in England and Wales with company number 879531. This e-mail may contain confidential
information. If you are not the intended recipient, please notify the sender immediately, delete all copies and do
not distribute it further. It could* *also contain personal views which are not necessarily those of the FT Group.
We may monitor outgoing or incoming emails as permitted by law.*
EFTA00025083


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=== Page 1 ===
FedEx.
Invoice Number: 5-722-84226
Invoice Date:
Feb 19, 2001
Account Number:
1144-2081-6
Page:
1 of 9
FedEx Tax ID: 71-0427007
JEFFREY E EPSTEIN
Billing Account Shipping Address:
Invoice Questions?
JEFFREY E EPSTEIN
MRS SHERMAN
FedEx Account Services
Phone:
(800) 622-1147 M-F 7-6 (CST)
US
Fax:
(800) 548-3020
Internet: www.fedex.com
Invoice Summary Feb 19, 2001
FedEx Express Services
Transportation Charges
314.10
Base Discount
-36.82
Special Handling Charges
21.07
Total Charges
USD.$
298.35
TOTAL THIS INVOICE
USD $
298.35
You saved $36.82 in discounts this period!
To ensure proper credit, please return this portion with your payment to FedEx.
Please do not staple or fold.
For change of address, check here and complete form on reverse side.
Invoice
Account
Amount
Number
Number
Due
Remittance Advice
Your payment is due by Mar 06, 2001
5-722-84226
1144-2081-6
USD $298.35
114420815722842266000002983566
SP 01 000001 97702 A 1 ASNGLP
JEFFREY E EPSTEIN
FedEx
P.O. Box 1140
NEW YORK NY 10022-6809
Memphis TN 38101-1140
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FedEx.
Invoice Number: 5-722-84226
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FedEx.
Invoice Number: 5-722-84226
Invoice Date:
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FedEx Express Payment Type Summary
Original
Shipper
Number of Airbills
15
Transportation Charges
286.60
Base Discount
-34.07
Special Handling Charges
20.08
Number of Airbills
15
Total Charges
USD $
272.61
Third Party
Number of Airbills
1
Transportation Charges
27.50
Base Discount
-2.75
Special Handling Charges
0.99
Number of Airbills
1
Total Charges
USD $
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16
TOTAL CHARGES
USD $
298.35
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FedEx.
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FedEx.
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FedEx.
Invoice Number: 5-722-84226
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Distance Based Pricing. Region 8
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Service Type FedEx Standard Overnight
JEFFREY EPSTEIN
Package Type FedEx Pak
JEFFREY E EPSTEIN
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FedEx.
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=== Page 1 ===
From:
To:
Subject: RE: Arrest Today
Date: Thu, 02 Jul 2020 14:32:21 +0000
One caveat: there will be a bail argument in New Hampshire today, and if anyone takes an appeal, that would be to Judge
Nathan here. Presumably remotely.
From:
Sent: Thursday, July 2, 2020 8:52 AM
To:
Subject: Re: Arrest Today
thank you for the heads up. Hope all is well.
Sent from my BlackBerry - the most secure mobile device
From:
Sent: July 2, 2020 8:50 AM
To:
Subject: Arrest Today
Ed,
Just a heads up that we are unsealing an indictment this morning against Ghislane Maxwell, an associate of Jeffrey
Epstein, charging her with facilitating his abuse of minors. She was arrested in New Hampshire this morning, so the
presentment will not be in SDNY. She will not appear in SDNY today. Let me know if you have any issues.
Chief, Criminal Division
United States Attorney's Office, SDNY
EFTA00026527


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=== Page 1 ===
From: Gary Bloxsome
To:
)"
Cc: Daniel Cundy
Jennifer Richardson
=
,
)"
Subject: Re: Sensitive correspondence
Date: Thu, 16 Jul 2020 16:45:00 +0000
Inline-Images: image841628.jpg; image877270.jpg
Dear
Thank you for your email and the constructive approach contained therein.
I will revert back to you.
Regards.
Gary
Gary Bloxsome
I
Partner
RANKED IN
Chambers
LEGAL
UK
500
UNITED
KINGDOM
2020
TOP TIER
Leading Firm
2020
Coronavirus - COVID-19 - A message to our clients and fellow professionals
All of the partners of the firm are still working and their contact details can be found on our website
at www.blackfords.com. In addition we have a team of key workers supporting us across all offices.
We continue to take instructions from existing and new clients.
EFTA00023791

=== Page 2 ===
As a consequence of the coronavirus pandemic and the need to ensure the safety of our staff, the
firm will be operated by a limited number of key personnel.
Family Court hearings and proceedings - these are operating through video and telephone hearings.
Our family team is operating as normal.
Criminal and Regulatory hearings - most court and tribunal hearings are being adjourned but you
must please stay in contact with us to check hearing dates and deadlines until we have confirmation
that they have been moved or extended. For individuals held in custody, cases are being dealt with
where social distancing measures or electronic hearings can be implemented.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in ourPrivacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 14 Jul 2020, at 15:59,
)
wrote:
External email: is it safe to open attachments and links?
Gary,
In response to your July 13 email, we are prepared to enter into a limited period of confidential negotiations regarding a
voluntary interview of your client, subject to the following conditions:
1. The confidential negotiation period shall last no more than two weeks, starting today, and ending at the end of the day
on July 28, 2020 (the "Negotiation Period");
2. Both sides agree that the fact of the Negotiation Period, as well as any communications made during the Negotiation
Period, shall be treated as confidential, and shall not be the subject of any public comments;
3. If, as the result of negotiations conducted during the Negotiation Period, your client completes a voluntary interview
with U.S. authorities, either side may publicly confirm that your client met with United States law enforcement
authorities and answered questions about matters under investigation. Neither party, or their representatives, shall
comment further on the circumstances or substance of the interview.
4. Alternatively, if, at the end of the Negotiation Period, no agreement is reached, the parties will jointly inform the
appropriate authorities in the UK and US that the parties are not able to reach agreement on a voluntary interview and
accordingly a voluntary interview will not occur.
We believe these conditions directly address your stated concerns while allowing us to satisfy ourselves that all sides are
endeavoring in good faith to either expeditiously reach agreement on a voluntary interview or reach agreement that no
such interview will occur.
Please inform us as soon as possible if you are amenable to this proposal. If so, we are prepared to schedule a call at your
earliest convenience to discuss arrangements for the interview.
Regards,
From: Gary Bloxsome
Sent: Monday, July 13, 2020 11:49
To:
)
EFTA00023792

=== Page 3 ===
Cc: Daniel Cundy ; Jennifer Richardson ;
);
Subject: Re: Sensitive correspondence
Dear
Geoffrey Berman and Audrey Strauss have persistently commented about the prospects and purpose of
interviewing the Duke of York, prompting widespread media coverage. We regard that commentary as
improper. Your offer to refrain from publicly commenting on the substance of any witness interview and
general assurances about your standard practice are clearly insufficient to prevent the DoJ and the SDNY from
encouraging a media circus around the process of arranging for and the Duke attending any interview.
All we are asking for at this stage is an undertaking of confidentiality in relation to the discussion of dates,
concerns and arrangements in relation to any interview. This is no more than would be good practice in the UK
and we invite you provide an assurance in this regard.
Regards
Gary
Gary Bloxsome Partner
Coronavirus - COVID-19 - A message to our clients and fellow professionals
All of the partners of the firm are still working and their contact details can be found on our website at
www.blackfords.com. In addition we have a team of key workers supporting us across all offices. We
continue to take instructions from existing and new clients.
As a consequence of the coronavirus pandemic and the need to ensure the safety of our staff, the firm
will be operated by a limited number of key personnel.
Family Court hearings and proceedings - these are operating through video and telephone hearings.
Our family team is operating as normal.
Criminal and Regulatory hearings - most court and tribunal hearings are being adjourned but you
must please stay in contact with us to check hearing dates and deadlines until we have confirmation
that they have been moved or extended. For individuals held in custody, cases are being dealt with
where social distancing measures or electronic hearings can be implemented.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 10 Jul 2020, at 00:51,
)
wrote:
External email: is it safe to open attachments and links?
Gary,
EFTA00023793

=== Page 4 ===
While we do not think it would be productive to rehash the history of our communications, we have always been and
remain open to a voluntary interview in lieu of one compelled under U.K. law. However, your client has neither offered
nor agreed to sit for a voluntary interview. That has left us no choice but to pursue a compelled interview.
You have asked about the confidentiality of any witness interview. We have previously told you, by email dated
February 4, 2020, and reiterate here, that it is our standard practice to refrain from publicly commenting on the
substance of any witness interview, and we intend to abide by that practice in this case. It is also our standard practice to
disclose information provided during a witness interview only in connection with an ongoing criminal investigation or
proceeding, any related civil or forfeiture proceeding initiated by this Office, or as otherwise authorized under U.S. law.
We do not voluntarily share information with the press or civil litigants or members of the public, and it is entirely
unclear why you believe we might do so here.
Give us a commitment that your client will sit for a voluntary interview with us, give us a date or dates that work for
you and your client, and we will be happy to schedule a call to discuss any additional arrangements or particular
concerns you may have. But until we have a commitment from your client to sit for a voluntary interview - and to do so
on a timeline that reflects the urgency of our ongoing investigation - we will continue to pursue a compelled interview
through all available legal channels.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Monday, July 06, 2020 09:15
To:
Cc: Daniel Cundy
Jennifer Richardson
)
Subject: Re: Sensitive correspondence
Dear
Thank you for your email of 2 July 2020, sent late in the evening UK time.
It appears that there may be cultural differences between UK and US legal practice that are causing problems
in our communications. Normally in UK practice, any written communication is acknowledged promptly and
any differences between the parties are identified in that correspondence. Following our emails of 3 and 8
June 2020, I had expected the DOJ to at least acknowledge our email of 8 June 2020. I did not expect to have
to chase for an acknowledgment, let alone a response, on 1 July 2020.
I remain very keen to discuss a path for the Duke's voluntary cooperation, without necessity for compelled
process under the MLAT. I believe that through a cooperative agreement which could be reached, the Duke
would be able to provide answers to any relevant questions you may have.
I am disappointed that your email response of 2 July 2020 seems to suggest that the DOJ has no interest in
discussing the practical arrangements that obviously need to made to allow us to advise the Duke of York that
he should agree a process under which he provides witness evidence to you. For that discussion to take place I
would invite you to indicate what protections might be available to ensure that this process is fair and does
not turn into a media circus.
Insofar as you complain about our public statement on 8 June 2020, this solitary public comment was made in
response to what I believe have been highly unusual public statements and persistent and deliberate leaks to
the press by the DOJ, including the latest leak of the fact that there had been a mutual legal assistance request.
However, I acknowledge that both sides appear to have quite different views as to how we have reached this
position and who is in the right. May I therefore suggest that we start afresh, and both make a good faith
attempt to reach an agreement which will allow the Duke of York to provide the potential evidence you seek.
I do not believe that this agreement can be achieved by the DOJ unilaterally insisting that the Duke must
commit to a voluntary cooperation without any guarantee that he would have even the limited protection that
he would be given in the context of a request for mutual legal assistance. In the mutual legal assistance
process in the UK, for example, he could only be required to answer questions and provide evidence that are
demonstrably relevant to a US criminal trial. Whatever evidence he provides may only be used for the US
EFTA00023794

=== Page 5 ===
criminal proceedings and cannot be given to the press or deployed by civil claimants' lawyers. The overall
confidentiality of the evidence taking process is supervised by a judge.
In those circumstances I do urge you to agree that we should at least attempt to iron out the cultural
differences and practical issues between us by speaking on a call in the very near future.
I look forward to hearing from you regarding a time you might be available to speak by telephone.
Kind regards
Gary
Gary Bloxsome|Partner
Coronavirus — COVID-19 - A message to our clients and fellow professionals
All of the partners of the firm are still working and their contact details can be found on our website at
www.blackfords.com. In addition we have a team of key workers supporting us across all offices. We
continue to take instructions from existing and new clients.
As a consequence of the coronavirus pandemic and the need to ensure the safety of our staff, the firm
will be operated by a limited number of key personnel.
Family Court hearings and proceedings - these are operating through video and telephone hearings.
Our family team is operating as normal.
Criminal and Regulatory hearings - most court and tribunal hearings are being adjourned but you
must please stay in contact with us to check hearing dates and deadlines until we have confirmation
that they have been moved or extended. For individuals held in custody, cases are being dealt with
where social distancing measures or electronic hearings can be implemented.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in ourPrivacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 2 Jul 2020, at 22:07,
)
wrote:
External email: is it safe to open attachments and links?
Gary,
There is nothing under active consideration because you have not proposed anything for consideration. To the
contrary, in your email of June 8, you stated: "we cannot commit to a particular form of cooperation until we are
properly informed and assured as to what protections, including as to confidentiality and use, are to pertain." We note
that notwithstanding your professed interest in confidentiality, that email was followed almost immediately by a
EFTA00023795

=== Page 6 ===
public release issued in your name that contained any number of false and misleading characterizations of your
dealings with our Office and your client's purported interest in cooperation.
If and when you are prepared to arrange a date for your client to sit for an interview with our Office, we assume you
will let us know, and we will be happy to discuss the particulars of such an interview. Until such an interview is
arranged, we will continue to report to the authorities in the UK, through the appropriate channels, that there has been
no offer of a voluntary interview, nor any likelihood of one being scheduled, and that we will therefore have no
alternative but to pursue a compelled interview via formal request.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Wednesday, July 01, 2020 12:28
To:
)
i
)
Cc: Daniel Cundy
>; Jennifer Richardson
Subject: Sensitive correspondence
Dear
I refer to our email dated 8th June 2020. We have not received any response from you. We assume it is still under
active consideration by your department. If it would assist we would welcome a telephone conference to discuss the
matter further.
Kind regards
Gary
Gary Bloxsome Partner
Coronavirus - COVID-19 - A message to our clients and fellow professionals
All of the partners of the firm are still working and their contact details can be found on our website at
www.blackfords.com. In addition we have a team of key workers supporting us across all offices. We
continue to take instructions from existing and new clients.
EFTA00023796

=== Page 7 ===
As a consequence of the coronavirus pandemic and the need to ensure the safety of our staff, the firm
will be operated by a limited number of key personnel.
Family Court hearings and proceedings - these are operating through video and telephone hearings.
Our family team is operating as normal.
Criminal and Regulatory hearings - most court and tribunal hearings are being adjourned but you
must please stay in contact with us to check hearing dates and deadlines until we have confirmation
that they have been moved or extended. For individuals held in custody, cases are being dealt with
where social distancing measures or electronic hearings can be implemented.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in ourPrivacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
EFTA00023797


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10643456-1 has received final approval
Date: Thu, 26 Sep 2019 12:09:59 +0000
Importance: Normal
Dear
Travel authorization 10643456-1 has received final approval.
Trip ID: 10643456-1
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews
Destination: Santa Monica, CA, United States
Dates: 2019-09-17 - 2019-09-20
Current status: Authorization Approved
E2 Single Sign On Login (within DOJ Network Only):
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E2 Manual Login (User ID and Password):
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EFTA00025338


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=== Page 1 ===
April 9, 2021 Call with Dr. Lisa Rocchio
Opinions and conclusions are based upon 30 years plus of education, training, and
experience in field of psychology
There are decades of published and unpublished scientific work in field of forensic and
clinical psychology, psychological assessment, trauma psychology, interpersonal violence,
and dynamics and impact of childhood sexual abuse
Impossible to identify specific works or treatises representing all of accumulated education,
knowledge, and experience
Has read published works on complex trauma, psychological assessment and issues
relating to forensic assessment, psychological trauma, interpersonal violence, childhood
sexual abuse
Has also read published personal accounts of individuals who have been abused; literature
about cultural competency and why that's important in conducting forensic evaluation
To point to one specific book, journal, or article would not be fair or accurate answer
Working in field for 30 plus years; information gleaned in process of assessing and
providing treatment to survivors of childhood sexual abuse as well as work in forensic
arena, numerous continuing education programs attended by experts in the field
Can give examples of certain articles or if making particular statements on particular topics,
can provide sources, as well as identify peer reviewed research supporting position;
example: National Crime Victim Survey - used to look at prevalence data or
underreporting of sex crimes
Opinions not exclusively based on peer reviewed literature but 30 plus years of education,
training, and experience in clinical and forensic realms
Commonly known that perpetrators tend to target individuals who they feel they are going
to be most successful in grooming and gaining compliance
In most instances of child sexual abuse, the sexual encounters come later in the
process of a relationship and that relationship is something that has been established
over time
Perpetrators tend to identify children or individuals with particular needs for
warmth or affection, identify the needs of that individual, and target kids for whom
they believe have a way to manipulate or fulfill those needs
Perpetrators often target children who lack supervision because need to get access
Perpetrators often put themselves in position where have a great deal of access;
begin slowly and gradually testing boundaries to see how kids respond; kids who
put up barriers or withdraw or who perpetrator doesn't think will be successful with,
will move on and move to child with whom will be able to engage in abuse
Grooming is process by which perpetrator wins over the intended target victim. Begin to
first identify individual and work to establish relationship with that person and increase
access
3502-004
Page 1 of 7
EFTA00026929

=== Page 2 ===
Sometimes means developing relationships with person's parents or other people
in that person's life so can continue to build trust
Over time perpetrator tends to move standard for what is and is not acceptable or
deviant such that child begins to slowly and incrementally rely more and more on
perpetrator's definitions of right and wrong
Example: less typical that perpetrator on first interaction with individual
immediately moves toward aggressive sexual assault; more likely that first begin a
relationship; might take kid out for ice cream, lavish with presents, spend time
together; maybe in some of those interactions start talking about sexual activity so
becomes normal; breaking down barriers by talking about sex; then maybe show
pictures or artwork about sexual activity, maybe do hugging and touch to normalize
contact; over time incrementally advance towards ultimate end goal of sexual abuse
High degree of variation based not only on individual characteristics of perpetrators and
victims, but also based on specific circumstances; sometimes it is a crime of opportunity
and may be about what is happening in a particular moment; high degree of variability
Sometimes grooming process can take long time; sometimes it doesn't and it's
quick process
Violent sexual assault and violent rape is less common among abusers of children
Violence and force are not the same; without gaining permission, adult may engage
in sexual touch that they haven't physically threatened; that is nonconsensual but
not obtained by threats of violence; compliance not given due to threats of violence;
Often kids in that situation are shocked, confused, unsure of what has happened;
may have conflicting feelings because perpetrator is someone they trust and rely on
but engaging in sexual abuse
Adult who wants to manipulate a child into doing something is at a major advantage
in terms of their ability to do so
Sexual abuse can be accomplished by leading child to believe a particular behavior
is totally acceptable and normal
Abusers of child victims are more likely to engage in grooming behaviors and to cultivate
a relationship with victim to ensure compliance as well as silence
Vast majority of sexual assault across age span is committed by someone known to the
victim
Extremely common for abuse to occur multiple times because abuse occurs in context of
an established relationship
Sexual abuse may escalate over time; perpetrator may move from sexual touch to
oral contact to intercourse
Often times victims of sexual assault maintain attachment and use coping strategies,
such as disassociation, to put abusive parts out of their mind and focus on the
attachment and ways in which the relationship meets their needs
Attachment in context of child sexual abuse - adult creates situation in which a
child comes to care for them; adult communicates to child that they care for the
child in return; engage in behavior especially initially designed to increase trust and
cause child to be dependent on them for certain needs (e.g., financial, attention,
basic needs, meals); over time child comes to care deeply about person in spite of
fact that person is sexually abusing them; perpetrator often works quite hard to
3502-004
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EFTA00026930

=== Page 3 ===
maintain that connection and ensure subsequent compliance with demands and
silence
Child - anyone below the age of consent
Sexual abuse - nonconsensual sexual touch
Nonconsensual: when someone has said no, someone too incapacitated because of
drugs or alcohol, someone below the age of consent
Trauma defined as exposure either by directly experiencing or witnesses severe bodily
injury harm, death, or sexual violence; criterion for PTSD
Sexual violence is broader term that encompasses sex abuse, sexual harassment, childhood
sexual abuse, inappropriate unwanted non-consensual behavior; term that is used to define
trauma in DSM-V
Kind of behavior perpetrator engages in or offers may vary depending on the age;
perpetrator is often quite skilled at figuring out what intended target needs or wants
For example, adolescents often like to be treated as older than they are; sometimes
offered access to alcohol, drugs, sense of belonging, physically flattered
For young child, perpetrator might offer toys or games or secret fun time;
Underlying concepts are the same but ways in which it is carried out can differ
depending on the age of the individual
Abuser of adolescent female victim might identify the adolescent's vulnerabilities (figure
out if she is lonely or feels unattractive) or determine if she doesn't have access to certain
material things (e.g., items, meals, education, connection to jobs/internships, money,
vacations trips); may put self in position of being a close friend of adolescent
Adolescent female victim who is being abused may go back because she is connected or
attached to the person doing the abuse; continues to return in spite of the abuse because she
has come to trust, rely upon, and care for the individual
As true of many children, adolescents, and adults, she may not recognize that what
is happening to her is abusive; may come to believe in a special relationship with
individual and that individual truly cares about her
For adolescent, certain kinds of touch can be pleasurable even if abusive in nature;
At other times, may be afraid of consequences of saying no; may feel have little
options or nowhere else to go; may be in need of material goods being provided or
that may get in trouble if what happened is disclosed; may be fearful of getting
perpetrator in trouble; number of reasons can vary
Whether a female victim of sexual abuse returns multiple times to her abuser as opposed
to a single instance of abuse depends in part on the relationship
If someone is in a relationship with person who is abusing them, it is far more likely
that sexual abuse is something that will occur repeatedly and over the course of
time
Where individual is a child, the onus for how often child is brought back into sphere
of perpetrator lies with the adult, the perpetrator
When there is close connection/relationship or some kind of dependency or fear,
those factors are designed to keep person engaged in relationship so perpetrator can
continue to abuse them
Effects of child sexual abuse on adolescents
Often times child and adolescent victims blame themselves
3502-004
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=== Page 4 ===
Adolescents in particular filled with self-blame and shame because have false sense
of responsibility or feeling that they are somehow to blame particularly if there was
coercion and not force;
Host of psychological difficulties associated with childhood sexual abuse,
including but not limited to eating disorders, post-traumatic stress disorder,
physical difficulties, chronic headaches, problems with weight, substance use
Young adolescent girls typically engage in other forms of risky sexual behavior
following sexual abuse
All child and adolescent victims of sexual abuse are at increased risk of re-
victimization
Being sexually abused creates vulnerability identified by subsequent perpetrators;
people who have been sexually abused, particularly by someone with whom have
close personal relationship, are taught over time to ignore internal warning system;
may not perceive subsequent red flags or grooming behaviors
If emotional and sexual abuse has evoked difficulty with shame, low self-worth,
may increase vulnerability to subsequent abusers and perpetrators; engaged in other
kinds of high risk behaviors that place them in high risk settings, may make more
vulnerable
Impact of childhood sexual abuse on victims into adulthood
Opportunity cost because spending time with adult who becomes center focus of
their world so not engaging in developmentally appropriate or normal social
activities
May not have ability to develop appropriate skills on how to handle anger or
regulate emotion or have more normal or healthy relationships with same age peers
Many of coping strategies that survivors of sexual abuse develop include
compartmentalization, suppression, denial, or not recognizing that were abused;
sometimes it is not until adulthood that someone realizes that what happened to
them was abuse and begins lengthy process of making connections between abuse
suffered as a child and adult challenges
Extremely common for survivors of all kinds of sexual abuse to not label experiences as
sexual abuse
For that reason, in scientific field on experiences, talk about behaviors
If do survey and speak with 100 individuals and ask if they have been raped, they
say no; if continue to talk to those individuals and ask if they have been forced to
have sex against their will or had sex after saying no, or they were too drunk, they
say yes to those kind of behaviors; when ask college men if they have raped or
sexually assaulted a woman, they say no; if asked if they ever pushed a woman to
have sex after she said no, will say yes, but say that's not rape
Victims of childhood sexual abuse sometimes remain friendly with abusers into victims'
adulthood
Documented in literature and seen in own clinical practice
Depends on how old the victim is when become involved with perpetrator, how
much perpetrator has insinuated themselves into victim's life, to what degree victim
believes conduct is abusive
If believe expression of care, then abuse might continue into adulthood until
person encounters some new information or person to help recognize
3502-004
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EFTA00026932

=== Page 5 ===
Fear of ending relationship with perpetrators also a factor; may be significant
consequences for person separating from person who has harmed them; to initiate
separation may result in significant loss of part of victim's life (e.g., fear of public
shaming or blaming, financial loss)
May be forced to confront that relationship was abusive overall which is challenge
to ways in which coped
Rape myths: false beliefs that are commonly held by individuals that are presented in media
(news, television, movies) associated with what rape is. Examples:
Rape myth that rape occurs as a result of violent attack perpetrated by a stranger;
vast majority are perpetrated by someone known to the victim
Tend to put lot of blame on rape victim (that what a victim was wearing or drinking
or circumstance in which she found herself somehow caused rape to occur); only
person responsible for perpetrator's behavior is perpetrator and those assisting
perpetrator
Delayed disclosure
Vast majority of sexual assaults and rapes are not reported
Studies done using national samples inquire about a range of experiences
people have had and ask if certain things have happened and whether
reported to law enforcement agency or another individual
Studies looking at crimes reported to agency (e.g., numbers in National
Crimes Victim database are far lower than incidents of sexual assault)
Children often are led to believe that something bad will happen if they disclose;
depending on age of child, wouldn't occur to child to go to law enforcement agency;
typically disclosure made because brought to some other adult's attention who then
brings to attention of law enforcement
Unlikely that make disclosure because may perceive that they or perpetrator will
get into trouble if disclose; perpetrator may tell victim that bad things will happen
if they tell or that positive thing getting out of relationship (separate and distinct
from abusive relationship) will cease; if getting certain needs met, disinclined to
cut relationship off if have dependency or attachment
Limited disclosure or delayed disclose is very common
Extensive scientific literature supports idea that individuals who are harmed as kids
don't come to disclose or come to an awareness of how they were harmed until later
in life
adults don't become aware that their experiences were abusive or if abusive, degree
to which harmed or negatively impacted, until later in life
Disclosure is not an all or nothing phenomenon; often see incremental disclosure
where people tell bits and pieces of what is happening but not full story
Kids may share information with a peer but less likely to go to an adult
That is part of what the grooming process accomplishes; perpetrator
becomes a trusted and relied upon person in child's life because it has
likelihood of reducing disclosure
Incremental disclosure depends in part on how safe the victim feels with person disclosing
to, how voluntarily they are making the disclosure; certain psychological factors may
prevent victim from accessing memories of full extent of what happened to them all at once
3502-004
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EFTA00026933

=== Page 6 ===
May be experiencing great deal of shame or self-blame so may not want to reveal
pieces of information that feel is more shameful or afraid in getting in more trouble
May still feel in love with person who is hurting them; may desire to protect that
person or others; may try to deliberately or unconsciously avoid sharing
information all at once
If information shared by someone who is a child, ability to trust other adults may
already be impaired;
Impact of sexual abuse during adolescence on memory of abuse
Memory for any event, traumatic or otherwise, is not a video screen; comprised of
multiple components
Initially encoding of the memory (what is encoded in someone's circumstances)
In traumatic circumstances, only thing person pays attention to are what is
most salient/big picture, not details
Then look at how it is stored (in short term and long term memory)
When talk about disclosure later in life, talking about retrieving memory
Natural forgetting can happen over time; may forget even if encoded; during
traumatic event, if someone is disassociating (escaping in minds because
can't escape in bodies), those individuals may not remember specific
details; remember key individuals involved, but likely not able to provide
clear chronological report including all of the details; part of it is because
that is how memory works
Few of us can give accurate report of what happened long ago; memories
can blur together and can be grouped
Remember general act, things that are most relevant and salient
With traumatic memory in particular, adrenaline and cortisol in context of fear and
trauma cause people to narrow focus of attention so likely to tune into most salient
and relevant things; less likely to attend to details
What is extraneous detail for one person may be very salient detail for another
person
Expect memories of survivors of child sexual abuse who experience multiple instances of
abuse to be impacted by abuse occurring multiple times
If someone is abused by a variety of different people over the course of time,
majority of individuals will remember key facts associated with that traumatic
experience, who person was
May not remember specific details about what month it was or where occurred if
multiple assailants and multiple acts
Very common for victim's memories to run together if perpetrator abused victims
multiple times over years; what is most relevant is that person is doing this behavior
multiple times over time; may be able to remember some of places where happened,
but very common for memories of similar occurrences to jumble together
In process of grooming, how common for there to be someone who assists primary abuser
in grooming but not necessarily the abuse itself; how presence of someone who helps in
grooming process facilitating the sexual abuse
Documented cases in literature of individuals who assist the primary perpetrator in the
grooming process and facilitate the sexual abuse but do not necessarily participate in abuse
themselves
3502-004
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EFTA00026934

=== Page 7 ===
Abuse with multiple perpetrators occurs, not unusual
Multiple perpetrators don't have to engage in physical sexual abuse (e.g., fraternity
house, alcohol spiked, number of people get a drunk girl to a particular bedroom;
someone else assaults her)
Sometimes individuals use other people as a way to break down someone's
defenses to help them appear to be a more safe and trusted individual
Involved in a case where perpetrator frequently had one of his younger assistants
who he had also sexually abused over course of many years but who was now an
adult with him when he would connect with other young boys; presence of young
man who made it seem ok to be there
If multiple adults engaging in sexual conversation around child, adds to idea that
this is appropriate, this is what adults do; helps create false sense of security on part
of child that what is happening is ok, normal, acceptable
Based on years of experience working with individuals, know that young children in
particular often feel more comfortable in the presence of a woman; adolescent girls might
bring a friend with them if they are going out with a guy or group of guys; sense of security
that there is someone else like them
Factors that could help disarm intended victim
Person helping perpetrator shares a common interest with the perpetrator and
functions to make an introduction or serve as bridge; that person may hold certain
qualities that victim is known to respond positively to; person might possess certain
skills in terms of ability to make initial connection; person might serve to normalize
what might be otherwise viewed as inappropriate or deviant behavior
Vast majority of sex crimes committed by men and vast majority of victims are girls and
women. However, sexual abuse also occurs in same sex relationships, women are capable
of and have committed heinous sex abuse crimes and have been active perpetrators of child
sexual abuse even though statistically in lesser number than male perpetrators
LR has not met or interviewed victims in this case
LR is aware of multiple news reports about Epstein and Maxwell as his longtime
companion
LR is aware of allegations by some victims that Maxwell was present for or participated in
or knew about the abuse
LR has seen photographs of Epstein and Maxwell on the news with celebrity figures (e.g.,
Trump, Clinton, Prince Andrew)
LR is aware that there have been multiple documentaries and podcasts and interviews with
various people
LR read some articles that raised questions about the initial plea deal that Epstein
negotiated in Florida
LR saw one of documentaries about Epstein on Netflix (Filthy Rich)
Heard some episodes of podcast called Seeking Justice; not sure which episodes
Reviewed those before retained as expert witness
Relevant to LR and her profession; helpful to be aware of popular culture
Information provided today was based on LR's knowledge, experience, training
LR was asked to avoid viewing or reviewing media reports about the case to the extent
possible
3502-004
Page 7 of 7
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
)"
Cc:
(USANYS)"
i
)"
Subject: RE: 21-58 United States of America V. Maxwell "Motion Order FILED denying for bail"
Date: Tue, 27 Apr 2021 18:00:26 +0000
Agreed. Great work, great result.
From:
(USANYS)
Sent: Tuesday, April 27, 2021 2:00 PM
To:
is
(USANYS)
Cc:
(USANYS)
>;
Subject: RE: 21-58 United States of America V. Maxwell "Motion Order FILED denying for bail"
Excellent. Congrats team, and great job
!
From:
)
Sent: Tuesday, April 27, 2021 1:59 PM
To:
(USANYS)
>;
(USANYS)
Cc:
(USANYS)
i
Subject: FW: 21-58 United States of America V. Maxwell "Motion Order FILED denying for bail"
See below. Congratulations to
who did a really kickass job with this appeal.
From: cmecf@ca2.uscourts.gov <cmecf@ca2.uscourts.gov>
Sent: Tuesday, April 27, 2021 1:57 PM
To:
Subject: 21-58 United States of America V. Maxwell "Motion Order FILED denying for bail"
***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
Document(s): Document(s)
EFTA00025177

=== Page 2 ===
Docket Text:
MOTION ORDER, denying motion for bail [39] filed by Appellant Ghislaine Maxwell, by PNL, RJL, RJS,
FILED. [3087715][86] [21-58, 21-770]
Notice will be electronically mailed to:
Ms.
David Oscar Markus, -:
, Assistant U.S. Attorney:
,
Assistant U.S. Attorney:
Assistant U.S. Attorney:
Ms. Bobbi C. Sternheim,
Notice will be stored in the notice cart for:
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Motion Order FILED
Original Filename: 21-58.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=04/27/2021] [FileNumber=3087715-0]
[c4dae9d83e3602096564248f5bfcc0e89b9f8c55fe4ec1014f3c2db1a909f4f7c8b360f2544b2115306751b7aa82b9
4f70f4198d95fcdcb8ef868b204742b03e]]
EFTA00025178


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=== Page 1 ===
From:
To:
Subject: FW: Application for Amended SW
Date: Thu, 22 Oct 2020 17:45:49 +0000
Looking now and will send to you.
From:
)
Sent: Thursday, October 22, 2020 1:07 PM
To:
is
Cc:
is
Subject: Application for Amended SW
Chiefs,
Thanks very much for talking this morning. As discussed, attached is a draft application for an amended search warrant
correcting the FBI barcode numbers for 3 devices that were seized from Epstein's NY residence. In case it's useful, I'm also
attaching the exhibits that are referenced in the draft application.
Thanks,
EFTA00024737


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein update
Date: Sat, 10 Aug 2019 16:37:46 +0000
Will do,
Thanks!
>>>
>
8/10/2019 12:36 PM >>>
In addition to Marshal
can you please include Chief
Thank you
From:
Sent: Saturday, August 10, 2019 12:32 PM
To:
Cc:
(
Subject: Re: Epstein update
Hi all,
Who is his lead counsel? The Warden is preparing the formal letter for the Court, in which your office, the USMS, USPO, and
lead counsel are cc'ed. Do you have an email address for him/her?
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
New York, New York 10007
>>>
>
8/10/2019 11:30 AM >>>
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.
EFTA00024356

=== Page 2 ===
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,
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:
(
Cc:
is
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:
(USMS)
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 2
or
EFTA00024357


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=== Page 1 ===
POLICY
OF
30 MARS 1983
PROMISHED RHS
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28MAY W02
04 $ NOV. 542 FRANCH
CHARLES POLICE 6 NATIONALE SEP. FRANCE 1982
a
2
LEAVE EMPLOYMENT FOR SIX MONTHS
LEAVE TO TO SIX MONTHS
EMPLOYMENT PROMIBITED
IMMIGRATION * OFFICER
M. PATION OFFICER
240CT
*
8
*
232) *
25 SEP 1982
HEATHROW (2)
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HEATHROW (2)
0 9 NOV. 1982
CHARLES DE GAULLE 2
STUNCHEVIN FORM
13
12


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=== Page 1 ===
Event: Accepted: Call with
counsel
Start Date: 2020-02-20 20:00:00 +0000
End Date: 2020-02-20 20:30:00 +0000
Location:
will conference
in
Class: X-PERSONAL
Comment:
Date Created: 2020-02-25 04:49:58 +0000
Date Modified: 2020-02-25 04:49:58 +0000
Priority: 5
DTSTAMP: 2020-02-20 17:48:43 +0000
Attendee:
EFTA00026871


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=== Page 1 ===
Event:
Start Date: 2020-07-06 17:15:00 +0000
End Date: 2020-07-06 18:00:00 +0000
Organize
Location: https://usao.webex.com/usao/j.php?MTID=m9e79db001801f4b343b72dca13dedc17
Class: X-PERSONAL
Date Created: 2020-07-05 17:03:10 +0000
Date Modified: 2020-07-05 17:03:10 +0000
Priority: 5
DTSTAMP: 2020-07-05 16:47:12 +0000
Attendee
Alarm: Display the following message 15m before start
Reminder
https://usao.webex.com/usao/.php?MTID=m9e79db001801f4b343b72dca13dedc17
-- Do not delete or change any of the following text. --
When it's time, join your Webex meeting here.
Join meeting
Tap to join from a mobile device (attendees only)
EFTA00026403

=== Page 2 ===
Join from a video system or application
Dial 1995719104@usao.webex.com
You can also dial 207.182.190.20 and enter your meeting number.
Join using Microsoft Lync or Microsoft Skype for Business
Dial 1995719104.usao@lync.webex.com
If you are a host, click here to view host information.
Need help? Go to http://help.webex.com
EFTA00026404


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: State of the Office
Date: Mon, 01 Jun 2020 22:55:16 +0000
Attachments: SOTO - PCU - 2020.rc.docx
Some additions in the attached
From:
(USANYS)
Sent: Saturday, May 30, 2020 4:07 PM
To:
(USANYS)
Subject: State of the Office
I put something together modeled off what we did last year. Feel free to add/subtract, particularly if I missed anything
significant.
EFTA00025170


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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
(NYPD)"
,
(NY) (FBI)"
Bcc: "USAHUB-USAJournal111"
Subject: Call w/ SDNY re: discovery, Epstein investigation
Date: Thu, 22 Oct 2020 16:34:28 +0000
Embedded:Call_w_SDNY_re:_discovery,_Epstein_investigation.msg
Sender:
Subject: Call w/ SDNY re: discovery, Epstein investigation
Message-Id:
<BN3P110MB0292D5CE7185CFC8304060AD841D0@BN3P110MB0292.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
EFTA00025511


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=== Page 1 ===
From
To
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Date: Thu, 13 Aug 2020 21:07:08 +0000
Of course! Thank you for answering a million questions.
From:
Sent: Thursday, August 13, 2020 5:06 PM
To
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Thank you so much for handling!!
From:
Sent: Thursday, August 13, 2020 5:06 PM
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
I just sent the next round of discovery via FedEx. The password for this drive is
We also sent a letter with
the password in a separate envelope.
Please let us know when it arrives.
Thank you,
From:
Sent: Monday, August 10, 2020 6:03 PM
Subject: Re: delivery of hard drive to MDC for discovery production to inmate
That should be enough to track it down, thank you! If I have any issues, I'll let you know.
Best,
>>>
8/10/2020 5:59 PM >>>
I sent this via FedEx. When I enter the tracking number it says:
Delivered
Friday 8/07/2020 at 7:16 am
EFTA00026713

=== Page 2 ===
Let us know if you have any other questions.
Thanks!
Sent from my iPhone
On Aug 10, 2020, at 5:48 PM,
wrote:
Good evening
Just confirming - did you use FedEx, USPS, or some other carrier to send the discovery here? I have not received it yet, but
it could just be that staff did not notify me a package arrived. Depending on the carrier, it could be in the warehouse or
mailroom, so I just want to verify so I can find it expeditiously.
Thanks!
8/5/2020 7:13 PM >>>
That's extremely helpful, thanks so much. We'll plan to put the drive in the mail tomorrow, and of course please let us
know if any issues arise.
thanks again,
From:
Sent: Wednesday, August 05, 2020 19:05
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Hard drives should be mailed to the facility to the attention of the legal department. We need to etch the drive with a
number and provide an authorization memo so she can retain it. Then it will be provided to her. It can be password
protected so long as you include a cover letter that contains the password for her.
Hope this helps,
8/5/2020 4:34 PM >>>
We have a hard drive with loaded discovery that we need to deliver to Ghislaine Maxwell,
at MDC. Could
you please let us know what the current protocol is for that? Also, it's our understanding that hard drives with discovery
materials for inmates needs to be non-encrypted (and not have a password for access), is that also correct?
We're hoping to get these materials to her tomorrow if at all possible, so we greatly appreciate your help. And I'm
reachable any time at
if it would be helpful to discuss.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00026714


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=== Page 1 ===
From:
To:
)"
Cc:
)"
Subject: RE: Maxwell
Date: Mon, 08 Jul 2019 21:53:33 +0000
Inline-Images: image002.jpg; image003.jpg
Hello,
I'm checking to see if we are still on for a call today. I am available, at my office, I don't think we firmed up who is making
the call.
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain
information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to
the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing,
distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have
received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its
attachments without reading or saving it in any manner. Thank you
From:
)
[mailto:
Sent: Sunday, July 7, 2019 1:46 PM
To:
Pagliuca
Cc: Nicole Simmons;
);
)
Subject: RE: Maxwell
Thanks for speaking with me this afternoon. I've copied my colleagues,
and
so that you
have everyone's contact information.
In terms of scheduling a call tomorrow, we are going to be tied up in the morning, and the afternoon is a bit uncertain
given that we are not sure yet of the timing of the presentment for Mr. Epstein. I think it would make sense to plan for a
call at 4, and we can let you know if we need to reschedule, if that's alright with you.
EFTA00026637

=== Page 2 ===
Attached is the subpoena for Ms. Maxwell. The indictment is currently under seal, but we anticipate that it will be
unsealed tomorrow morning and publicly available. Please let us know tomorrow if you have any difficulty and we can
certainly send you a copy.
Thanks very much, and looking forward to discussing further tomorrow.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-2225
From:
Sent: Sunday, July 7, 2019 3:09 PM
To:
Cc:
Subject: Maxwell
Dear
It was a pleasure talking to you today. As we discussed, I am authorized to accept service of the subpoena for testimony
issued to Ms. Maxwell by the Grand Jury, SDNY. I expect that we will need to coordinate a mutually convenient time to
either appear or proffer, either in advance or in lieu of any testimony.
I will be in court tomorrow morning and afternoon, so I have a small window to discuss the matter- probably between
11am and noon and then again at around 4pm my time which is 2 hrs. earlier than the East Coast. My staff will attempt to
obtain a copy of the Epstein indictment as soon as it is publicly available. In my experience this can sometimes be difficult
so If it is not an inconvenience perhaps you could email the indictment along with the subpoena and waiver.
Best Regards,
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
VP
ISLL
Denver, Colorado 80203
Main
www.hmflaw.com
EFTA00026638

=== Page 3 ===
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain
information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to
the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing,
distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have
received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its
attachments without reading or saving it in any manner. Thank you
EFTA00026639


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From: New York Law360 <news@law360.com>
To:
Subject: Sheldon Silver Winds Up With 6½-Year Prison Term
Date: Tue, 21 Jul 2020 07:29:34 +0000
Law360 New York
NEW YORK
Tuesday, July 21, 2020
Follow Law360
TOP NEWS
Law360 Practice Groups of the
Sheldon Silver Winds Up With 61/2-Year Prison Term
Year
More than four years after he was first sentenced to 12 years in prison on
corruption charges, former New York State Assembly Speaker Sheldon Silver
on Monday was resentenced to a 61/2-year term, in a rejection of his bid for
home confinement.
Read full article
For Attys, Flexible Work Arrangements May Be Here To Stay
When COVID-19 hit the U.S. in March, law firms grappled with office closures
and remote-work arrangements to comply with local stay-at-home orders.
Four months later, many attorneys seem to have adapted to working from
home and may not need to return to the office anytime soon, experts said
during a panel discussion Monday.
Read full article
LAW FIRMS
Alva & Gleizer
Ex-Fox News Host Accused Of Rape In New Harassment Suit
Arnold & Porter
Fox News fired a producer after she was allegedly raped by ousted host Ed
Henry and complained about toxic workplace culture, while a female guest
Barclay Damon
lost out on a full-time job after refusing an advance from Tucker Carlson and
Berger Montague
enduring harassment by Sean Hannity, according to a lawsuit filed Monday.
Berke-Weiss Law PLLC
Complaint attached Read full article
Boies Schiller
Cleary Gottlieb
2nd Circ. Upholds Turkish Banker's Conviction
Covington & Burling
The Second Circuit upheld a Turkish banker's conviction for evading U.S.
Cravath Swaine
sanctions on Iran, saying in a Monday opinion that strong evidence
Davis Wright Tremaine
supported the jury verdict, even if one of the government's charging theories
missed the mark.
Debevoise & Plimpton
Opinion attached Read full article
Dechert
Dentons
Showtime Beats Cayuga Nation's 'Billions' Defamation Suit
Diserio Martin
A New York judge has tossed a defamation suit by the Cayuga Nation and a
Earthjustice
council member over what they called a negative portrayal of the tribal official
Eisenberg & Baum
in an episode of Showtime's fictional show "Billions," saying they hadn't
Garces & Grabler
shown the character was based closely enough on the council member.
Ghidotti Berger
Opinion attached Read full article
Gibbons PC
Sens. Moving Forward On Bill With 65 New Fed. Judgeships
Goldberg & Iryami
Two Republican senators are putting the finishing touches on a bill that would
Goodwin
create 65 new district judgeships, a move that would fulfill the federal
Harvey & Binnall
Haynes & Boone
EFTA00025392

=== Page 2 ===
judiciary's recommendation for addressing shortages in overworked courts
Herrick Feinstein
across the country.
Hodgson Russ
1 document attached Read full article
Hogan Lovells
23 AGs Challenge Rollback Of Transgender Health Protections
Jenner & Block
A coalition of 23 Democratic attorneys general sued the Trump administration
Jones Day
Monday over a rule eliminating civil rights protections for transgender people
under the Affordable Care Act, arguing the rule ignored the U.S. Supreme
Kaplan Fox
Court's landmark decision extending Title VII protections to LGBTQ workers.
Kirkland & Ellis
2 documents attached Read full
article
Klestadt Winters
Kobre & Kim
REAL ESTATE & DEVELOPMENT
Law Offices of Tim Powers
Levi & Korsinsky
5Pointz Owner Tells High Court Art Law Is Unconstitutional
Linklaters
A New York City real estate developer who destroyed a famed graffiti space
McCarter & English
known as 5Pointz asked the U.S. Supreme Court on Monday to strike down
as unconstitutional a federal law that protects works of art from harm.
McCulley McCluer
Petition attached Read full article
McDermott Will
Morgan Lewis
ENERGY & ENVIRONMENTAL
Norris McLaughlin
Orrick
EPA Escapes Long Island Sound Dumping Grounds Suit
Palazzo Law Firm
The U.S. Environmental Protection Agency acted within its rights when
Parker Ibrahim
designating an area of eastern Long Island Sound as a dumping ground for
Paul Weiss
dredged materials in a long-term plan for the region, a New York federal
judge ruled.
Peiffer Wolf
Order attached Read full article
Petrillo Klein
Rottenberg Lipman
Federal Coal Lease Ban Should Be Reinstated, AGs Say
Schneider Wallace
Several state attorneys general, environmentalists and a Native American
Selendy & Gay
tribe on Monday regrouped and took another stab at attempting to revive an
Shearman & Sterling
Obama-era moratorium on federal coal leasing after a federal judge recently
Sullivan & Worcester
shot down their initial attempt.
2 documents attached Read full article
Vinson & Elkins
Weitz & Luxenberg
EMPLOYMENT
Wigdor LLP
Wilkinson Walsh
WeWork Fights Atty's Bid To Appeal Arbitration Ruling
WilmerHale
A New York federal judge should reject a former WeWork attorney's bid to
Winston & Strawn
appeal a decision that the federal arbitration law trumps the state's arbitration
Ziontz Chestnut
rules on allegations of discrimination, as the question is not "exceptional," the
shared workspace company has argued.
Zumpano Patricios
Memorandum attached Read full article
COMPANIES
Advanced Micro Devices Inc.
SECURITIES & WHITE COLLAR
American Bar Association
SEC Seeks Sanctions For CEO Of Memorabilia Biz
Apple Inc.
The U.S. Securities and Exchange Commission asked a New York federal
Arctic Cat Inc.
judge Friday to sanction the CEO of a sports memorabilia auction company
Banco Santander SA
and his wife for violating a temporary restraining order in a multimillion-dollar
Bank of America Corp.
fraud suit, saying the couple covertly transferred cash from the U.S. to
Russia, perpetrated two insurance fraud schemes and destroyed
Barclays PLC
communications at the center of the schemes.
Celgene Corp.
Memorandum attached Read full article
Center for Biological Diversity
Chevron Corp.
Textron Escapes Investor Suit Over Arctic Cat Buy
China International Economic and
Textron Inc. slipped a proposed securities class action Monday after a New
Trade Arbitration Commission
York federal judge found that its shareholders hadn't properly alleged a single
Citigroup Inc.
EFTA00025393

=== Page 3 ===
misrepresentation regarding Textron's purchase of a snowmobile company in
Dell Technologies Inc.
2017.
Deutsche Bank AG
Opinion attached Read full article
El Paso Corporation
GOVERNMENT CONTRACTS
FedEx Corp.
Federation for American
Judge Says DOD Freight False Claims Suit Should Proceed
Immigration Reform
A New York federal magistrate judge recommended that most of the U.S.
FibroGen Inc.
Department of Defense's allegations in a False Claims Act suit accusing a
Ford Motor Co.
freight carrier of systematically overcharging the department move forward,
while refusing to transfer the case.
Fordham University
Report attached Read full article
Fox News Network LLC
Henry Schein Inc.
BANKRUPTCY
Hertz Global Holdings Inc.
ICAP
Cancer Center Beats Ex-Lobbyist's $6M Claim At 2nd Circ.
Immigration Reform Law Institute
The Second Circuit on Monday upheld a bankruptcy court finding that an ex-
lobbyist for 21st Century Oncology Holdings Inc. is not owed $7 million in
Intel Corp.
bonus pay, saying the letter of the law allows the bankrupt cancer chain to
JPMorgan Chase & Co.
cap his bonus.
Los Angeles Dodgers
Opinion attached Read full article
Mylan NV
National Women's Law Center
BANKING
New York City Bar Association
New York Civil Liberties Union
$12.6M Deal In Forex Rigging Suit Gets Initial OK
Nike Inc.
A $12.6 million allocation plan between a class of investors and several major
banks including JPMorgan Chase & Co., Standard Chartered PLC and Bank
Partnership for New York City
of America Corp. got preliminary approval by a New York federal judge to
Pivotal Software Inc.
resolve foreign exchange market rigging claims against the financial
QUALCOMM Inc.
institutions.
RFR Realty LLC
Order attached Read full article
Roku Inc.
Santander Investment Securities
TAX
Inc.
Servotronics Inc.
NYC Biz Execs Oppose Competitive Regional Tax Incentives
Showtime Networks Inc.
New York City business leaders asked political leaders Monday to consider
cutting tax subsidies, ending regional tax incentive competition and
Sierra Club
eliminating commercial rent taxes on some businesses in light of the
Southern Poverty Law Center
economic hit caused by the COVID-19 pandemic.
Standard Chartered PLC
Report attached Read full article
State Bar of California
Sunoco LP
PROJECT FINANCE
TD Ameritrade Holding Corp.
Vale Wins Bid For Docs In $500M Guinean Mining Project Fight
Tencent Holdings Ltd.
Textron Inc.
A New York judge on Monday allowed Brazilian mining company Vale SA to
seek information on the whereabouts of $500 million it invested in a doomed
The Boeing Co.
Guinean mining project to be used in U.K. litigation accusing Israeli billionaire
The Coca-Cola Co.
Beny Steinmetz of fraudulently inducing it to enter into the venture.
The Walt Disney Co.
Order attached Read full article
Thoratec Corporation
Twitter Inc.
IMMIGRATION
Vale SA
NYCLU Sues For Info On Child Refugee Atty Policy Change
WeWork Co. Inc.
The New York Civil Liberties Union filed a freedom-of-information suit
Witkoff Group
Monday seeking details from the Trump administration about what the rights
YRC Freight Inc.
group calls a stealth move to cut back on access to lawyers for
unaccompanied immigrant children in federal custody.
GOVERNMENT AGENCIES
Complaint attached
Read full article
Administration for Children and
Families
EFTA00025394

=== Page 4 ===
NATIVE AMERICAN
Bureau of Citizenship and
Immigration Services
Native Cig Co. Says NY Judge Should Snuff Out State's Suit
Bureau of Land Management
King Mountain Tobacco Co. has opposed the state of New York's request that
California Supreme Court
a federal court keep jurisdiction over the state's suit against the Native
Confederated Tribes and Bands of
American tobacco maker, saying claims King Mountain might have resumed
the Yakama Nation
shipping illegal cigarettes to New York are "flatly wrong."
European Commission
1 document attached Read full article
Executive Office for Immigration
Review
EXPERT ANALYSIS
Federal Bureau of Investigation
Despite 2nd Circ. Ruling, Discovery Statute's Reach Grows
Georgia Supreme Court
The Second Circuit's recent Guo ruling barring the use of cross-border
Judicial Conference of the United
discovery under Section 1782 in private, international commercial arbitration
States
is the exception to the rule of broad circuit-level interpretation as this statute
New York Attorney General's Office
becomes an increasingly powerful tool for litigators, say attorneys at Dechert.
New York City Council
Opinion attached Read full article
New York State Assembly
Northern Cheyenne Tribe
Mediator Confidentiality Promises Carry Serious Risks
U.S. Army
A mediation agreement that promises to keep evidence confidential could
result in a legal malpractice case for the mediator, and the risk has increased
U.S. Army Corps of Engineers
in the COVID-19 era of online sessions, says mediator Jeff Kichaven.
U.S. Attorney's Office
Read full article
U.S. Coast Guard
U.S. Court of Appeals for the
LEGAL INDUSTRY
District of Columbia Circuit
U.S. Court of Appeals for the Fifth
'Men's Rights' Atty Named As Killer Of Federal Judge's Son
Circuit
The deceased gunman suspected of killing U.S. District Judge Esther Salas'
U.S. Court of Appeals for the Ninth
son and wounding her husband at their New Jersey home was identified
Circuit
Monday as Roy Den Hollander, a solo "men's rights" attorney who has
U.S. Court of Appeals for the
argued before her, according to the FBI and U.S. attorney's office.
Second Circuit
Read full article
U.S. Court of Appeals for the Tenth
Circuit
Judge Whose Son Was Gunned Down Made History In NJ
U.S. Department of Defense
U.S. District Judge Esther Salas, whose son was killed and husband
U.S. Department of Health and
wounded in a shooting at their New Jersey home Sunday, has had a history-
Human Services
making judicial career marked by some of the most high-profile cases in the
Garden State, including a recent suit against Deutsche Bank AG over its ties
U.S. Department of Justice
to millionaire sex offender Jeffrey Epstein.
U.S. Department of the Interior
Read full article
U.S. District Court for the Central
District of California
Analysis
U.S. District Court for the District of
Salas Attack Highlights Importance Of Judicial Security
Delaware
Past violent attacks on judges and their families have spurred attempts to
U.S. District Court for the Eastern
address weaknesses in judicial security, but following a fatal shooting at the
District of New York
home of U.S. District Judge Esther Salas in New Jersey on Sunday, experts
U.S. District Court for the Eastern
say that even more can be done to ensure the safety of judges and those
District of Texas
close to them.
Read full article
U.S. District Court for the Southern
District of New York
Haynes And Boone Eyes Expansion With New Leader
U.S. District Court for the Western
District of New York
A new managing partner will take the helm at Haynes and Boone LLP in
January as the Texas-based firm sets lofty goals to expand at home in Texas
U.S. District Court for the Western
and in its national and international offices, the firm announced Monday.
District of Texas
Read full article
U.S. Environmental Protection
Agency
Coca-Cola, Ford Each Name New General Counsel
U.S. Navy
EFTA00025395

=== Page 5 ===
The Coca-Cola Co. and Ford Motor Co. announced Monday that they will
U.S. Securities and Exchange
both have new general counsel, with the automotive giant's top attorney
Commission
shifting over to the beverage company.
U.S. Supreme Court
Read full article
United States District Court for the
Gun-Toting St. Louis Attys Charged Over Anti-Protest Standoff
District of Montana
Husband-and-wife attorneys who run a prominent St. Louis personal injury
firm were charged with a felony apiece in Missouri state court Monday as
prosecutors say they brandished an assault rifle and a handgun while
confronting protesters marching outside their home last month.
Read full article
Allow Menstrual Products At Bar Exam, Thousands Tell NCBE
Thousands of law professors, lawyers and law students on Monday urged the
National Conference of Bar Examiners to clarify that examinees must be
permitted to bring menstrual products to the Multistate Bar Examination,
characterizing some states' practice of banning them as "illogical" and
"shaming."
Read full article
Ga. Is Latest State To Delay Bar Exam And Move Online
Georgia's high court on Monday canceled the in-person bar examination
scheduled for September and moved the test online, joining a growing list of
states that have changed plans for the exam as a result of COVID-19.
Read full article
Survey Finds Most Judges Say Systemic Racism Is An Issue
A National Judicial College poll released Monday found that 65% of the
judges who responded believe systemic racism is part of the U.S. criminal
justice system, with many leaving comments that suggested the problem was
one the judiciary should be paying close attention to.
Read full article
2 Ex-High Court Clerks Exit BigLaw For The MacArthur Center
The appellate practices at Orrick and Jenner & Block each lost a former
Supreme Court clerk this month to the MacArthur Justice Center, a Chicago
public interest law firm aimed at criminal justice reform.
Read full article
Flynn Says Trial Judge 'Hijacked' Case With En Banc Bid
President Donald Trump's former national security adviser Michael Flynn
accused a federal judge Monday of hijacking his criminal prosecution by
refusing to immediately grant the government's request to end his case and
urged the full D.C. Circuit to allow a recent ruling ordering his case's
dismissal to stand without a review.
Read full article
Avenatti Is Out Of Money For Legal Fees, Lawyer Says
Michael Avenatti is out of money and can't afford the legal fees for his
upcoming embezzlement trial, his counsel told a California federal judge over
the weekend, asking to continue representing the embattled attorney on a
publicly funded basis.
Read full article
Expert Witness Sues Levi & Korsinsky For Unpaid Fees
Securities and consumer litigation law firm Levi & Korsinsky LLP has not paid
a financial industry consulting firm for its work as an expert witness in a
proposed class action against TD Ameritrade Inc. and has refused to respond
to a demand for arbitration, according to a suit filed in Connecticut state
court.
EFTA00025396

=== Page 6 ===
Read full article
Ex-FAIR Research Director Among 46 New Immigration Judges
Former immigration judges said Monday that the Trump administration's
recent appointments of 46 immigration judges are "a fraud on American
justice" and that the appointment of a former leader of an immigration
restrictionist organization will make it "impossible for one to receive a fair
hearing."
Read full article
Interview
15 Minutes With Geometer's Chief Legal Officer
After in-house stints at EMC and a cloud software company spun out by Dell
EMC and VMware, Andrew Cohen earlier this year helped establish a
software incubator that dedicates a quarter of its projects to furthering the
social good. Here, the head lawyer shares more about the challenges at
Geometer, and the ways he has seen the general counsel role change.
Read full article
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EFTA00025397


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c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025435.pdf
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c7: images
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=== Page 1 ===
4
MCC new YORK
mcc new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
SPECIAL housing UNIT
ZA
TIER-G
DATE: 08/10/2019
TIME
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TIME
TIME
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TIME FRAME
TIME
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END
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END
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12:00-12:30 AM
1209
1210
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1241
1242
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
1"
112
9:00-9:30 AM
5:00-5:30 PM
1:30-2:00 AM
137
138
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
207
208
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
241
242
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
309
308
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
343
34
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
4"4
47
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
440
4"
12:30- 1:00 PM
8:30- 9:00 PM
5:00-5:30 AM
508
509
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
5"
542
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
410
4"
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00025435

=== Page 2 ===
mcc new YORK
acc new YORK
MCC NEW YORK
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SPECIALHOUSING UNIT
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ZA
TIER-H
DATE: 08/10/2019
TIME
TIME
TIME
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TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
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END
START
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START
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12:00-12:30 AM
12"
1219
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1245
1244
8:30- 9:00 AM
4:30-5:00 PM
1:00-1:30 AM
13
114-
9:00-9:30 AM
5:00-5:30 PM
1:30-2:00 AM
1:37
138
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
2"
2"
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
245
240
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
3"
3
D
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
343
344
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
414
4
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
+140
441
12:30- 1:00 PM
8:30-9:00 PM
5:00-5:30 AM
510
5"
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
543
544
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
612
103
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates ( onfined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at le: st once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another roun 1 in the second 30 minutes period of the same hour (example, 12:30
am- 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 0 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
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=== Page 3 ===
MOC new YORK
MCC NEW YORK
mcc new YORK
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SPECIAL HOUSING UNIT
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SPECIAL HOUSING UNIT
TIER-J
DATE: 08/10/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1205
1206
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1237
1238
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
107
Psol
9:00-9:30 AM
5:00-5:30 PM
1:30-2:00 AM
135
136
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
2.05
200
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
2399
240
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
305
36
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
339
3400
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
aily
413
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
436
12:30- 1:00 PM
8:30-9:00 PM
5:00-5:30 AM
504
505
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
534
538
1:30-2:00 PM
9:30-10:00 PM
6
$ 59
of
6:00-6:30 AM
6
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
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=== Page 4 ===
new YORK
MCC NEW YORK
MGC new YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
JERS NOUSING UNIT
ZA
SPECIAL HOUSING UNIT
TIER-K
DATE: 08/10/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
FRAME
START
END
START
END
START
END
12:00-12:30 AM
1207
120
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1259
1040
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
109
110
9:00-9:30 AM
5:00-5:30 PM
1:30-2:00 AM
137
138
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
267
208
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
241
242
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
307
308
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
341
342
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
4th
4
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
438
43
12:30- 1:00 PM
8:30-9:00 PM
5:00-5:30 AM
506
502
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
539
540
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
0°8
600
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
RNING WATCH
DAY WATCH
EVENING WATCH
ERATIONS
OPERATIONS
OPERATIONS
UTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00025438

=== Page 5 ===
moo new TORK
MOG new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIMENOUSING UNIT
SPECIME HOUSING UNIT
ZA
TIER- L
DATE: 08/10/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1201
1202
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1233
1234
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
103
104
9:00-9:30 AM
5:00 -5:30 PM
1:30-2:00 AM
131
132
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
201
202
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
235
234
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
001
302
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
333
1/2
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
406
407
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
430
43
12:30- 1:00 PM
8:30-9:00 PM
5:00-5:30 AM
500
you
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
533
534
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
602
(003
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00025439

=== Page 6 ===
moo new YORK
moo new TORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
SPECIAL HOUSENG UNIT
ZA
TIER-M
DATE: 08/10/2019
TIME
TIME
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
203
1204
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1235
1236
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
105
106
9:00-9:30 AM
5:00-5:30 PM
1:30-2:00 AM
133
134
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
203
204
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
22
238
10:30-11:00 AM
6:30-7:00 PM
304
7:00-7:30 PM
3:00-3:30 AM
303
11:00-11:30 AM
3:30-4:00 AM
333
334
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
408
409
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
434
for
12:30- 1:00 PM
8:30- 9:00 PM
5:00-5:30 AM
502
503
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
535
534
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
604
605
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
P
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00025440


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c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024275.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Messages
Page 1 of 4
Records Listed For: JEFFREY EPSTEIN from 04/11/2005 to 04/11/2005
From
Message
Phone
Done
1. Call
reminders
2. Call William
Gowen
7:43AM
w) 3. Peter Mandelson In Paris on
Thursday 4. Pinto in Paris this week
Just FYI flight info:
and me Jetblue 623 arriving 12.20pm
WPB.
8:54AM
678 jetblue, leaving WPB 11.10 am, arriving JFK
1.45pm. Citicar picking up
LM for Emad to talk to Paul Gandy re phone system and electric
9:35AM
distribution.
Yanush is picking up
and
9:35AM
Miles
9:37AM
Will email photos of beach house floor.
9:55AM
I lost my cell phone, but will be in the office after 10:30.
You had wanted me to put the tiles on the Midnight express for
G
the cabana - the midnight express has not left yet as you know -
10:13AM
should I wait for the boat to come to FLA or orgnaise for the tiles
to be sent to PB
Warren
Elsenstein
Where should I mail the DVD?
10:17AM
I'm available all week except for Thurs, if you're around.
10:20AM
Ira
Zicherman
Bought 50 000 CELG at $437.068
10:22AM
Pls call.
10:24AM
Looking In a realestate magazine - there are 2 hses for sale PB
G
w/ direct ocean front - Christine COndon in PB -
+
10:27AM
another Carole Koeppel
they were in the NY
times realestate mag
10:33AM
Lm for G to just send the tiles.
Ira
Stock is trading at 36.79. I understand there are some
Zicherman
additional shares, some blocks available in this area. Do you
10:35AM
have any interest?
LM for
10:49AM
to call.
G
bought bought the two vases (6.500 Euros) and the large
11:06AM
console (4.200 Euros - nice surprise).
http://domsrv01/foxhaven/wc.d1l7Gmax-MsgDisplay
4/11/2005
EFTA00024275

=== Page 2 ===
Messages
Page 2 of 4
11:07AM
Call me at the office (I tried to connect you).
Prof. Camhi
Pls call
11:16AM
Miles
Schnitman
Just calling to see where we stand.
11:24AM
Eric
11:34AM
Dr. Landon's $25k quartly payment is due, please approve.
Dan
Sperberg
Calling re meeting. I'm in NY until Mon. Pls email your reply.
11:38AM
George
Reenstra
Via email re photos of other 76 s: That is on temp hold,
11:40AM
apparently we are now painting all black with a camel stripe
LM for
re is any of her friends
12:17PM
back?
Naomi
Via email: Hello, naomi here would like to know when I can
Campbell
speak with Jeffery, regarding my swimsuit line. For a meeting
12:18PM
with VS to see,I have pics and some of the sults with me.. Hope
is well
12:26PM
LM and emailed Dan Sperberg to call.
Bill Karr
12:27PM
I will email the plans later today.
Dr. Jarecki
Please call.
12:33PM
12:43PM
LM for Jerry Goldsmith re has lawyer letter been sent out yet?
Calling for Congressman Tom Reynolds regarding the June 14th
12:50PM
annual dinner with Bush. NRCC Business Advisory.
G
Spoke to Miles re sending the blue tiles for the cabana to PB -
12:51PM
you sd to him last week to keep them for the Tiki house kitchen
- plse advise
Kenneth
Cole
Returning your call.
12:51PM
I'm back in NY.
1:45PM
From Dr. Moskovitz' office. We're trying to find some place in NY
2:04PM
where
can have her heart test done.
is back.
2:29PM
Call me re what we talked about.
http://domsrv01/foxhaven/wc.dll7Gmax-MsgDisplay
4/11/2005
EFTA00024276

=== Page 3 ===
Messages
Page 3 of 4
2:38PM
Fiona
From Dr. Jarecki's. Pls call.
2:39PM
From Dr. Moskowitz's office.
can get the heart test done
on Fri in NY. Appt at 3.30pm, check-In 3.15pm. Faculty practice
2:43PM
radiology, 530 1st ave, G elevator to 13th floor, $1656 total,
Is there a check for me?
2:44PM
Eric
Please confirm that I am wiring $3mm from your account to MJ
2:54PM
LLC.
Can
and I work this week?
2:55PM
Jerry
Goldsmith
Gowdy was out of town, but the letter will be delivered today.
2:57PM
Leighton Chandler doesn't know if she can organize for me to
see the mansion this week as it is just getting on the market.
G
She will check to see if she get me in tomorrow. If not, it will
3:02PM
have to be the next time I'm in town. *** Copied From
GHISLAINE MAXWELL *** Original Date and Time: 04/11/2005
at 2:19P
via my email: Please let Jeffrey know that if he intends to
Greg Hersch
participate in the Emerging Market Special Opportunities fund
3:08PM
that the deadline for subscription docs is next Wednesday, April
20 for May 1 trading. Thanks!
3:11PM
will pick up
prescription. WHere should I fedex it?
Eric
FYI: on the Dr. Landon quarterly payments, we (NYSG) billed
3:11PM
LHW/Abigail In advance as we have in prior years.
Pls call.
3:29PM
Larry
Newman
I just need a few more minutes if you have time.
3:39PM
4:17PM
Just calling to check in.
G
The Tel Aviv ticket was not a fraud. It was to get a renewal for
4:21PM
your 2nd valid passport. We're getting a refund for it.
The pool specialist can't come tomorrow in PB. He can only come
4:26PM
on wednesday morning If it's ok for you. Pls advice
Fro the power symposium, we are looking at 4 days between
January 6, 2006 and January 17th or 18th. The participants
4:27PM
working on their schedules and need to know ASAP. We also
need to let the hotel so we don't lose our $20,000 deposit.
http://domsrv01/foxhaven/wc.dllGmax-MsgDisplay
4/11/2005
EFTA00024277

=== Page 4 ===
Messages
Page 4 of 4
4:27PM
I had
on the line for you.
Dr. Victor
Pls call.
4:28PM
can work tomorrow at 4pm.
4:29PM
I had Dan Sperberg on the line for you. He will call back since he
4:41PM
has no reception in the library.
I forwarded helicopter pictures from George Reenstra to your
4:45PM
yahoo.
I had Dr. Jarecki on the line.
4:47PM
G
4:50PM
got her aesthetician license and can not do facials.
manu
GYM works in Paris: 3 weeks 1/2 to finish. Pinto waiting for a
4:54PM
starting date ( possibly 8 days of advance to organize it).
Bill Karr
The mail server Is down, but I will email the plans as soon as I
4:55PM
can.
Outstanding
did not call back
4:56PM
Callers
Prof. Camhi, Miles Schnitman,
4:56PM
Dr. Victor.
Mark Checked, Messages as Read
Copyright (c) 2000-2004, Epstein Interests, Inc. All Rights Reserved
http://domsrv01/foxhaven/wc.dll1Gmax-MsgDisplay
4/11/2005
EFTA00024278


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023747.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
Date: Mon, 14 Sep 2020 19:29:32 +0000
Received, thank you very much.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
Original Message
From:
Sent: Monday, September 14, 2020 3:23 PM
To:
Subject: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
The attached document is in regard to the above referenced case, to which you are a party of or have an interest
in. If you have any questions, please contact our office at
EFTA00023747


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c3: VOL00008
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c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Maxwell - Telephone Conference Tomorrow
Date: Thu, 21 Oct 2021 00:17:58 +0000
Attachments: 2021.10.19_Order_re_October_21_Teleconference.pdf
I know Bobbi Sternheim emailed you earlier about the telephone conference being held by Judge Nathan tomorrow at
noon. I just wanted to follow up in case you had any questions and make sure that you have all the information you
need. The Court emailed the parties that the phone number for the defendant for tomorrow's conference is
with access code
I'm attaching the Court's order on this, which provides the separate dial-in for members
of the press and the public. Please let us know if you have any questions.
Thanks so much,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00026478


c1: EFTA00024829
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024829.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: Re: Ghislaine Maxwell Victim Update
Date: Mon, 29 Nov 2021 19:08:28 +0000
If the previous link didn't work, this one should: https://www.justice.gov/usao-sdny/united-states-v-ghislaine-maxvwel
,
thanks for providing that language, very helpful to be able to simply copy/paste on a very hectic day!
Sent from my iPhone
On Nov 29, 2021, at 1:21 PM,
(USANYS)
wrote:
please insert this into our Ghislaine Maxwell victim page ( https://www.justice.gov/usao-sdny/united-
states-v-ghislaine-maxwell ) right above the last update entry dated October 20, 2021? Let me know. Thanks.
November 29, 2021 update:
Victim Attendance at Trial. In orders dated October 14 and November 24, 2021, the S.D.N.Y.
Court outlined procedures for public access to the trial in this matter. (Trial began on November
29, 2021, with jury selection.) Specifically, consistent with the District's COVID-19 protocols, the
Court will ensure public access (with COVID-19 distancing) to the trial in the courtroom itself and
in several overflow rooms at the courthouse with live feeds of the proceedings. Beyond the live
feeds within the courthouse, the trial will not be further broadcast; nor will there be any telephonic
dial-in to the proceedings. Victim access will be coordinated by the U.S. Attorney's Office Victim-
Witness Coordinator,
Victims who wish to attend the trial may contact either one of
those persons for further information.
COVID-19 Protocols. Per the S.D.N.Y. Response to COVID-19, anyone who appears at any
S.D.N.Y. courthouse must complete a questionnaire on the date of the proceeding prior to
entering the courthouse. All visitors must also have their temperature taken when they arrive at
the courthouse. Only persons who meet the entry requirements established by the questionnaire
and whose temperatures are below 100.4 degrees will be allowed to enter the courthouse. All
visitors must wear a mask that covers the person's nose and mouth. Bandannas, gaiters, and
masks with valves are not permitted. If a person does not have an approved mask, a screener
will provide one. Anyone who fails to comply with the COVID-19 protocols that have been
adopted by the Court will be required to leave the courthouse. There are no exceptions. For more
information, please see https://www.nysd.uscourts.gov/covid-19-coronavirus.
Thanks.
EFTA00024829


c1: EFTA00023822
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023822.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
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 January 23, 2010, 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 2/5/2020
(date)
(signature of declarant)
Fraud Analyst
(name and title of declarant)
American Airlines
(name of business)
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.
EFTA00023822

=== Page 2 ===
Record Locator: TYPJ
American Airlines CONFIDENTIAL for official use only.
Booked: 2019-06-25
PASSENGER INFORMATION
Pax Nbr
Name
1.01
FLIGHT INFORMATION
Seq Nbr Flight Class
Date
Dep
Arv
Stat
Qty
Dep TimejArv Time
1
AA167
V
22SEP2019
AX
BOS
HK
1
09:50
18:25
2
AA2542
G
01OCT2019
BOS
LAX
HK
1
17:22
20:49
TICKET INFORMATION
Seq Nbr
Ticket or Time Limit
1
T-06SEP-XTM725Z
2
TE 0012362566941
XTM763Q 1513/25JUN 1B*77E711
3
TE 0012376452019
XTM7WWA 0840/06SEP 1B*435FC1
4
TK 0010655804777
XTM725Z 0846/06SEP AE 1B*7BE52E
PHONE INF ORMATION
Seq Nbr
Phone Number
1
1
ADDRESS INFORMATION
Address
FREQUENT FLYER INFO
Seq Nbr
Frequent Traveler
1
AA 216FYK8 HKAA 1.0
ADV
PRE REQUESTED SEATS INFO
Seq Nbr Flight
Class
Seat
DepartArrive Status
Name
1
AA167
V
17C
LAX
BOS
HK
-1.01
2
AA2542
G
17D
BOS
LAX
HK
-1.01
OSI INFO
Seq Nbr
OSI
1
OSI PURCHASED ON AA.COM US 06/25/2019 IN US CURRENCY
CONFIDENTIAL//For Offical Use Only
1
EFTA00023823

=== Page 3 ===
Record Locator: TIYP.
SSR
Seq Nor Type
SSR
1
DOCA/R/US///CA
2
DOCS/DB/02AUG1980/F
3
CCRD/CBAV NN1
4
GRPO2542G1OCT/PREM CC NN1
5
GRPOl167V22SEP/PREM CC NN1
REMARKS INFORMATION
Seq Nbr
Remarks
1
1. TBMX-ADD
2
2.H-/T$TTE11/117.99/200.00/N1.1
3
3.H-/T$TTE12/VCR0012362566941/C1-2
4
4.H-/T$DOC$VCR
5
.H-/T$DLVEMAILSJESSSABELLADIST.COM$0 0/00/00
6
6.H-/T$TBM*1K544045XXXXXX0435$03/23
7
7.H-/T$LINDAJ HILL
8
8.H-/T$WWWW EAU
9
9.H-/T$CCBC US
10
10.H-71.220.179.114
11
11.H-TRANC 5A0D9736-0D9B-4BA6-BB4B-CD4E0E789583
12
12.H-WWW/AUTH/CID IK3396 BANK VERIFIED CID
13
13.H-IPPADDR71.220.243.32$
14
14.H-TRANP 19D012F3-7053-42B3-8D9F-67E8CE1B98B8
15
15.H-PT11.1-ADT-ADT
16
16.H-BOOKED AMERICAN AIRLINES WEB SITE US IN US CURRENCY
17
17.H-IPHADDR71.220.243.32$
18
18.H-TRANH 19D012F3-7053-42B3-8D9F-67E8CE1B98B8
19
19.XXTACXTM25JUN/
20
20.H-RES CHANGE MADE VIA AMERICAN AIRLINES WEBSITE IN US CURRENCY
21
21.H-/TSFEE$PSEATS17C$N1.1$S1$42.01/3.15$USD
22
22.H-/T$FEESPSEATS17D$N1.1$S2$31.05/2.33$USD
23
23.XXAUTH/01210Z *Z
24
24.XXTTEXTM06 SEP/
25
25.H-T$EXCHANGE PROCESSED BY ETDS AUTOMATED EDITOR
26
26.ZXZ420
27
27.H-/TSTBMEDIT/EMAIL SENT 0846/06SEP/TDS
28
28.H-01 AE -PREFERRED SEATS USD 78.54
29
29.H-0012376452019
30
30.H-PC/PSGR CLEARED FOR TRAVEL/CORPORATE SECURITY/01
31
31.BAG-TAG ACCEPTED 3001142105 22SEP2019 1048/LAX/8MSG
32
32.BAG-SELFTAG 142105 D ACTIVATED BY 931547 22SEP2019 1048/LAX
33
33.H-OVERRIDE BY LAXJS1 22SEP19
GT
34
34.H-TICKET 0012376452019 0167 LAX BOS
35
35.H-01CHK BAG FEES
36
36.H-OVERRIDE BY BOS85S 01OCT19
GT
37
37.H-TICKET 0012376452019 2542 BOS LAX
38
38.H-01CHK BAG FEES 01EXCES PIECES
CONFIDENTIAL//For Offical Use Only
2
EFTA00023824

=== Page 4 ===
Record Locator:
LTIYPJ
BAGGAGE INFO
Seq NbrBag Routing Flight Bag Destination/Bag Psor Name Rag Tan NumberBag Checkin Agent/Bag Checkin LCL Date/Bag Checkin LCL Time
1
AA167
BOS
AA145755
LAX 5JS1
2019-09-22
09:37 AM
1
AA167
BOS
AA142105
LAX 5SMD
2019-09-22
08:33 AM
2
AA2542
LAX
AA546800
BOS 585S
2019-10-01
05:05 PM
2
AA2542
LAX
AA545128
BOS 590J
2019-10-01
03:54 PM
2
AA2542
LAX
AA546801
BOS 585S
2019-10-01
05:05 PM
PNR HISTORY
Seq
Nbr
Update Time
AAA
TTY
Received From
Airline or CRS
Agent Sine
Trans Seq
Code
OFFICE
Cd
Nbr
Code
History Data
29
01OCT19
16:56
PDCAABOS254201OCT
BOS
BOS5PD
1
UAX
RED SEATS/FL1 /AA2542G01OCT2019BOSLAX-
28
01OCT19
16:05
BOS
BOS585S
1
A5H
H-OVERRIDEBY BOS85S 01OCT19
GT
28
2
A5H
H-TICKET 0012376452019 2542 BOS LAX
28
3
A5H
H-01CHK BAG FEES 01EXCES PIECES
22SEP19
26
12:13
PDCAALAX016722SEP
LAX
LAX5PD
PREFERRED SEATS/FL1 /AA0167V22SEP2019LAXBOS-
1
UAX
25
22SEP19
11:37
LAX
LAX5JS1
1
A5H
H-OVERRIDE BY LAXJS1 22SEP19
GT
25
2
A5H
H-TICKET 0012376452019 0167 LAX BOS
25
3
A5H
H-01CHK BAG FEES
22SEP19
24
10:32
WWWSRIPACLIENT
CRC
CRC80D1
1
A4S
SSR /CBAV NN1
24
22SEP19
WWWSRIPACLIENT
10:32
CRC
CRC80D1
1
A4S
24
2
A4S
SSR 2542G1OCT/PREM CC NN1
24
2
A4S
SSR GRPO AA NN1. 2542G1OCT/PREM CC NN1
24
3
A4S
SSR 167V22SEP/PREM CC NN1
24
3
A4S
SSR GRPO AA NN1. 167V22SEP/PREM CC NN1
23
22SEP19
10:32
WWWSSSM
GSW
GSW5SSM
1
AFF
AA 216FYK8 NN/HK-AA
22
19SEP19
SCC UPDATE
10:51
CRC
HDQ8PAY
1
A5H
H-PC/PSGR CLEARED FOR TRAVEL/CORPORATE SECURITY/01
19SEP19
21
07:37
WWWSGUEST
www
HDQ5777
1
A9
21
2
A9
20
06SEP19
ITKTS
FULFILLMENT
08:46
XTM
XTM725Z
1
X5H
H-TBMEDIT/RSAPPP15 EDITOR SESSION 25
20
2
A5H
H-01 AE -PREFERRED SEATS USD 78.54
20
3
A5H
H-0012376452019
20
4
X7
T-06SEP-XTM7WWA
20
5
A7
T-06SEP-XTM7252
20
6
UAX
PREFERRED SEATS/HI1 /AA0167V22SEP2019LAXBO S-
20
7
UAX
SEATS/HI1 /AA2542G01OCT2019BOSLAX-
06SEP19
19
08:46
TDSEMAILEDIT/0848/06SEP/TDS
XTM
XTM7UEB
1
A5H
H-/T$TBMEDIT/EMAIL SENT 0846/06SEP/TDS
CONFIDENTIAL//For Offical Use Only
3
EFTA00023825

=== Page 5 ===
Record Locator:
LTIYP,
PNR HISTORY
06SEP19
18
TDSED
08:42
TOR/0842/06SEP/EVN
XTM
XTM7EVN
1
X5H
H-TBMEDIT/RSAPPP15 EDITOR SESSION 23
18
2
A5H
H-TBMEDIT/RSAPPP15 EDITOR SESSION 25
06SEP19
17
08:40
TDSED
TOR/0840/06SEP/WWA
XTM
XTM7WWA
1
A5H
H-TBMEDIT/RSAPPP15 EDITOR SESSION 23
17
2
ASH
H-T$EXCHANGE PROCESSED BY ETDS AUTOMATED EDITOR
17
3
X7
TTEXTM06SEP/
17
4
A7
T-06SEP-XTM7WWA
16
06SEP19
08:31
WWWSGUEST
WWW
WWW2777
1
X4O
OSI AA VIEWRES ADVISE CUST OF FLT CHG 14JUL19 1852
15
06SEP19
WWWS0A34UM0
WWW
08:12
WWW2777
1
A5H
H-/TSFEESPSEATS17C$N1.1$S1$42.01/3.15SUSD
15
2
A5H
H-/TSFEESPSEAT$17D$N1.1$S2$31.05/2.33SUSD
14
06SEP19
ITKTS FULFILLMENT
08:12
XTM
XTM7IGW
1
X4G
AA 2542G 01OCT2019 BOSLAX HK/SS 34E
14
2
A4G
AA 2542G 01OCT2019 BOSLAX SS/NN 170
14
3
UAX
PREFERRED SEATS/HD1 /AA2542G01OCT2019BOSLAX-
06SEP19
13
08:12
ITKTS FULFILLMENT
XTM
XTM7IGW
1
X4G
AA 167V 22SEP2019 LAXBOS HK/SS 358
13
2
A4G
AA 167V 22SEP2019 LAXBOS SS/NN 17C
13
PREFERRED SEATS/HD1 /AA0167V22SEP2019LAXBOS-
3
UAX
06SEP19
12
08:12
ITKTS FULFILLMENT
XTM
XTM7IGW
1
AAX
12
2
AAX
06SEP19
11
08:12
WWWS0A34UM0
www
WWW2777
1
X5H
H-/TSTBMEDIT/EMAIL SENT 1519/25JUN/TDS
11
2
X5H
H-TBMUSD297.72 BASE AMT PLUS SECURITY PER
ADT/1504/25JU
11
3
X5H
H-/T$3RD PARTY$15 DAYS OUT
11
4
X5H
H-/T$WWW EAU
11
5
X5H
H-/T$CCBC US
11
6
X5H
HI
11
7
X5H
H-/T$DOC$VCR
11
8
X5H
H-TBMEDIT/TKT DRIVEN FOR 336.61/1513/25JUN
11
9
X5H
H-TBMEDIT/ALL PQS DELETED AND PLACED INTO HISTORY
11
10
X5H
H-TBMEDIT/RSAPPP18 EDITOR SESSION 40
11
11
X5H
H-TBMEDIT/RSAPPP33 EDITOR SESSION 30
11
12
X5F
-TBMMK546638XXXXXX3396$07/20
11
13
X5F
11
14
A5F
--TBMXX-ADD
11
15
A5H
H-/TSTTE11/117.99/200.00/N1.1
11
16
A5H
H-/TSTTE12/VCR0012362566941/C1-2
11
17
A5H
H-/T$DOC$VCR
11
18
A5H
H-/T$DLV
00/00/00
11
19
A5H
H-/T$TBMIK544045XXXXXX0435$03/23
11
20
A5H
H-/T$L
11
21
A5H
H-/TSWWW EAU
11
22
A5H
H-/T$CCBC US
CONFIDENTIAL/For Offical Use Only
4
EFTA00023826

=== Page 6 ===
Record Locator:
LTIYPJ
PNR HISTORY
11
23
A5H
H-71.220.179.114
11
24
A5H
H-TRANC 5A0D9736-0D9B-4BA6-BB4B-CD4E0E789583
11
25
A5H
H-RES CHANGE MADE VIA AMERICAN AIRLINES WEBSITE IN US
C
11
26
X7
T-25JUN-XTM763Q
11
27
A7
TTEXTM06SEP/
11
28
X4G*
AA 167N 25SEP2019 LAXBOS HK/SC 20F
11
29
X4G*
AA 1161N 28SEP2019 BOSLAX HK/SS 20A
11
30
A4G
AA 167V 22SEP2019 LAXBOS SS/NN 35B
11
31
A4G
AA 2542G 01OCT2019 BOSLAX SS/NN 34E
11
32
XS
AA 167 N 25SEP2019 LAX BOS SC/HK 1 09:50 18:25
11
33
XS
AA 1161 N 28SEP2019 BOS LAX NN/HK1 12:43 15:58
11
34
AS
AA 167 V 22SEP2019 LAX BOS NN/SS 1 09:50 18:25
11
35
AS
AA 2542 G 01OCT2019 BOS LAX NN/SS1 17:22 20:49
10
9
XW
10
10
AW
15JUL19
9
05:54
TDSEDITOR/0554/15JUL/SCN
XTM
XTM7SCN
1
A5H
H-TBMEDIT/RSAPPP33 EDITOR SESSION 30
8
15JUL19
05:40
TDSEDITOR/0540/15JUL/WSC
XTM
XTM5WSC
1
A5H
H-TBMEDIT/RSAPPP18 EDITOR SESSION 40
8
2
XS
AA 167 N 26SEP2019 LAX BOS HK/WK 1 10:00 18:37
8
3
SC
AA 167 N 25SEP2019 LAX BOS SC/HK1 09:50 18:25
14JUL19
7
18:52
XTM
XIM7ROB
1
A40
OSI AA VIEWRES - ADVISE CUST OF FLT CHG 14JUL19 1852
14JUL19
6
06:09
SC.REAC.E18JUL19
1
X4G
AA 167N 25SEP2019 LAXBOS WK/HK 20F
6
2
A4G
AA 167N 25SEP2019 LAXBOS SC/SC 20F
6
3
SC
AA 167 N 25SEP2019 LAX BOS HK/WK1 10:00 18:37
6
4
AS
AA 167 N 25SEP2019 LAX BOS SC/SC 1 09:50 18:25
5
25JUN19
TDSEMAILEDIT/1519/25JUN/TDS
XTM
15:19
XTM7UVR
1
A5H
H-/T$TBMEDIT/EMAIL SENT 1519/25JUN/TDS
25JUN19
EDITOR EDITOR E051619-49 CC WEB NON
4
15:13
RUSH
XTM
XTM763Q
1
A5H
H-TBMEDIT/ALL PQS DELETED AND PLACED INTO HISTORY
4
2
A5H
H-TBMEDIT/TKT DRIVEN FOR 336.61/1513/25JUN
4
3
X7
TACXTM25JUN/
4
4
A7
T-25JUN-XTM763Q
25JUN19
3
15:04
WWWS0A34UM0
www
HDQ2EAU
1
A40
OSI PURCHASED ON AA.COM US 06/25/2019 IN US CURRENCY
3
6
AW
3
7
A5F
-TBM*IK546638XXXXXX3396$07/20
3
8
A5F
3
9
A5H
H-/T$DOC$VCR
3
10
A5H
H-/T$DLVS
3
11
A5H
H-/T$CCBC US
3
12
A5H
H-/TSWWW EAU
CONFIDENTIAL//For Offical Use Only
5
EFTA00023827

=== Page 7 ===
Record Locator:LTIYPJ
PNR HISTORY
3
13
A5H
H-/T$3RD PARTY$15 DAYS OUT
3
14
A5H
H-WWW/AUTH/CID IK3396 BANK VERIFIED CID
3
15
A5H
H-IPPADDR71.220.243.32$
3
16
A5H
H-TRANP 19D012F3-7053-42B3-8D9F-67E8CE1B9BBB
3
17
A5H
H-TBMUSD297.72 BASE AMT PLUS SECURITY PER
ADT/1504/25JU
3
18
X8
TLLAXAA116P/25JUN-TUE
3
19
A7
TACXTM25JUN/
25JUN19
2
15:02
ITKTS FULFILLMENT
XTM
XTM7168
1
A4G
AA 1161N 28SEP2019 BOSLAX SS/NN 20A
1
25JUN19
ITKTS FULFILLMENT
15:02
XTM
XTM7168
1
A4G
AA 167N 25SEP2019 LAXBOS SS/NN 20F
SIGNATURE LINE
Record Locator
AAA
Agent Create Date Create Time Received From Sabre Purge Date
LTIYPJ
WWW
HDQCRE25JUN2019 15:01
WWW$0A34UM0|01OCT2019
CONFIDENTIAL//For Offical Use Only
6
EFTA00023828

=== Page 8 ===
VCRH* 0012362566941
*
*
HISTORICAL TICKET
*
VIRTUAL COUPON RECORD
0012362566941
NAME-
TTL NBR OF CPNS- 2 DATE OF ISSOE-25J0N19 PNR- PURGED 01OCT19
FF NBR-AA 216FYK8
CPN A/L FLT CLS DATE BRDOFF TIME ST F/B
STAT
AA
167
N
25SEP
LAXBOS 950A OK NVAJZNM3
EXCH
20 AA 1161 N
28SEP
BOSLAX 1243P OK NVAJZNM3
EXCH
FARE USD 286.52 TAX 21.490S TAX 11.20AY TAX 17.40XT
TOTAL USD 336.61
FARE CALC LAX AA BOS143. 26NVAJZNM3 AA LAX143. 26NVAJZNM3 286.
52END ZPLAXBOS XT8.40ZP9.00XFLAX4.5BOS4.5
FCMI-1
FORM OF PAYMENT
EXP-0720 APPROVAL CODE-09888P
DATE OF ISSUE-25JUN19
ISSUED AT-XTMWB XTM 630
ENDORSEMENTS/RESTRICTIONS-
EFTA00023829

=== Page 9 ===
VCRH* 0012376452019
*
* HISTORICAL TICKET
*
VIRTUAL COUPON RECORD
0012376452019
NAME-1
TTL NBR OF CPNS- 2 DATE OF ISSUE-06SEP19 PNR-*PURGED 01OCT19
FF NBR-AA 216FYK8
(
CPN A/L FLT CLS DATE BRDOFF TIME ST F/B
STAT
1 AA 167 V
22SEP
LAXBOS
950A
OK V7AZZNN1
USED
20 AA 2542 G
01OCT
BOSLAX 522P OK GUAHZN01
USED
FARE USD 396.28 TAX 29.72US TAX 11.20AY TAX 17.40XT
TOTAL USD 454.60
FARE CALC LAX AA BOS229. 77V7AZZNN1 AA LAX1 66. 51GUAHZNO1 396.
28END ZPLAXBOS XFLAX4.5BOS4.5
FCMI-1
FORM OF PAYMENT-A/C 317.99
FEE-FEE 200.00
2
EXP-0323 APPROVAL CODE-01210Z
DATE OF ISSUE-06SEP19
ISSUED AT-XTMWX XTM WWA
¥
EFTA00023830

=== Page 10 ===
Record Locator: EQHCVH
American Airlines CONFIDENTIAL for official use only.
Booked: 2019-09-24
PASSENGER INFORMATION
Pax Nbr
Name
1.01
FLIGHT INFORMATION
Seq Nbr
Flight
Class
Date
Dep
Arv
Stat
Qty
Dep Time
Arv Time
2
AA2287
M
27SEP2019
AUS
JFK
HK
1
07:34
12:29
7
B6795
R
29SEP2019
JFK
AUS
HK
1
14:43
17:46
HOTEL INFORMATION
Seq Nbr
Hotel Data
3
HK 27SEP2019 OUT I/SI-/F T-ID-/C/ARR-/DEP-/CD-/CF
4
HK 1 JFK IN 28SEP2019 OUT .NT/DC-////AGT/SI-/FT-/ID-/C/ARR-/DEP-/CD-/C
NON-AIR SEGMENT INFO
Seq Nbr
Non-Air Segment Text
1
OTH 27SEP F GK01 AUS
2
OTH 28SEP J GK01 ZZZ
3
OTH 29SEP S GK01 JFK
4
OTH AA 29OCT T GK01 INFO/THANK YOU FOR CALLING DISNEY GLOBAL TRAVEL
5
OTH 24MAR T GK01 JFK
TICKET INFORMATION
Seq Nbr
Ticket or Time Limit
1
T-A/INVOICED 26SEP
2
TE
-AT
H32I*AJX 0909/25SEP
3
TE
AT
H321*AJX 0911/25SEP
PHONE INFORMATION
Seq Nbr
Phone Number
1
3
ADDRESS INFORMATION
Address
DISNEY GLOBAL TRAVEL
CONFIDENTIAL//For Offical Use Only
1
EFTA00023831

=== Page 11 ===
Record Locator: EQHCVH
PRE REQUESTED SEATS INFO
Sea Nbr Flight Class Seat DepartlArrive Status
Name
1
AA2287
M
27D
AUS
JFK
HK
E-1.01
2
B6795
R
20A
JFK
AUS
KK
E-1.01
OSI INFO
Seq Nbr
OSI
1
OSI AA TL9000 148462
2
OSI AA C148462
3
OSI AA RELEASE TO AMERICAN EXPRESS GBT/H321
4
OSI AA HHL DT 26710 ARR27SEP 24 HR CANCEL REQUIRED
5
OSI AA HHL DT 26710 ARR27SEP GUARANTEED BY CREDIT CARD
6
OSI AA HHL DT 26710 ARR28SEP 24 HR CANCEL REQUIRED
7
OSI AA HHL DT 26710 ARR28SEP GUARANTEED BY CREDIT CARD
8
OSI YY CTCA 312-392-3051 IATA 10588071
9
OSI BA DTID.IN3693US
10
OSI IB DTID.IN3693US
11
OSI YY CMP USDWSSK
12
OSI YY OIN DISNEY
13
OSI YY C148462
14
OSI YY CP/SQA7DNY
15
OSI YY RELEASE TO AMERICAN EXPRESS GBT/H321
SSR
Seq Nbr Type
SSR
1
CLID /C148462A21XDPT
2
CTCE
4
ADTK
PLS TICKET OR CANCEL BY 26SEP19 2359USFL PER GDS
5
ADTK
TTL
6
TKNE
0017459940165C1
7
GRPO
2287M27SEP/CORP NN1
8
CTCE
9
CTCM
10
CTCE
/
11
CTCM
12
DOCS
/DB/02JUL79/F
13
DOCS
/DB/02JUL79/F
REMARKS INFORMATION
Seq Nbr
Remarks
1
1.H-PC/PSGR CLEARED FOR TRAVEL/CORPORATE SECURITY/01
2
2.H-RIPA 05 ADDED EMAIL ADDRESS FROM CTCE DATA 25SEP
PNR HISTORY
Seq
AAA
TTY
Airline or CRS
Nbr
Update Time
Received From
Trans Seq
Code
Agent Sine
Cd
Code
OFFICE
Nbr
History Data
CONFIDENTIAL//For Offical Use Only
2
EFTA00023832

=== Page 12 ===
Record Locator:
EQHCVH
PNR HISTORY
74
27SEP19
15:04
COMPLEAT
K2S9
K2S9*ARC
1
AS
OTH 24MAR T /GK01 JFK
59
26SEP19
GN
16:16
H321
2QXC*API
1
XS
OTH 27SEP F /GK01 AUS
59
2
AS
OTH 27SEP F /GK01 AUS
58
26SEP19
COMPLEAT
15:09
H321
K2S9*ARC
1
X7
TAW2QXC26SEP227/IN
58
2
A7
T-A/INVOICED 26SEP
56
26SEP19
COMPLEAT
15:08
H321
K2S9*ARC
1
AAC
C 057400/DEP/ 0.00/0.00/0.00/ALL/CXXXXXXXXXXXXXXX4 066
26SEP19
55
15:04
COMPLEAT
H321
K2S9*ARC
1
XAS
SSR DOCS AA HK1. /DB/02JUL79/R
55
2
A4S
SSR /E
55
3
A4S
SSR CTCM.AA.HK1.
55
3
A4S
SSR
55
4
A4S
SSR DOCS AA HK1. /DB/02JUL79/F/
55
5
X3S
SSR DOCS B6 HK1./DB/02JUL79/F/
55
6
A3S
SSR DOCS B6 HK1. DB/02JUL79/F
55
7
X7
TAW2QXC26SEP227/MAX-H321
55
8
A7
TAW2QXC26SEP227/IN
54
26SEP19
JINSOL JUNG
15:01
H321
2QXC*ARV
1
X7
T-A/INVOICED 25SEP
54
2
A7
TAW2QXC26SEP227/MAX-H32I
53
26SEP19
GN
14:47
H321
2QXC*ARV
1
AS
OTH 28SEP J /GK01 222
26SEP19
52
GN
14:43
H321
2QXC*ARV
1
XS
OTH 29SEP S /GK01 AUS
52
2
AS
OTH 29SEP S /GK01 AUS
26SEP19
51
14:43
GN
H321
2QXC*ARV
1
AS
OTH 27SEP F /GK01 AUS
47
26SEP19
08:56
KIKIR
H321
2QXC*AKR
1
AS
OTH 27SEP F /GK01 AUS
39
25SEP19
COMPLEAT
16:46
H321
K2S9*ARC
1
X7
TAW2QXC25SEP289/IN
39
2
A7
T-A/INVOICED 25SEP
37
25SEP19
COMPLEAT
16:45
H321
K2S9*ARC
1
AAC
B 057400/DEP/0.00/0.00/0.00/ALL/CXXXXXXXXXXXXXXX4068
25SEP19
36
16:42
COMPLEAT
H321
K2S9*ARC
1
X4S
SSR DOCS AA HK1. /DB/02JUL79/F
36
2
A4S
SSR /B
3
A4S
SSR CTCM.AA.HK1.
36
3
A4S
SSR
36
4
A4S
SSR DOCS AA HK1. DB/02JUL79/F/
36
5
X3S
SSR DOCS B6 HK1. /DB/02JUL79/F/
36
6
A3S
SSR DOCS B6 HK1. /DB/02JUL79/F/
36
7
X7
TAW2QXC25SEP289/MAX-H32I
36
8
A7
TAW2QXC25SEP289/IN
35
25SEP19
16:39
H321
2QXC*AJM
1
X7
T-25SEP-H321"AJX
CONFIDENTIAL//For Offical Use Only
3
EFTA00023833

=== Page 13 ===
Record Locator:
EQHCVH
PNR HISTORY
35
2
A7
TAW2QXC25SEP289/MAX-H32I
25SEP19
34
GN
16:36
H321
2QXC*AJM
1
AS
OTH 29SEP S /GK01 AUS
25SEP19
33
16:35
GN
H321
2QXC*AJM
1
AS
OTH 27SEP F /GK01 AUS
25SEP19
32
RIPA 05 ADDED EMAIL TO PE FIELD FROM
14:23
CTCE
CRC
CRC5DIF
1
A5H
H-RIPA 05 ADDED EMAIL ADDRESS FROM CTCE DATA 25SEP
25SEP19
RIPA 05 ADDED EMAIL TO PE FIELD FROM
32
14:23
CTCE
CRC
CRC5DIF
1
A9
25SEP19
31
13:33
GN
H321
2QXC*ARL
1
AS
OTH 27SEP F /GK01 ZZZ
25SEP19
n
30
GN
H321
13:30
2QXC*ARL
1
AS
OTH 29SEP S /GK01 JFK
26SEP19
28
GN
12:32
H351
2QXC*AIB
1
AS
OTH 27SEP F /GK01 JFK
25SEP19
27
H321
11:11
2QWC*AJX
1
X7
T-25SEP-H321*AJX
27
25SEP19
H321
11:11
2QWC*AJX
1
AAC
B6$7459940166/ .00/230.85/ 31.61/ONE/CXXXXXXXX
27
2
A7
T-25SEP-H321*AJX
25SEP19
26
WWWSRIPACLIENT
CRC
11:10
CRC80D1
1
A4S
SSR 2287M27SEP/CORP NN1
25SEP19
26
11:10
WWWSRIPACLIENT
CRC
CRC80D1
1
A4S
SSR GRPO AA NN1. 2287M27SEP/CORP NN1
25SEP19
25
H321
11:10
2QWC*AJX
1
A4S
SSR TKNE AA HK1. AUSJFK 2287.M 2019-09-27
25SEP19
25
11:10
(H321
2QWC*AJX
1
AAC
AA$7459940165/ 00/264.34/ 34. 13/ONE/CXXXXXXXX
25
2
X7
TAW2QWC25SEP089/SPLIT.2-H321
25
3
A7
T-25SEP-H321*AJX
24
25SEP19
HDQRMB6251555 A84B0FEA-001 SYN
PLT
RM
B6
10:55
1
A4S
25SEP19
24
HDQRMB6251555 A8480FEA-001 SYN
PLT
SSR PLS TICKET OR CANCEL BY 26SEP19 2359USFL PER
10:55
RM
B6
1
A4S
GDS
24
2
A4S
SSR TTL
24
2
A4S
25SEP19
23
COMPLEAT
10:38
H321
K2S9*ARC
1
X4S*
SSR DOCS AA HK1. /DB/02JUL79/F/I
23
25SEP19
COMPLEAT
H321
K2S9*ARC
10:38
1
XS
OTH AA 28OCT M GK/GK01 INFO/THANK YOU FOR CALLING DI
23
2
A4S
SSR CTCE AA HK1.
23
2
AS
OTH
23
3
A4S
SSR
23
3
A4S
SSR CTCM AA HK1.
23
4
A4S
SSR DOCS AA HK1. /DB/02JUL79/F/
/ANNIE/E
23
5
X3S*
SSR DOCS B6 HK1. /DB/02JUL79/F/I
23
6
A3S
SSR DOCS B6 HK1. /DB/02JUL79/F/I
25SEP19
22
H321
2QWC*AJX
1
10:35
X7
TAW2QWC25SEP089/SPU/T.2-PTCA
22
2
A7
TAW2QWC25SEP089/SPLIT.2-H32I
CONFIDENTIAL//For Offical Use Only
4
EFTA00023834

=== Page 14 ===
Record Locator:
EQHCVH
PNR HISTORY
20
25SEP19
10:29
H321
2QWC*AJX
1
X7
T-A/INVOICED 24SEP
20
2
A7
TAW2QWC25SEP089/SPLIT.2-PTCA
25SEP19
19
09:53
H321
2QWC*AJX
1
A4G
AA 2287M 27SEP2019 AUSJFK SS/NN 27D
19
2
A4G
B6 795R 29SEP2019 JFKAUS KK/NN 20A
25SEP19
18
09:52
H321
2QWC*AJX
1
A4S
SSR DOCS AA HK1. /DB/02JUL79/F
18
2
A3S
SSR DOCS B6 HK1. /DB/02JUL79/F
25SEP19
17
09:49
CRC
HDQ8PAY
H-PC/PSGR CLEARED FOR TRAVEL/CORPORATE
1
A5H
SECURITY/01
16
25SEP19
JINSOL JUNG
09:49
H321
2QWC*AJX
1
AS
AA 2287 M 27SEP2019 AUS JFK OK/SS 1 07:34 12:29
16
2
AS
B6 795 R 29SEP2019 JFK AUS SS/SS 1 14:43 17:46
15
25SEP19
JINSOL JUNG
09:44
H321
2QWC*AJX
1
AS
HHL 28SEP2019 SS/HK1 JFK
25SEP19
15
09:44
JINSOLJUNG
H321
2QWC*AJX
1
A4O
OSI AA HHL DT 26710 ARR28SEP 24 HR CANCEL REQUIRED
15
2
A40
OSI AA HHL DT 26710 ARR28SEP GUARANTEED BY CREDIT
CARD
10
24SEP19
COMPLEAT
15:34
H321
K2S9*ARC
1
X7
TAW2QXC24SEP159/IN
10
2
A7
T-A/INVOICED 24SEP
24SEP19
8
COMPLEAT
15:33
H321
K2S9*ARC
1
AAC
A 055999/DEP/ 0.00/0.00/0.00/ALL/CXXXXXXXXXXXXXXX4068
24SEP19
7
15:29
COMPLEAT
H321
K2S9*ARC
1
X7
TAW2QXC24SEP159/MAX-H32I
7
2
A7
TAW2QXC24SEP15@/IN
24SEP19
6
15:27
H321
2YWC*ATK
1
X7
TAW2QXC24SEP159/MAX-PTCA
6
2
A7
TAW2QXC24SEP159/MAX-H32I
24SEP19
5
15:05
COMPLEAT
H321
K2S9*ARC
1
AS
OTH AA 28OCT M GK/GK01 INFO/THANK YOU FOR CALLING DI
24SEP19
4
MARIA
- 12124562745 /GISELA
15:03
PEREZ ROP
H321
2QXC*AGP
1
X7
TAWH32I24SEP009/
4
2
A7
TAW2QXC24SEP159/MAX-PTCA
24SEP19
3
15:02
H321
2QXC*AGP
1
A7
TAWH32124SEP009/
1
24SEP19
MARIA
- 12124562745 /GISELA
14:56
PEREZ
H321
2QXC*AGP
1
A9
PH
24SEP19
MARIA
1
- 12124562745 /GISELA
14:56
PEREZ
H321
2QXC*AGP
1
A30
OSI YY CTCA 312-392-3051 IATA 10588071
1
2
A9
R
1
2
A30
OSI BA DTID IN3693US
1
3
A9
PHX
BABETTE ROMAINE
1
3
A30
OSI IBDTID IN3693US
1
4
A9
PHX
JINGOL
1
4
A30
OSI YY CMP USDWSSK
1
5
AW
1
5
A9
PHX
CONFIDENTIAL//For Offical Use Only
5
EFTA00023835

=== Page 15 ===
Record Locator: EQHCVH
PNR HISTORY
1
5
A30
OSI YY OIN DISNEY
1
6
A
1
6
A3O
OSI YY C148462
1
7
A4S
SSR /C148462A21XDPT
1
7
A4S
SSR CLID YY NN1. /C148462A21XDPT
1
7
A3O
OSI YY CP/SQA7DNY
1
8
A30
OSI YY RELEASE TO AMERICAN EXPRESS GBT/H321
1
8
AS
HHL 27SEP2019 SS/HK1 JFK
1
9
A40
OSI AA TL9000 148462
1
10
A40
OSI AA C148462
1
11
A4O
OSI AA RELEASE TO AMERICAN EXPRESS GBT/H321
1
12
A40
OSI AA HHL DT 26710 ARR27SEP 24 HR CANCEL REQUIRED
1
13
A40
OSI AA HHL DT 26710 ARR27SEP GUARANTEED BY CREDIT
CARD
AGENCY ACCOUNTING LINE INFO
Seq Nbr
Agency Accounting Line
1
C 057400/DEP/ 0.00/0.00/0.00/ALL/CXXXXXXXXXXXXXXX4068/1-PY-26SEP
SIGNATURE LINE
Record Locator
AAA
Agent
Create Date Create Time
Received From
Sabre Purge Date
EQHCVH
H321
2QXCAGP
24SEP2019
14:56
/GISELA PEREZ 24MAR2020
CONFIDENTIAL//For Offical Use Only
6
EFTA00023836

=== Page 16 ===
VCRH
b<<
*
*
* HISTORICAL TICKET
*
*
*
VIRTUAL COUPON RECORD
NAME-
TTL NBR OF CPNS- 1 DATE OF ISSUE-25SEP19 PNR-EQHCVH 24SEP19
CPN A/L FLT CLS DATE BRDOFF TIME ST F/B
STAT
1 AA 2287 M
27SEP AUSJFK 734A OK MOAJZNN1/21XD USED
FARE USD 264.34 TAX 19.83US TAX 4.20ZP TAX 10.10XT
TOTAL USD 298.47
FARE CALC AUS AA NYC264.34USD264.34END ZPAUS XT5.60AY 4.50XFA
US4.5
FCMI-6
FORM OF PAYMENT
EXP-0221 APPROVAL CODE-087357
DATE OF ISSUE-25SEP19
ISSUED AT-PHX
H32I AJX
ARC/IATA NBR-10588071
ENDORSEMENTS/RESTRICTIONS-
NONREF/SVCCHGPLUSFAREDIF/CXL BONLY
¥
EFTA00023837

=== Page 17 ===
Record Locator: SFHNLX
American Airlines CONFIDENTIAL for official use only.
Booked: 2019-06-20
PASSENGER INFORMATION
Pax Nbr
Name
1.01
2.01
GROVER/JONATHAN
FLIGHT INFORMATION
Seq Nbr Flight Class
Date
Dep
Arv
Stat/Qty Dep Time|Arv Time
1
AA1453
Y
20JUL2019
BOS
CLT
AF
2
18:57
21:31
2
AA810
Y
20JUL2019
CLT
AUS
AF
2
22:29
00:12
TICKET INFORMATION
Seq Nbr
Ticket or Time Limit
1
T-20JUN-XTM726Z
2
TE 0012361555203
TM7EA0 0946/20JUN 18*77E705
3
TE 0012361555204 GROVE/J XTM7EA0 0947/20JUN 1B*77E705
4
TK 0010650749255
TM726Z 0952/20JUN AE 18*7BE52E
5
TK 0010650749256 GROVE/J XTM726Z 0952/20JUN - AE 1B*7BE52E
PHONE INFORMATION
Seq Nbr
1
2
ADDRESS INFORMATION
Address
REQUENT FLYER INFO
Frequent Traveler
AA 84PTP50 HKAA 1.01
ADV
2
AA 9HROL08 HK AA 2.01 GROVER/JONATHAN ADV*
PRE REQUESTED SEATS INFO
Seq Nbr
Flight
Class
Seat
Depart/Arrive
Status
Name
1
AA1453
Y
18E
BOS
CLT
HK
E-1.01
2
AA1453
Y
18F
BOS
CLT
HK
GROVER/JONATHAN-2.01
3
AA810
Y
18D
CLT
AUS
HK
E-1.01
4
AA810
Y
18E
CLT
AUS
HK
GROVER/JONATHAN-2.01
OSI INFO
Seq Nbr
OSI
CONFIDENTIAL//For Offical Use Only
1
EFTA00023838

=== Page 18 ===
Record Locator: SFHNLX
OSI INFO
1
OSI PURCHASED ON AA.COM US 06/20/2019 IN US CURRENCY
2
OSI YY AAAD Y30AUD/AVQ02
SSR
Seq Nbr
Type
SSR
1
DOCA|/R/US//TX
2
DOCS/DB/02JUL1979
3
DOCA
/R/US//TX
4
DOCS/DB/05SEP1979/M/GROVER/JONATHAN
5
DOCO//R/5125415385
6
CCRD /CBAV NN1
7
GRPO
810Y20JUL/PREM CC NN2
8
GRPO
810Y20JUL/PREM CC NN2
9
GRPO
1453Y20JUL/PREM CC NN2
10
GRPO
1453Y20JUL/PREM CC NN2
REMARKS INFORMATION
Seq Nbr
Remarks
1
1.TBMXX-AWC
2
2.H-TBMEDIT/RSAPPP15 EDITOR SESSION 33
3
3.H-/TSCERT-0010560787926$N1.1
4
4.H-/T$CERT-0010560787930$N2.1
5
5.H-/TSAWC$AWD$Y30AUD$S1/2$BOSAUS$84PTP50
6
6.H-/TSTBMTIK546616XXXXXX1829$04/23
7
7.H-/T
8
8.H-/T$DOCSVCR
9
9.H-/T$DLV$EMAI
10
10.H-/TSFEESPSEAT$18E$N1.1$S1$15.63/1.17SUSD
11
11.H-/TSFEE$PSEAT318F$N2.1$S1$22.34/1.68SUSD
12
12.H-/T$CCBC US
13
13.H-/T$WWW EAU
14
14.H-WWW/AUTH/CID IK1829 BANK VERIFIED CID
15
15.H-IPPADDR70.123.13.38$
16
16.H-TRANP 745877A4-9347-498F-9554-DAB3EFB3E440
17
17.H-PTI1.1-ADT-FFY
18
18.H-PT12.1-ADT-FFY
19
19.H-BOOKED VIA AMERICAN AIRLINES WEB SITE US IN US CURRENCY
20
20.H-IPHADDR70.123.13.38$
21
21.H-TRANH F6FFAF3D-5A10-40B1-A097-533D0B04D6E4
22
22.H-Y30AUD AA/US 1 ECONOMY CLASS TICKET
23
23.H-ONE-WAY FLEX AANYTIME LEVEL 2 AWARD
24
24.H-WITHIN THE 48 U.S.
25
25.H-FOR VALID DATES SEE /N.AAD DATES/
26
26.H-TKT DESIGN AVQ02
27
27.H-ACCT CODE.. AWARD
28
28.H-/TSMULTIPLESSFHNLX$2
29
29.CHECK COMPLETE
30
30.H-/T$PCC
CONFIDENTIAL//For Offical Use Only
2
EFTA00023839

=== Page 19 ===
Record Locator:
SFHNLX
REMARKS INFORMATION
31
31.H-/TSMULTIPLESSFHNLXS2
32
32.H-AUTH/CID IK1829-XTMEA0
33
33.H-CERT-0560787926/2902 TKT DESIG AVQ02
34
34.XXAUTH/34001P
35
35.XXTAAXTM20JUN/
36
36.H-CERT-0560787930/2903 TKT DESIG- AVQ02
37
37.XXTAAXTM20JUN/
38
38.H-01 AE PREFERRED SEATS USD 16.80
39
39.H-0012361555203
40
40.H-01 AE -PREFERRED SEATS USD 24.02
41
41.H-0012361555204
42
42.H-/T$TBMEDIT/EMAIL SENT 0953/20JUN/TDS
43
43.H-PC/PSGR CLEARED FOR TRAVEL/CORPORATE SECURITY/01
44
44.BAG-TAG ACCEPTED 224029 20JUL2019 1639/BOS/8MSG
45
45.BAG-TAG ACCEPTED 224030 20JUL2019 1639/BOS/8MSG
46
46.BAG-SELFTAG 224029'D ACTIVATED BY 584966 20JUL2019 1639/BOS
47
47.BAG-SELFTAG 224030 D ACTIVATED BY 584966 20JUL2019 1639/BOS
BAGGAGE INFO
Seq Nbr/Bag Routing FlightBag Destination
Bag Psgr Name
Bag Tag NumberBag Checkin Agent|Bag Checkin LCL Date
Bag Checkin LCL Time
1
AA1453
CLT
AA224029
BOS 5SMD
2019-07-20
05:36 PM
1
AA1453
CLT
GROVER/JONATHAN
AA224030
BOS 5SMD
2019-07-20
05:36 PM
1
AA810
AUS
AA224029
BOS 5SMD
2019-07-20
05:36 PM
1
AA810
AUS
GROVER/JONATHAN
AA224030
BOS 5SMD
2019-07-20
05:36 PM
PNR HISTORY
Seq
AAA
Received From
Agent
TTY
Airline or CRS
Update Time
Trans Seq
Code
Nbr
Code
Sine
OFFICE
Cd
Nbr
History Data
19
20JUL19
PDCAACLT
CLT
CLT5PD
1
SC
AA 810 Y 20JUL2019 CLT AUS HK/AF 2 22:29 00:12
21:55
20JUL19
PREFERRED SEATS/FL1 /AA1453Y20JUL2019BOSCLT-
18
PDCAABOS
BOS
BOS5PD
1
UAX
18:11
PREFERRED SEATS/FL2 /AA1453Y20JUL2019BOSCLT-
18
2
UAX
GROVER/JONA
18
3
SC
AA 1453 Y 20JUL2019 BOS CLT HK/AF 2 18:57 21:31
17JUL19
12
SCC UPDATE
CRC
17:02
HDQ8PAY
1
A5H
H-PC/PSGR CLEARED FOR TRAVEL/CORPORATE SECURITY/01
20JUN19
11
TDSEDI
TOR/1233/20JUN/SFV
XTM
XTM7SFV
1
A5H
H-TBMEDIT/RSAPPP15 EDITOR SESSION 33
12:33
20JUN19
10
TDSEMAILEDIT/0953/20JUN/TDS
XTM
XTM7UEB
1
A5H
H-/TSTBMEDIT/EMAIL SENT 0953/20JUN/TDS
09:53
20JUN19
9
09:52
ITKTS FULFILLMENT
XTM
XTM726Z
1
X5H
H-TBMEDIT/TKT DRIVEN FOR 5.60/0946/20JUN
9
2
X5H
H-TBMEDIT/TKT DRIVEN FOR 5.60/0947/20JUN
9
3
X5H
H-TBMEDIT/ALL PQS DELETED AND PLACED INTO HISTORY
9
4
A5H
H-01 AE -PREFERRED SEATS USD 16.80
9
5
A5H
H-0012361555203
9
6
A5H
H-01 AE -PREFERRED SEATS USD 24.02
9
7
A5H
H-0012361555204
CONFIDENTIAL//For Offical Use Only
3
EFTA00023840

=== Page 20 ===
Record Locator: SFHNLX
PNR HISTORY
9
8
X7
T-20JUN-XTM7EA0
9
9
A7
T-20JUN-XTM726Z
9
10
UAX
SEATS/HI1 /AA1453Y20JUL2019BOSCLT-
9
11
UAX
PREFERRED SEATS/HI2 /AA1453Y20JUL2019BOSCLT-
GROVER/JONA
20JUN19
8
EDITOR EDITOR E051619-49 ADVANTAGE
09:47
WEB
XTM
XTM7EA0
1
X5H
H-TBMEDIT/RSAPPP17 EDITOR SESSION 7
8
2
A5H
H-TBMEDIT/ALL PQS DELETED AND PLACED INTO HISTORY
8
3
A5H
H-TBMEDIT/TKT DRIVEN FOR 5.60/0947/20JUN
B
4
A5H
H-TBMEDIT/TKT DRIVEN FOR 5.60/0946/20JUN
8
5
A5H
H-/T$CERT-0010560787926$N1.1
8
6
A5H
H-/T$CERT-0010560787930$N2.1
8
7
A5H
H-/T$PCC
8
8
A5H
H-/T$MULTTPLESSFHNLXS2
8
9
A5H
H-AUTH/CID IK1829-XTMEA0
8
10
A5H
H-CERT-0560787926/2902 TKT DESIG AVQ02
8
11
A5H
H-CERT-0560787930/2903 TKT DESIG AVQ02
8
12
X7
TAAXTM20JUN/
8
13
A7
T-20JUN-XTM7EA0
7
20JUN19
TDSEDITOR/0940/20JUN/FDP
09:40
XTM
XTM7FOP
1
A6H
H-TBMEDIT/RSAPPP17 EDITOR SESSION 7
7
2
A5H
H-/TSMULTIPLESSFHNLX$2
20JUN19
6
WWWS84PTP50
www
09:22
HDQ2EAV
1
A4O
OSI PURCHASED ON AA.COM US 06/20/2019 IN US CURRENCY
6
6
AW
78721
6
7
A5F
-TBMXX-AWC
6
8
A5H
H-/T$AWCSAWD$Y30AUD$S1/2$BOSAUS$84PTP50
6
9
A5H
H-/TSTBMTK546616XXXXXXX1829$04/23
6
10
A5H
H-/T
6
11
A5H
H-/T$DOCSVCR
6
12
A5H
H-/T$DLV$EMAIL
600/00/00
6
13
A5H
H-/T$FEESPSEAT$18E$N1.1$S1$15.63/1.17$USD
6
14
A5H
H-/T$FEESPSEAT$18F$N2.1SS1$22.34/1.68SUSD
6
15
A5H
H-/T$CCBC US
6
16
A5H
H-/TSWWW EAU
6
17
A5H
H-WWW/AUTH/CID IK1829 BANK VERIFIED CID
6
18
A5H
H-IPPADDR70.123.13.38$
6
19
A5H
H-TRANP 745877A4-9347-498F-9554-DAB3EFB3E440
6
20
XB
TLBOSAA1159P/25JUN-TUE
6
21
A7
TAAXTM20JUN/
20JUN19
5
08:37
WWWSGUEST
WWW
WWW2777
1
XB
TLBOSAA950A/20JUN-THU
5
2
A8
LBOSAA1159P/25JUN-TUE
4
20JUN19
ITKTS
FULFILLMENT
08:37
XTM
XTM7168
1
A4G
AA 810Y 20JUL2019 CLTAUS SS/NN 18D
4
2
A4G
AA 810Y 20JUL2019 CLTAUS SS/NN 18E
CONFIDENTIAL//For Offical Use Only
4
EFTA00023841

=== Page 21 ===
Record Locator:
SFHNLX
PNR HISTORY
20JUN19
3
08:37
ITKTS FULFILLMENT
XTM
XTM7168
1
A4G
AA 1453Y 20JUL2019 BOSCLT SS/NN 18E
3
2
A4G
AA 1453Y 20JUL2019 BOSCLT SS/NN 18F
3
PREFERRED SEATS/HD1 /AA1453Y20JUL2019BOSCLT
3
UAX
3
4
UAX
PREFERRED SEATS/HD2 /AA1453Y20JUL2019BOSCLT-
GROVER/JONA
20JUN19
2
08:37
ITKTS FULFILLMENT
XTM
XTM7168
1
AAX
PREFERRED SEATS/HD1 15.63USD/1.17US/16.80USD/PTC-ADT/G
2
2
AAX
PREFERRED SEATS/HD2 22.34USD/1.68US/24.02USD/PTC-ADT/G
20JUN19
1
08:35
WWWSRIPACLIENT
CRC
CRC80D1
1
A4S
1
20JUN19
08:35
WWWSRIPACLIENT
CRC
CRC80D1
1
A4S
SSR /CBAV NN1
1
2
A4S
SSR GRPO AA NN2. 810Y20JUL/PREM CC NN2
1
2
A4S
SSR 810Y 20JUL/PREM CC NN2
1
3
A4S
SSR 810Y20JUL/PREM CC NN2
1
3
A4S
SSR GRPO AA NN2. 810Y20JUL/PREM CC NN2
1
4
A4S
SSR 1453Y20JUL/PREM CC NN2
1
4
A4S
SSR GRPO AA NN2. 1453Y20JUL/PREM CC NN2
1
5
A4S
SSR 1453Y20JUL/PREM CC NN2
1
5
A4S
SSR GRPO AA NN2. 1453Y20JUL/PREM CC NN2
SIGNATURE LINE
Record Locator
AAA
Agent
Create Date
Create Time
Received From
Sabre Purge Date
SFHNLX
www
HDQEAV
20JUN2019
08:35
WWW$84PTP50
20JUL2019
CONFIDENTIAL//For Offical Use Only
5
EFTA00023842

=== Page 22 ===
VCR
*
*
* HISTORICAL TICKET
*
*
*
VIRTUAL COUPON RECORD
NAME-
TTL NBR OF CPNS- 2 DATE OF ISSUE-20JUN19 PNR-*PURGED 20JUL19
FF NBR-AA 84PTP50
CC
CPN A/L FLT CLS DATE BRDOFF TIME ST F/B
STAT
1 AA 1453 Y
20JUL
BOSCLT 657P OK Y30AUD/AVQ02 USED
2X AA 810 Y
20JUL
CLTAUS 1029P OK Y30AUD/AVQ02 USED
FARE USD 0.00 TAX 5.60AY TOTAL USD 5.60
FARE CALC BOS AA X/CLT AA AUSO.00Y30AUD/AVQO2 0.00END
FCMI-1
FORM OF PAYMENT
EXP-0423 APPROVAL CODE-33223P
DATE OF ISSUE-20JUN19
ISSUED AT-XTMWB XTM EAO
CERT-
ENDORSEMENTS/RESTRICTIONS-
VALID ON AA/US ONLY/VOID IF SLD/PURCSD/BRTR
¥
EFTA00023843

=== Page 23 ===
Record Locator: UMVDLY
American Airlines CONFIDENTIAL for official use only.
Booked: 2019-06-20
PASSENGER INFORMATION
Pax Nbr
Name
1.01
FLIGHT INFORMATION
Seq Nbr
Flight
Class
Date
Dep
Arv
Stat
Qty
Dep Time
Arv Time
1
AA1176
B
06JUL2019
AUS
DFWHK
1
08:43
09:54
2
AA3340
B
06JUL2019
DFW
LIT
HK
1
10:35
11:57
3
AA3458
B
08JUL2019
IT
DFW
HK
1
18:26
19:45
4
AA1435
B
08JUL2019
DFW
(AUS
HK
1
20:36
21:33
TICKET INFORMATION
Seq Nbr,
Ticket or Time Limit
1
T-20JUN-XTM7CCS
2
TE 0012361653448
XIM/CCS 1649/20JUN 18*77E711
PHONE INFORMATION
Seq Nbr
Phone Number
1
OPT
2
1-512-541-5385-POPT
3
4
5
ADDRESS INFORMATION
Address
JULIE KNIPE BROWN
PRE REQUESTED SEATS INFO
Seq
Nbr
Flight
Class
Seat
Depart/Arrive
Status
Name
1
AA1176
B
218
AUS
DFW
HK
-1.01
2
AA3340
B
11A
DFW
LIT
HK
-1.01
3
AA3458
B
19F
LIT
DFW
HK
-1.01
4
AA1435
B
13B
DFW
AUS
HK
-1.01
OSI INFO
Seq Nbr
OSI
11
OSI PURCHASED ON AA. COM US 06/20/2019 IN US CURRENCY
SSR
Seq Nbr Type
SSR
CONFIDENTIAL//For Offical Use Only
EFTA00023844

=== Page 24 ===
Record Locator: UMVDLY
SSR
1
DOCA/R/US///TX
2
DOCS
/DB/02JUL1979/
3
BESH
3458B8JUL/NN1
4
BESH
1435B8JUL/NN1
5
BESH
1176B6JUL/NN1
6
BESH
3340B6JUL/NN1
7
DBSS
AA1435DDFWAUS201907090136AUCB201907090233LITAUS201907082256 NN1
REMARKS INFORMATION
Seq Nbr
Remarks
1
1.TBM*BA402451XXXXXX8619S09/19
2
2.H-TBMEDIT/ALL PQS DELETED AND PLACED INTO HISTORY
3
3.H-TBMEDIT/TKT DRIVEN FOR 440.01/1649/20JUN
4
4.JULIE KNIPE BROWN
5
5.H-/T$DOC$VCR
6
6.H-/T$DLV$
7
7.H-/T$BE$BENE
8
8.H-/T$CCBC US
9
9.H-/T$WWWW EAU
10
10.H-/T$3RD PARTY$15 DAYS OUT
11
11.H-WWW/AUTH/CID BA8619 BANK VERIFIED CID
12
12.H-IPPAD
13
13.H-TRANP 5941E454-D0D5-4B31-A6E6-952A25AFEE4F
14
14.H-PT11.1-ADT-ADT
15
15.H-BOOKED VIAAMERICAN AIRLINES WEB SITE US IN US CURRENCY
16
16.H-IPHADDR166.108.243.253$
17
17.H-TRANH 5941E454-D0D5-4B31-A6E6-952A25AFEE4F
18
18.H-GOOGLE/US
19
19.H-TBMUSD377.72 BASE AMT PLUS SECURITY PER ADT/1643/20JUN
20
20.H-AUTH/APV-012851/BA8619/20JUN
21
21.H-AUTH/CSC NOT SUPPLIED
22
22.H-AUTH/AVS-Z/ZIP/POSTAL MATCH / ADDRESS FAIL
23
23.XXAUTH/012851 /TB9$09
24
24.XXTACXTM20JUN/
25
25.H-/T$TBMEDIT/EMAIL SENT 1654/20JUN/TDS
26
26.H-PC/PSGR CLEARED FOR TRAVEL/CORPORATE SECURITY/01
27
27.H-/OSOS08JUL20
28
28.H-/OSO$DLY$DOM$08JUL
29
29.H-/OSO$08JUL18
30
30.H-/OSO$DLY$DOM$08JUL
PNR HISTORY
Seq
Update Time
Received From
AAA
Agent
TTY
Airline or CRS
Trans Seq
Nbr
Code
Sine
Code
OFFICE
Cd.
Nbr
History Data
08JUL19
11
16:14
REAACCOM UPDATE
CRC
CRC8YMG
1
A5H
H-/OSO$08JUL18
11
2
A5H
H-/OSO$DLYSDOM508JUL
CONFIDENTIAL//ForOffica Use Only
2
EFTA00023845

=== Page 25 ===
Record Locator: UMVDLY
PNR HISTORY
08JUL19
10
14:27
REAACCOM UPDATE
CRC
CRCBYMG
1
A5H
H-/OSO$08JUL20
10
2
A5H
H-/OSO$DLY$DOMS08JUL
08JUL19
9
00:37
WWWSDBAPRSS
HDQ
HDQ5FY1
1
A4S
08JUL19
9
WWWS
DBAPRSS
HDQ
00:37
HDQ5FY1
SSR
1
A4S
/AA1435DDFWAUS201907090136AUCB201907090233LITAUS201
07JUL19
8
CKI
21:40
1
A4G
AA 3458B 08JUL2019 LITDFW SS/NN 19F
8
2
A4G
AA 1435B 08JUL2019 DFWAUS SS/NN 13B
05JUL19
7
20:53
CKI
1
A4G
AA 1176B 06JUL2019 AUSDFW SS/NN 21B
7
2
A4G
AA 3340B 06JUL2019 DFWLIT SS/NN 11A
05JUL19
6
WWWSGUEST
20:51
www
WWW5777
1
A9
6
2
A9
WWW
6
3
A9
WWW
5
03JUL19
SCC UPDATE
CRC
HDQ8PAY
1
A5H
H-PC/PSGR CLEARED FOR TRAVEL/CORPORATE SECURITY/01
07:46
4
20JUN19
TDSEMAILEDIT/1654/20JUN/TDS
XTM
XTM7EXW
1
A5H
H-/T$TBMEDIT/EMAIL SENT 1654/20JUN/TDS
16:54
20JUN19
3
WWW$RIPACLIENT
16:49
CRC
CRC80D1
1
A4S
SSR BESH AA NN1. 3458B8JUL/NN1
20JUN19
3
WWW$RIPACLIENT
CRC
CRC80D1
T
A4S
SSR 3458B8JUL/NN1
16:49
3
2
A4S
SSR BESH AA NN1. 1435B8JUL/NN1
3
2
A4S
SSR 1435B8JUL/NN1
3
3
A4S
SSR 1176B6JUL/NN1
3
3
A4S
SSR BESH AA NN1. 1176B6JUL/NN1
3
4
A4S
SSR 3340B6JUL/NN1
3
4
A4S
SSR BESH AA NN1. 3340B6JUL/NN1
2
20JUN19
EDITOR EDITOR E051619-49 CC WEB NON
XTM
XTM7CCS
1
A5H
H-TBMEDIT/ALL PQS DELETED AND PLACED INTO HISTORY
16:49
RUSH
2
2
A5H
H-TBMEDIT/TKT DRIVEN FOR 440.01/1649/20JUN
2
3
A5H
H-AUTH/APV-012851/BA8619/20JUN
2
4
A5H
H-AUTH/CSC NOT SUPPLIED
2
5
A5H
H-AUTH/AVS-Z/ZIP/POSTAL MATCH /ADDRESS FAIL
2
6
X7
TACXTM20JUN/
2
7
A7
T-20JUN-XTM7CCS
20JUN19
1
WWWSGUEST
www
HDQ2EAU
1
A40
OSI PURCHASED ON AA.COM US 06/20/2019 IN US CURRENCY
16:43
JULIEKNIPE BROWN
1
6
AW
331
1
7
A5F
TBM*BA402451XXXXXXB619$09/19
1
B
A5F
-JULIE KNIPE BROWN
1
9
A5H
H-/T$DOCSVCR
1
10
A5H
1
11
A5H
H-/T$BE$BENE
1
12
A5H
H-/T$CCBC US
CONFIDENTIAL//For Offical Use Only
3
EFTA00023846

=== Page 26 ===
Record Locator: UMVDLY
PNR HISTORY
1
13
A5H
H-/TSWWW EAU
1
14
A5H
H-/T$3RD PARTY$15 DAYS OUT
1
15
A5H
H-WWW/AUTH/CID BA8619 BANK VERIFIED CID
1
16
A5H
H-IPPAD
1
17
A5H
H-TRANP 5941E454-D0D5-4B31-A6E6-952A25AFEE4F
1
18
A5H
H-TBMUSD377.72 BASE AMT PLUS SECURITY PER ADT/1643/20JU
1
19
XB
TLAUSAA455P/20JUN-THU
1
20
A7
TACXTM20JUN/
SIGNATURE LINE
Record Locator
AAA
Agent Create Date Create Time Received From Sabre Purge Date
UMVDLY
www HDQCRE 20JUN2019 16:40
WWWSGUEST
08JUL2019
CONFIDENTIAL//For Offical Use Only
4
EFTA00023847

=== Page 27 ===
*
* HISTORICAL TICKET
*
*
*
VIRTUAL COUPON RECORD
NAME-
TTL NBR OF CPNS- 4 DATE OF ISSUE-20J0N19 PNR-*PURGED 08JUL19
CC-
CPN A/L FLT CLS DATE BRDOFF TIME ST F/B
STAT
1 AA 1176 B 06JUL AUSDEW 843A OK SUAIZNBI
USED
2X AA 3340 B
06JUL
DFWLIT 1035A OK SUAIZNB1
USED
30 AA 3458 B
08JUL
LITDFW 626P OK SUAIZNB1
USED
4X AA 1435 B
08JUL
DFWAUS 836P OK SUAIZNB1
USED
FARE USD 366.52 TAX 27.49US TAX 11.20AY TAX 34.80XT
TOTAL USD 440.01
FARE CALC AUS AA X/DFW AA LIT183.26SUAIZNB1 AA X/DFW AA AUS1
83.26SUAIZNB1 366.52END ZPAUSDFWLITDFW XT16.80ZP18.
00XFAUS4.5DFW4.5LIT4.5DFW4.5
FCMI-1
FORM OF PAYMENT
FOP-
EXP-0919 APPROVAL CODE-012851¥
EFTA00023848

=== Page 28 ===
Record Locator: DCFDTC
American Airlines CONFIDENTIAL for official use only.
Booked: 2019-08-01
PASSENGER INFORMATION
Pax Nbr
Name
1.01
MAXWELL/GHISLAINE
FLIGHT INFORMATION
Seq Nbr
Flight
Class
Date
Dep
Arv
StatiQty
Dep
TimelAry Time
1
AA814
S
04AUG2019
LAX
PHL
HK
1
06:00
14:20
2
AA5003
S
04AUG2019
PHLMHT
HK
1
16:10
17:41
TICKET INFORMATION
Seq Nbr
Ticket or Time Limit
1
T-01AUG-XTM7U72
2
TE 0012369671898 MAXWE/G XTM7CCY 2052/01AUG 1B*AA650A
3
TK 0010653592355 MAXWE/G XTM7U72 2055/01AUG AE 1B*7BE52E
PHONE INFORMATION
Seq Nbr
Phone Number
1
2
3
ADDRESS INF ORMATION
Address
GHISLAINE MAXWELL
A
IA
02114
PRE REQUESTED SEATS INFO
Seq Nbr Flight
Class
Seat
Depart|Arrive
Status
Name
1
AA814
S
11A
LAX
PHL
HK
MAXWELL/GHISLAINE-1.01
2
AA5003
S
12A
PHL
MHT
HK
MAXWELL/GHISLAINE-1.01
OSI INFO
Seq Nbr
OSI
1
OSI PURCHASED ON AA.COM US 08/01/2019 IN US CURRENCY
SSR
Seq Nbr Type
SSR
1
DOCA
/R/US///FL
2
DOCS
/DB/25DEC1961/F/MAXWELL/GHISLAINE
CONFIDENT IAL//For Offical Use Only
1
EFTA00023849

=== Page 29 ===
Record Locator: DCFDTC
SSR
3
GRPO5003S4AUG/NN1
REMARKS INFORMATION
Seq Nbr
Remarks
1
1.TBM*AX376792XXXXX8004$ 12/22
2
2.GHISLAINE MAXWELL
3
3.H-/T$DOCSVCR
4
4.H
5
5.H-/TSFEE$PSEAT$11A$N1.1$S1$39.09/2.93$USD
6
8.H-/TSFEE$PSEAT$12A$N1.1$S2$57.50/5.06$USD
7
7.H-/TSCCBC US
8
8.H-/TSWWWW EAU
9
9.H-WWW/AUTH/CIDAX
10
10.H-PSGR QUALIFIED FOR EXIT SEATING
11
11.H-IPPADDR99.48.181.171$
12
12.H-TRANP 0AC36F7B-FA1B-4515-8394-F1ABC4456FBD
13
13.H-PTI1.1-ADT-ADT
14
14.H-BOOKED VIA AMERICAN AIRLINES WEB SITE US IN US CURRENCY
15
15.H-IPHADDR99.48.181.171$
16
16.H-TRANH 0AC36F7B-FA1B-4515-8394-F1ABC4456FBD
17
17.H-PC/PSGR CLEARED FOR TRAVEL/CORPORATE SECURITY/01
18
18.H-TBMUSD255.83 BASE AMT PLUS SECURITY PER ADT/2043/01AUG
19
19.XXAUTH/169641 /TB$12/
20
20.XXTACXTM01AUG/
21
21.H-01 AE -PREFERRED SEATS USD 114.58
22
22.
23
23.H-/T$TBMEDIT/EMAIL SENT 2057/01AUG/TDS
PNR HISTORY
Seq
Update Time
Received From
AAA
Agent
TTY
Airline or CRS
Trans Seq
Nbr
Code
Code
Sine
OFFICE
Cd
Nbr
History Data
04AUG19
11
PDCAAPHL500304AUG
PHL
PHL5PD
MAIN CABIN EXTRA/FL1 /AA5003S04AUG2019PHLMHT-
15:41
1
UAX
MAXWELL/GH
10
04AUG19
PDCAALAX081404AUG
08:14
LAX
LAX5PD
1
UAX
PREFERRED SEATS/FL1 /AA0814S04AUG2019LAXPHL-
MAXWELL/GHI
03AUG19
9
10:11
WWW$GUEST
www
WWW5777
1
A9
9
2
A9
WWW
9
3
A9
WWW
8
01AUG19
20:57
TDSEMAILEDIT/2057/01AUG/TDS
XTM
XTM7UVR
1
A5H
H-/T$TBMEDIT/EMAIL SENT 2057/01AUG/TDS
7
01AUG19
ITKTS FULFILLMENT
20:55
XTM
XTM7U72
1
X5H
H-TBMEDIT/TKT DRIVEN FOR 292.00/2052/01AUG
7
2
X5H
H-TBMEDIT/ALL PQS DELETED AND PLACED INTO HISTORY
7
3
X5H
H-TBMEDIT/AE FOUND
7
4
A5H
H-01 AE PREFERRED SEATS USD 114.58
7
5
A5H
H
7
6
A4S
SSR 5003S4AUG/NN1
7
6
A4S
SSR GRPO AA NN1. 5003S4AUG/NN1
CONFIDENTIAL//For Offical Use Only
2
EFTA00023850

=== Page 30 ===
Record Locator: DCFDTC
PNR HISTORY
7
7
X7
T-01AUG-XTM7CCY
7
8
A7
T-01AUG-XTM7U72
7
9
UAX
PREFERRED SEATS/HI1 /AA0814S04AUG2019LAXPHL-
MAXWELL/GHI
7
10
UAX
MAIN CABIN EXTRA/HI1 /AA5003S04AUG2019PHLMHT-
MAXWELL/GH
01AUG19
EDITOR EDITOR E051619-49 CC WEB
6
20:52
RUSH
XTM
XTM7CCY
1
A5H
H-TBMEDIT/AE FOUND
6
2
A5H
H-TBMEDIT/ALL PQS DELETED AND PLACED INTO HISTORY
6
3
A5H
H-TBMEDIT/TKT DRIVEN FOR 292.00/2052/01AUG
6
4
X7
TACXTM01AUG/
6
5
A7
T-01AUG-XTM7CCY
01AUG19
5
20:43
WWWSGUEST
WWW
HDQ2EAU
1
A4O
OSI PURCHASED ON AA COM US 08/01/2019 IN US CURRENCY
GHISLAINE MAXWELL
5
7
AW
5
8
A5F
-TBM"AX376792XXXXX8004$12/22
5
9
A5F
--GHISLAINE MAXWELL
5
10
A5H
H-/T$DOC$VCR
5
11
A5H
H-/
5
12
A5H
H-/TSFEESPSEATS11A$N1.1$S1$39.09/2.93SUSD
5
13
A5H
H-/TSFEESPSEATS12A$N1.1$S2$67.50/5.06$USD
5
14
A5H
H-/T$CCBC US
5
15
A5H
H-/T$WWW EAU
5
16
A5H
H-WWW/AUTH/CIDAX
5
17
ASH
H-PSGR QUALIFIED FOR EXIT SEATING
5
18
A5H
H-IPPADDR99.48.181.171$
5
19
A5H
H-TRANP 0AC36F7B-FA1B-4515-8394-F1ABC4456FBD
5
20
A5H
H-TBMUSD255.83 BASE AMT PLUS SECURITY PER
ADT/2043/01AU
5
21
XB
TLLAXAA652P/01AUG-THU
5
22
A7
TACXTM01AUG/
01AUG19
4
20:40
ITKTS FULFILLMENT
XTM
XTM7168
1
A4G
AA 5003S 04AUG2019 PHLMHT SS/NN 12A
4
MAIN CABIN EXTRA/HD1 /AA5003S04AUG2019PHLMHT-
2
UAX
MAXWELL/GH
01AUG19
3
ITKTS FULFILLMENT
XTM
XTM7168
1
A4G
AA 814S 04AUG2019 LAXPHL SS/NN 11A
20:40
PREFERRED SEATS/HD1 /AA0814S04AUG2019LAXPHL-
3
2
UAX
MAXWELL/GHI
01AUG19
2
20:40
ITKTS FULFILLMENT
XTM
XTM7168
1
AAX
PREFERRED SEATS/HD1 /39.09USD/2.93US/42.02USD/PTC-ADT/G
2
2
AAX
MAIN CABIN EXTRA/HD1 67.50USD/5.06US/72.56USD/PTC-ADT/
01AUG19
1
20:37
CRC
HDQ8PAY
1
A5H
H-PC/PSGR CLEARED FOR TRAVEL/CORPORATE SECURITY/01
SIGNATURE LINE
Record Locator
AAA
Agent
Create Date
Create Time
Received From Sabre Purge Date
DCFDTC
www
HDQCRE
01AUG2019
20:37
WWW$GUEST
04AUG2019
CONFIDENTIAL//For Offical Use Only
3
EFTA00023851

=== Page 31 ===
VCRH*0012369671898<
*
* HISTORICAL TICKET
*
*
VIRTUAL COUPON RECORD
NAME-MAXWELL/GHISLAINE
TTL NBR OF CPNS- 2 DATE OF ISSUE-01AUG19 PNR-*PURGED 04AUG19
CC-
CPN A/L FLT CLS DATE BRDOFF TIME ST F/B
STAT
1 AA 814 S 04AUG LAXPHL 600A OK S3AHZNM5
USED
20 AA 5003 S 04AUG PHLMHT 410P OK S3AHZNM5
USED
FARE USD 250.23 TAX 18.77US TAX 5.60AY TAX 17.40XT
TOTAL USD 292.00
FARE CALC LAX AA PHL AA MHT250.23S3AHZNM5 250.23END ZPLAXPHL
XT8.40ZP9.00XFLAX4.5PHL4.5
FCMI-1
FORM OF PAYMENT
FOP-
EXP-1222 APPROVAL CODE-169641
DATE OF ISSUE-01AUG19
ISSUED AT-XTMWB XTM CCY
ENDORSEMENTS/RESTRICTIONS-
NONREF/SVCCHGPLUSFAREDIF/CXL BY FLT TIME OR NOVALUE
¥
EFTA00023852

=== Page 32 ===
Record Locator: BAXNIL
American Airlines CONFIDENTIAL for official use only.
Booked: 2019-07-18
PASSENGER INFORMATION
Pax Nbr|
Name
1.01
SAFFIAN/LEAH
2.01
MAXWELL/GHISLAINE
FLIGHT INFORMATION
Seq Nbr Flight Class
Date
Dep
Arv
Stat/Qty
Dep
Time|Arv Time
1
AA5675
K
19JUL2019
MHT
CLT
HK
2
08:00
10:30
2
AA812
K
19JUL2019
CLT
LAX
HK
2
11:40
13:44
TICKET INFORMATION
Seq Nbr
Ticket or Time Limit
1
T-18JUL-XTM758Q
2
LE
SAFFI/LXTM758Q 1626/18JUL 18*77E719
3
TE
MAXWE/G XTM758Q 1626/18JUL 18*77E719
PHONE INFORMATION
Sea Nbr
Phone Number
2
ADDRESS INFORMATION
Address
LEAH SAFFIAN
E
FREQUENT FLYER INFO
Seq Nbr
Frequent Traveler
1
AA 7685480 HK AA 1.01 SAFFIAN/LEAH GLD
PRE REQUESTED SEATS INFO
Seq Nbr Flight Class Seat Depart/Arrive Status
Name
1
AA5675
K
15D
MHT
CLT
HK
SAFFIAN/LEAH-1.01
2
AA5675
K
15F
MHT
CLT
HK
MAXWELL/GHISLAINE-2.01
3
AA812
K
22B
CLT
LAX
HK
SAFFIAN/LEAH-1.01
4
AA812
K
22C
CLT
LAX
HK
MAXWELL/GHISLAINE-2.01
OSI INFO
Seq Nbr
OSI
1
OSI PURCHASED ON AA.COM US 07/18/2019 IN US CURRENCY
CONFIDENTIAL//For Offical Use Only
1
EFTA00023853

=== Page 33 ===
Record Locator: BAXNIL
SSR
Seq Nbr Type
SSR
1
DOCA/R/US///CA
2
DOCS/DB/11DEC1958/F/SAFFIAN/LEAH/S
3
DOCO/K/XXXXXXXXX
4
DOCA
/R/US///FL
5
DOCS
/DB/25DEC1961/F/MAXWELL/GHISLAINE
6
PRAC
5675K19JUL/MHT NN1
7
PRAC
812K19JUL/CLT NN1
8
PRAC
5675K19JUL/MHT NN1
9
PRAC
812K19JUL/CLT NN1
10
STBY
5675K19JUL/NN2
11
STBY
812K19JUL/NN2
12
DBSS
/AA0812DCLTLAX201907191540AUCK201 907192044MHTLAX201907191130 NN2
13
FQTU
UAA0812K19JULCLT LAX 1140GLD
14
FQTU
UAA0812K19JULCLT LAX 1140GLD
REMARKS INFORMATION
Seq Nbr
Remarks
1
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EFTA00023856

=== Page 36 ===
VCRH*0012366995898
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FCMI-1
FORM OF PAYMENT
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IT-¥
EFTA00023857


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c3: VOL00008
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c0:
=== Page 1 ===
From: "
(USANYS) [Contractor]"
To: "Berman, Geoffrey (USANYS)"
(USANYS)"
,
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
Subject: New Epstein Ruling
Date: Thu, 21 Feb 2019 20:01:04 +0000
Importance: Normal
https://www.miamiherald.com/news/state/florida/article226577419.html
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
EFTA00024715


c1: EFTA00024870
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c3: VOL00008
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 260 Filed 05/00/21 Page 1 of 2
CG
800 Third Avenue
COHEN & GRESSER LLP
New York, NY 10022
+1 212 957 7600 phone
USDC SDNY
www.cohengresser.com
DOCUMENT
Christian R. Everdell
ELECTRONICALLY FILED
+1 (212) 957-7600
DOC #:
ceverdell@cohengresser.com
DATE FILED: 5/3/21
April 30, 2021
BY ECF
The Honorable Alison J. Nathan
Counsel for the MDC may
United States District Court
5/3/21
submit any objection to
Southern District of New York
Alim D. Nito
the Defendant's request by
United States Courthouse
May 4, 2021.
40 Foley Square
so ORDERED.
SO ORDERED.
ALISON NATHAN, U.S.D.J.
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.
EFTA00024870

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 260 Filed 05/00/21 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
800 Third Avenue, 21st Floor
New York, New York 10022
(212) 957-7600
cc:
All Counsel of Record (By ECF)
MDC Legal Department
EFTA00024871


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c0:
=== Page 1 ===
From:
"
)"
To:
)"
)"
"
,
Subject: A New Story Emerges of How Ghislaine Maxwell Recruited Young Girls | Vanity Fair
Date: Fri, 02 Oct 2020 00:42:48 +0000
https://www.vanityfair.com/style/2020/10/new-ghislaine-maxwell-recruiting-report
Sent from my iPad
EFTA00023697


c1: EFTA00024928
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c3: VOL00008
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 250 Filed 04/29/21 Page 1 of a
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100
Main
33 West 19th Street 4th Floor
917-306-6666
Cell
New York, New York 10011
888-587-4737
Fax
bc@sternheimlaw.com
April 29, 2021
USDC SDNY
Honorable Alison J. Nathan
DOCUMENT
United States District Judge
ELECTRONICALLY FILED
DOC #:
United States Courthouse
DATE FILED: 4/29/21
40 Foley Square
New York, NY 10007
Re: United States V. Ghislaine Maxwell
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
During oral argument of Ghislaine Maxwell's bail appeal before the Circuit, Ms.
Maxwell's appellate counsel expressed concern that she was improperly deprived of sleep while
detained in the MDC, an issue that has been raised in filings before this Court. In its brief denial
of her appeal, the Circuit stated: "To the extent Appellant seeks relief specific to her sleeping
conditions, such request should be addressed to the District Court." See Exhibit A. We press our
concerns regarding disruption of Ms. Maxwell's sleep and the deleterious effect sleep
deprivation is having on her health, well-being, and ability to prepare for and withstand trial.
Ms. Maxwell continues to be disrupted throughout the night by guards shining a
flash/strobe light into her cell, claiming that her breathing must be checked. The myth that Ms.
Maxwell's conditions of confinement are related to her being a suicide risk was laid to rest
during the oral argument: There is nothing to support that contrived claim. In fact, Ms. Maxwell
is classified with the standard CC1-Mh designation: inmate with no significant mental health
care. (See Dkt. 159 at 3.)
Contrary to the report that Ms. Maxwell "wears an eye mask when she sleeps" (Dkt. 196
at 4), an item neither available for purchase through MDC commissary nor provided to her, she
resorts to using a sock or towel to cover her eyes in an awkward attempt to shield them from
disrupting illumination every 15 minutes. Last night, she was confronted by MDC staff due a
visible bruise over her left eye. The "black eye" is depicted in Exhibit B. Despite 24/7 camera
surveillance (except when guards elect to exert authority in an intimidating way off-camera, as
they did in Saturday's bathroom incident), no guard addressed the bruise until Ms. Maxwell, who
has no mirror, caught a reflection of her aching eye in the glean of a nail clipper. At that point,
MDC staff confronted Ms. Maxwell regarding the source of the bruise, threatening to place her
in the SHU if she did not reveal how she got it. While Ms. Maxwell is unaware of the cause of
the bruise, as reported to medical and psych staff, she has grown increasingly reluctant to report
information to the guards for fear of retaliation, discipline, and punitive chores. However, there
is concern that the bruise may be related to the need for Ms. Maxwell to shield her eyes from the
lights projected into her cell throughout the night.
EFTA00024928

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 250 Filed 04/29/21 Page 2 of a
LAW OFFICES OF BOBBI C. STERNHEIM
The MDC routinely places inmates in the SHU if they have engaged in physical
altercation with other inmates or to protect inmates who are the subject of abuse. It would be
ironic if the MDC follows through with its threat to place Ms. Maxwell in the SHU: It would
signal that Ms. Maxwell needs protection from the very staff so intent on protecting her, since
she has no contact with anyone but staff.
As suggested by the Circuit, we ask the Court to address Ms. Maxwell's sleeping
conditions by directing the MDC to cease 15-minute light surveillance of Ms. Maxwell or
justify the need for the disruptive flashlight surveillance.
Very truly yours,
Bobbi C. Sternbeim
BOBBI C. STERNHEIM
Encs.
cc: All counsel of record
By May 5, 2021, the Government is ORDERED to
confer with MDC legal counsel and provide the
Court responses to the following questions:
1. Is Ms. Maxwell being subjected to flashlight
surveillance every 15 minutes at night? Or
any other atypical flashlight surveillance?
2. If so, what is the basis for doing so?
4/29/21
3. And if so, can she be provided with
Alin D.Nitto
appropriate eye covering?
The Government is further ORDERED to share its
response with defense counsel before filing it on
so ORDERED.
ECF so that defense counsel can indicate whether
ALISON J. NATHAN, U.S.D.J.
they believe any private medical information needs
to be redacted before public filing.
so ORDERED.
2
EFTA00024929


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=== Page 1 ===
From: "Kathleen E. Cassidy"
To:
)"
)"
Cc: Susan Necheles
>, Samidh Guha
)"
Subject: RE: Call re
Date: Fri, 27 Mar 2020 20:29:39 +0000
Attachments: 2020.03.27
draft_submission.pdf
Attached is our most recent draft for discussion purposes.
Thanks,
Kate
Original Message
From:
)
Sent: Friday, March 27, 2020 1:57 PM
To: Kathleen E. Cassidy
i
)
Cc: Susan Necheles
>; ; Samidh Guha
)
Subject: RE: Call re
Confirmed, thanks very much.
Original Message
From: Kathleen E. Cassidy
Sent: Friday, March 27, 2020 1:39 PM
To:
Cc: Susan Necheles
>; Samidh Guha
;
Subject: Re: Call re
Yes we can all do 3pm tomorrow. We can use the same call-in
pin
Sent from my iPhone
> On Mar 27, 2020, at 12:25 PM,
)
wrote:
>
> Kate,
V
> Would it work to plan to have a call tomorrow at 3:00? That would give us about a day to review and internally
discuss. Or if that timing doesn't work on your side, please let us know -- we're flexible on timing, especially
since it's a weekend and given all the circumstances.
>
> thanks,
V
V
V
Original Message
> From: Kathleen E. Cassidy
> Sent: Friday, March 27, 2020 11:43
> To:
EFTA00023551

=== Page 2 ===
>
Cc: Susan Necheles
>; Samidh Guha
V
)
V
>
Subject: RE: Call re
V
>
> Sorry for the delay -- we plan to send you a revised draft submission in the early afternoon today. After you
have had a chance to review, can we discuss? Either later today, or perhaps more realistically over the weekend?
> Thanks, Kate
>
V
Original Message
> From:
)
>
Sent: Wednesday, March 25, 2020 1:51 PM
> To: Kathleen E. Cassidy
>
Cc: Susan Necheles
>; Samidh Guha
>
V
>
Subject: RE: Call re
>
>
Great thank you!
>
V
Original Message
>
From: Kathleen E. Cassidy
> Sent: Wednesday, March 25, 2020 13:51
> To:
>
Cc: Susan Necheles
Samidh Guha
>
>
>
Subject: Re: Call re
>
> Yes we can use the same call in number.
V
>
Sent from my iPhone
>
On Mar 25, 2020, at 1:21 PM,
)
wrote:
>> I know we were bandying about the idea of a zoom discussion yesterday but I'm actually going to be away
from a computer this afternoon - alright to do a call-in to the same conference number as yesterday?
Original Appointment
From: Kathleen E. Cassidy
Sent: Tuesday, March 24, 2020 20:15
To: Susan Necheles; Samidh Guha;
);
);
)
Subject: Call re
When: Wednesday, March 25, 2020 16:00-17:00 (UTC-05:00) Eastern Time (US & Canada).
Where:
https://zoom.us/j/143912742?pwd=ekdqQkpjeGQ4bWNzRkNQZmtIUWFFdz09
gedalia Stern is inviting you to a scheduled Zoom meeting.
Join Zoom Meeting
https://zoom.us/j/143912742?pwd=ekdqQkpjeGQ4bWNzRkNQZmtlUWFFdz09
EFTA00023552

=== Page 3 ===
>>
>> Meeting ID: 143 912 742
>> Password: 704696
>>
>> One tap mobile
>> +19292056099,, 143912742# US (New York) 13126266799,, 143912742# US
>> +(Chicago)
>>
>> Dial by your location
>> +1 929 205 6099 US (New York)
>> +1 312 626 6799 US (Chicago)
>> +1 346 248 7799 US (Houston)
>> +1 669 900 6833 US (San Jose)
>> +1 253 215 8782 US
>> +1 301 715 8592 US
>>
Meeting ID: 143 912 742
>>
Find your local number: https://zoom.us/u/acaYAcAEbj
EFTA00023553


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=== Page 1 ===
From:
"
(USANYS)"
To:
"
)"
)"
,
(USANYS)"
Cc:
"
(USANYS)"
Bcc:
"
=
Subject: New accuser?
Date: Mon, 05 Oct 2020 00:44:35 +0000
Embedded: New_accuser?.msg
Sender:
Subject: New accuser?
Message-Id: <03A1DEDB-9801-49F9-915E-12E7BE43B938@usa.doj.gov>
To:
To:
To:
Cc:
EFTA00026579


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=== Page 1 ===
From:
)"
To:
)"
)
[Contractor]"
Subject: Prince Andrew reportedly now cooperating with Jeffrey Epstein investigators
Date: Sat, 14 Mar 2020 04:07:36 +0000
Did anyone talk to the telegraph?
https://pagesix.com/2020/03/13/prince-andrew-reportedly-now-cooperating-with-jefrey-epstein-investigators/
EFTA00025548


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=== Page 1 ===
From:
To:
Subject: FW: Epstein estate
Date: Wed, 08 Jul 2020 14:45:50 +0000
This works for me, and the more the merrier but also happy to handle if that's useful.
From:
Sent: Wednesday, July 08, 2020 10:44
To:
Cc:
Subject: Epstein estate
Would you have time for a relatively quick call today around 1:00?
Thanks,
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
New York, NY 10004-1482
Office
Cell
I Fax
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.
EFTA00024769


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=== Page 1 ===
From:
(NY) (FBI)"
To:
)"
Cc:
)"
)"
Subject: Re: Epstein search warrant documents
Date: Thu, 04 Jun 2020 19:16:47 +0000
Attachments: 1st_Floor.jpg; 2nd_Floor.jpg; 3rd_Floor.jpg; 4th_Floor.jpg; 5th_Floor.jpg; 6th_Floor.jpg;
Basement.jpg
From:
Sent: Thursday, June 4, 2020 1:55 PM
To:
(NY) (FBI)
is
Cc:
is
Subject: RE: Epstein search warrant documents
Great, thanks.
From:
(NY) (FBI)
Sent: Thursday, June 4, 2020 1:55 PM
To:
)
is
Cc:
y.
Subject: RE: Epstein search warrant documents
Yup
From:
)
[mailto:
Sent: Thursday, June 04, 2020 1:52 PM
To:
(NY) (FBI)
i
Cc:
is
Subject: RE: Epstein search warrant documents
Do those say what Room A, Room B, Room C, etc. are?
From:
(NY) (FBI)
Sent: Thursday, June 4, 2020 1:51 PM
To:
is
Cc:
is
)
Subject: Re: Epstein search warrant documents
I have the blueprints... I can take a picture of those and send to you. That way you'll have a visual.
From:
)
Sent: Thursday, June 4, 2020 1:47 PM
To:
(NY) (FBI)
i
Cc:
is
Subject: RE: Epstein search warrant documents
EFTA00025129

=== Page 2 ===
Thanks
!
Do you have a map or chart that can tell me which part of the residence corresponds to each room letter
in this chart?
From:
(NY) (FBI)
Sent: Thursday, June 4, 2020 1:10 PM
To:
)
is
Cc:
is
Subject: Re: Epstein search warrant documents
Hey
,
Wanted to get this to you. This spreadsheet contains all evidence seized in NY. Let me know if you have any
issues/concerns.
Thanks,
From:
Sent: Wednesday, June 3, 2020 9:37 AM
To:
is
(NY) (FBI)
Cc:
is
Subject: RE: Epstein search warrant documents
No problem-totally understood. Be safe.
From:
Sent: Wednesday, June 3, 2020 2:15 AM
To:
)
is
(NY) (FBI)
Cc:
>;
)
Subject: Re: Epstein search warrant documents
Hey
,
Both myself and
were pulled this week to assist with the riots and looting currently happening in
Manhattan. Hopefully this does not go on for too long. When we return to the office we will be sure to fill in
those blanks for you and hopefully, once again get back on track.
Be safe.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
From:
Sent: Tuesday, June 2, 2020 2:18 PM
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=== Page 3 ===
To:
is
(NY) (FBI)
Cc:
is
Subject: FW: Epstein search warrant documents
Hi
and
Any chance you'd be able to help fill in the attached chart with the specific location in the NY mansion where each device
was recovered (similar to the chart you sent me for the USVI devices), please? Once I get that, I can put together the
revised warrant.
Thanks,
EFTA00025131


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: US V. Epstein
Date: Thu, 15 Oct 2020 20:13:00 +0000
Inline-Images: image001.jpg; image002.jpg
Yes, please exclude the "Junk Search Terms (From)" hits from the responsiveness search. Once the search for the
responsiveness terms are run, please save the search so that we can take a look. I do not expect we will ask to batch
these out.
Thanks,
From:
Sent: Thursday, October 15, 2020 3:55 PM
To:
is
is
Cc:
is
Subject: RE: US V. Epstein
I am assuming that when we run the responsiveness terms and e-mail addresses we are excluding the junk documents
correct? Also, once the search for the responsiveness terms are run what do you want to do with the documents? Will
you be conducting a review and will I need to batch these documents out for you?
From:
Sent: Thursday, October 15, 2020 3:41 PM
To:
is
is
Cc:
is
Subject: RE: US V. Epstein
Thanks
I think we'd like to scrap this second search entirely. So please only keep the first search entitled "Epstein -
Junk Search Terms (From)" and tag those hits as junk. Please run the responsiveness search terms on all of the remaining
documents.
From:
Sent: Thursday, October 15, 2020 3:11 PM
To:
is
>;
Cc:
is
Subject: RE: US V. Epstein
The searches were run on the e-mails and the attachments. Do you not want the searches run on the full families?
EFTA00027052

=== Page 2 ===
From:
Sent: Thursday, October 15, 2020 3:06 PM
To:
is
in
Cc:
is
Subject: RE: US V. Epstein
I've reviewed the searched in US V. Epstein (SW). The search entitled "Epstein - Junk Search Terms (From)" looks
good to me. Please tag all of those as junk.
The search entitled "Epstein - Junk Search Terms (Keywords)" seems to have caught up a number of documents that are
not junk and appear responsive to the warrant. It's not clear to me why that happened- the ones I'm seeing don't
appear to have any of the keywords on the attached list. Is there a reason that would be? Also, I realized that this search
caught up a number of non-email documents. Would it be possible to run this search only on emails files, please?
Thanks,
From:
Sent: Thursday, October 15, 2020 2:12 PM
To:
is
is
Cc:
is
Subject: RE: US V. Epstein
Thanks very much,
The searches in the US V. Epstein database look good to me. Those materials are ready stamp as set out in my prior email.
l'll review the searches in US V. Epstein (SW) now.
From:
Sent: Thursday, October 15, 2020 12:19 PM
To:
is
is
Cc:
is
Subject: US V. Epstein
Hello,
Can you please review the following searches
US V. Epstein database:
01.Produce As Confidential
01. Produce As Highly Confidential
01. Produce As Is
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=== Page 3 ===
US V. Epstein (SW)
Epstein - Junk Search Terms (From)
Epstein - Junk Search Terms (Keywords)
Please let me know if there are any questions.
Thank you.
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=== Page 1 ===
Event: Accepted: Epstein call
Start Date: 2020-04-29 18:00:00 +0000
End Date: 2020-04-29 18:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-04-29 15:58:09 +0000
Date Modified: 2020-04-29 15:58:09 +0000
Priority: 5
DTSTAMP: 2020-04-29 15:50:03 +0000
Attendee:
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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
-V.-
S2 20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
Defendant.
THE GOVERNMENT'S MEMORANDUM OF LAW
IN SUPPORT OF ITS MOTION IN LIMINE TO PRECLUDE EXPERT TESTIMONY
OF DR. RYAN HALL, BENNETT GERSHMAN, ROBERT KELSO,
,
GERALD LAPORTE, AND JENNIFER NASO
DAMIAN WILLIAMS
United States Attorney for the
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Assistant United States Attorneys
Of Counsel
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=== Page 2 ===
TABLE OF CONTENTS
PRELIMINARY STATEMENT
1
I.
APPLICABLE LAW
1
II.
THE COURT SHOULD PRECLUDE THE TESTIMONY OF DR. RYAN HALL
4
A.
Dr. Hall's Opinions
Are Irrelevant
5
B.
The Bases of Dr. Hall's Opinions Are Not Independently Admissible
12
C.
Any Undisclosed Significance of Dr. Hall's Opinions Is Inadmissible
14
D.
Dr. Hall's Fact Testimony Is Inadmissible
15
III.
THE COURT SHOULD PRECLUDE THE TESTIMONY OF BENNETT
GERSHMAN
20
IV.
BEFORE THE DEFENDANT'S REMAINING WITNESSES OFFER EXPERT
TESTIMONY, THE DEFENDANT SHOULD BE REQUIRED TO PROVIDE SUPPLEMENTAL
NOTICE 21
A.
Robert Kelso and
22
B.
Forensic Document Specialists
24
CONCLUSION
26
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=== Page 3 ===
PRELIMINARY STATEMENT
The defendant has notified the Government that she plans to call six additional experts.
One of them, Dr. Ryan Hall,
and drafted a lengthy report, containing largely a recitation of hearsay, attributing some but not all
o
Another, Bennett
Gershman, is a purported expert on prosecutorial misconduct. Neither of these issues is relevant
at trial, and both experts should be precluded.
The defendant has failed to provide adequate notice as to the four remaining experts.
Instead of describing those experts' opinions and the bases for them, as required by Rule 16, the
notice identifies topics on which the experts might testify. The Government is therefore not able
to interpose a Daubert challenge at this time. 1 The Court should require the defense to provide
supplemental expert notice forthwith or preclude these witnesses from testifying.
I.
APPLICABLE LAW
Federal Rule of Criminal Procedure 16(b)(1)(C) provides that where, as here, the
Government has provided expert notice and requested reciprocal notice from the defense, the
defendant "must
give to the government a written summary of any [expert] testimony that
the defendant intends to use
as evidence at trial." Such summary must "describe the witness's
opinions, the bases and reasons for those opinions, and the witness's qualifications." Fed. R.
1
As described below, however, insofar as two of these witnesses will testify as fact witnesses
related to computer forensics and financial records, the Government does not object to their
testimony on Daubert grounds.
1
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=== Page 4 ===
Crim. P. 16(b)(1)(C).
As the 1993 amendments to Rule 16 note, the Rule is meant to "minimize surprise that
often results from unexpected expert testimony, reduce the need for continuances, and to provide
the opponent with a fair opportunity to test the merit of the expert's testimony through focused
cross-examination." Id. 1993 Amend. Accordingly, the Rule requires the defense to provide
(1) "notice of the expert's qualifications which in turn will permit the requesting party to
determine whether in fact the witness is an expert within the definition of Federal Rule of
Evidence 702;" (2) a "summary of the expected testimony," which "permit[s] more complete
pretrial preparation by the requesting party;" and (3) "a summary of the bases of the expert's
opinion." Id.
The content of the expert notice must actually "summarize the experts' opinions."
United States V. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017), abrogated on other grounds by
Carpenter V. United States, 138 S. Ct. 2206 (2018). "Merely identifying the general topics about
which the expert will testify is insufficient; rather, the summary must reveal the expert's actual
opinions." United States V. Valle, No. 12 Cr. 847 (PGG), 2013 WL 440687, at *5 (S.D.N.Y.
Feb. 2, 2013); see Ulbricht, 858 F.3d at 115 (calling "plainly inadequate" a disclosure that
"listed general and in some cases extremely broad topics on which the experts might opine").
The notice then must describe the bases and reasons for those opinions. "[A] general description
of possible bases does not meet the requirements of Rule 16(b)(1)(C)." United States V. Tuzman,
2017 WL 6527261, at *10 (S.D.N.Y. Dec. 18, 2017) (internal quotation marks omitted).
"Merely asserting that [an expert] will provide [an] opinion based on some unspecified method
based on data from unspecified sources, does not suffice." United States V. Ulbricht, No. 14
2
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=== Page 5 ===
Cr. 68 (KBF), 2015 WL 413318, at *6 (S.D.N.Y. Feb. 1, 2015), aff'd, Ulbricht, 858 F.3d 71. A
district court has "broad discretion" over the remedy for failure to comply with Rule 16,
including "ordering the exclusion of evidence." Ulbricht, 858 F.3d at 115 (internal quotation
marks omitted).
As the Court is well aware, a properly noticed expert witness may then testify if such
testimony complies with Federal Rule of Evidence 702. Accordingly, before admitting expert
testimony, the Court must conclude that (1) the witness is qualified to be an expert, (2) the
proposed expert testimony is reliable, and (3) the proposed testimony is relevant. See Daubert
V. Merrell Dow Pharm., Inc., 509 U.S. 579, 592 (1993); Nimely V. City of New York, 414 F.3d
381, 396 n.11 (2d Cir. 2005). "Expert testimony which does not relate to any issue in the case
is not relevant and, ergo, non-helpful." Daubert, 509 U.S. at 591 (internal quotation marks
omitted). The party that proffers the testimony bears the burden of showing that it is admissible
by a preponderance of the evidence. See id. at 592 & n.10 (citing Bourjaily V. United States,
483 U.S. 171, 175-76 (1987)).
Rules 401 and 403 of the Federal Rules of Evidence state that relevant evidence is
admissible when it tends to make the existence of any fact that is of consequence more or less
probable than it would be without the evidence, but it may be excluded if its probative value is
substantially outweighed by, among other things, the danger of unfair prejudice, confusion of the
issues, and misleading the jury. "Expert evidence can be both powerful and quite misleading
because of the difficulty in evaluating it. Because of this risk, the judge in weighing possible
prejudice against probative force under Rule 403 exercises more control over experts than over
lay witnesses." Daubert, 509 U.S. at 595 (quoting authority omitted). Among other things, the
3
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=== Page 6 ===
Court "must consider whether an expert's proposed testimony would usurp the province of the
judge to instruct on the law, or of the jury to make factual determinations." Island Intell. Prop.
LLC V. Deutsche Bank AG, No. 09 Civ. 2675 (KBF), 2012 WL 526722, at *2 (S.D.N.Y. Feb. 14,
2012) (citations omitted).
II.
THE COURT SHOULD PRECLUDE THE TESTIMONY OF DR. RYAN HALL
Dr. Ryan Hall is a psychiatrist who frequently testifies as an expert witness.
According to the notice
provided by the defendant, Dr. Hall "will offer the opinions and diagnoses contained in his
report, the bases for those opinions, and the significance of the diagnoses and opinions." (Ex. A,
Def. Expert Notice, at 12). 2
This Court should exclude Dr. Hall's testimony. As disclosed, his expert opinion
have no relevance, because none bears on the facts of this case or Minor Victim-4's
credibility. Any basis for those opinions is therefore also irrelevant. Similarly, absent some as-
yet-undisclosed relevance, the "significance" of Dr. Hall's opinion
have no bearing
here: Because none of those opinions bear on the facts of this case or a witness's credibility, their
introduction would serve onl
Dr. Hall's proffered fact testimony should also be
2
The Government has attached, and moves to file, the same redacted version of the defendant's
expert notice attached to its previous filings (See Dkt. Nos. 418 and 424).
4
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=== Page 7 ===
excluded. Much of it would constitute hearsay, and the small portion that may not would run afoul
of other rules of evidence.
A. Dr. Hall's Opinions
Are Irrelevant
3
The Government moves to redact portions of this brief and seal Exhibit B, which is Dr. Hall's
evaluation of Minor Victim-4, in accordance with the three-part test articulated by the Second
Circuit in Lugosch V. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this brief
and the attached exhibit are judicial documents subject to the common law presumption of access,
because this brief discusses a psychiatric evaluation of Minor Victim-4 contained in Exhibit B,
consisting throughout of
these
redactions and sealing requests are narrowly tailored to protect her privacy interest.
5
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=== Page 8 ===
Dr. Hall's conclusion on this issue should thus be excluded
to avoid "confusing the issues," as well as causing "undue delay," and "wasting time." Fed. R.
Evid. 403; see United States V. Blum, 62 F.3d 63, 68 (2d Cir. 1995) (assessing whether evidence
would result in "confusing the issues" under Rule 403 by asking whether it would bear upon, or
distract from, "the central issue" of the defendant's "guilt or innocence"); United States V.
Stewart, 433 F.3d 273, 313 (2d Cir. 2006) (upholding preclusion of evidence that would have
necessitated a "mini-trial").
6
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=== Page 9 ===
7

=== Page 10 ===
8

=== Page 11 ===
9

=== Page 12 ===
10
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11

=== Page 14 ===
B. The Bases of Dr. Hall's Opinions Are Not Independently Admissible
According to the defendant's expert notice, she also seeks to elicit the "bases" for the
opinions in Dr. Hall'
report. Because those opinions themselves should not be admitted for
the reasons just discussed, there is no ground to admit their basis.
To start, all the summarized information about Minor Victim-4's past is hearsay or
otherwise inadmissible. Dr. Hall was obviously not a percipient witness to any of the conduct
discussed in his report, and instead derived his understanding of Minor Victim-4's past from out-
of-court statements by Minor Victim-4 and other
12
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=== Page 15 ===
In any event, no information about the bases of Dr. Hall's opinions can satisfy the
requirements of Rule 703. Pursuant to that Rule, although an expert may rely on hearsay in
forming his opinion, the "expert may not, however, simply transmit that hearsay to the jury."
United States V. Mejia, 545 F.3d 179, 197 (2d Cir. 2008). Instead, "if facts or data would otherwise
be inadmissible, the proponent of the opinion may disclose them to the jury only if their probative
value in helping the jury evaluate the opinion substantially outweighs their prejudicial effect." See
Fed. R. Evid. 703. Here, the probative value of relaying the hearsay would be essentially nil:
13
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=== Page 16 ===
C. Any Undisclosed Significance of Dr. Hall's Opinions Is Inadmissible
In addition to testifying abou
As discussed above, to the extent his
2009 report discloses the significance of his opinions, for purposes of this case they have none,
because nothing in the report concerns the elements of or defenses to the charged offenses, or
Minor Victim-4's ability to testify accurately. (See supra at 5 to 11). And to the extent Dr. Hall
would testify about any undisclosed significance to his opinions, the failure to disclose that
testimony itself renders it inadmissible.
The party proposing to call an expert must provide "a written summary of any testimony
that the defendant intends to use." Fed. R. Crim. P. 16(b)(1)(C). The Rule requires that the expert
disclose what his testimony will be, not just the topics about which he will testify. See United
States V. Valle, No. 12 Cr. 847 (PGG), 2013 WL 440687, at *5 (S.D.N.Y. Feb. 2, 2013) ("Merely
14
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=== Page 17 ===
identifying the general topics about which the expert will testify is insufficient; rather, the
summary must reveal the expert's actual opinions."); United States V. Duvall, 272 F.3d 825, 828
(7th Cir. 2001) ("The Rule requires a summary of the expected testimony, not a list of topics.").
"Proper expert disclosures are not a mere technicality with which compliance may be made or
not-they are required by Rule 16 of the Federal Rules of Criminal Procedure" and the
requirements "do not only apply to one side and not the other." United States V. Ulbricht, No. 14
Cr.
Such a belated disclosure may require a Daubert
hearing to test the reliability of Dr. Hall's heretofore unrevealed analysis on this question. But as
the record now stands, because Dr. Hall's expert opinions are irrelevant without the addition of
some undisclosed significance, his testimony should be excluded. See Ulbricht, 2015 WL 413318,
at *5 (collecting cases concerning the exclusion of expert testimony for insufficient notice).⁸
D. Dr. Hall's Fact Testimony Is Inadmissible
The defendant's disclosure states that, in addition to providing his expert opinions and their
basis, Dr. Hall would testify about
8
To the extent the defendant is aware of additional conclusions Dr. Hall would offer, those
should be disclosed immediately-both because without such disclosures his opinions have no
apparent relevance, and because even the current disclosures are vague yet disclosed relatively
close to trial. See, e.g., Valle, 2013 WL 440687, at *6 (ordering rapid supplemental disclosure).
15
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=== Page 18 ===
If Dr. Hall had some admissible substantive
testimony, the Government would not object to a foundational account of how he evaluated Minor
Victim-4. The defendant has not, however, identified any admissible substantive testimony from
Dr.
This Court has discretion, after careful consideration of alternatives, to exclude Dr. Hall's
testimony based solely on the inadequacy of the defendant's disclosures and the lateness of any
supplemental disclosures. See Ulbricht, 858 F. 3d at 116-17 (affirming district court's exclusion
of two defense experts on those grounds).
16
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=== Page 19 ===
17

=== Page 20 ===
It remains theoretically possible that Dr. Hall's interview with Minor Victim-4 will become
relevant for impeaching her with a prior inconsistent statement. At present, however, the
Government does not expect that Minor Victim-4's testimony will be contradicted by statements
she made to Dr. Hall. And to be clear, Minor Victim-4's expected testimony about the defendant's
involvement in Epstein's scheme is not inconsistent with the fact that Minor Victim-4 did not
describe those instances to Dr. Hall. "It is well settled that for two statements to be inconsistent,
they need not be diametrically opposed. Nevertheless, the statements must be inconsistent."
United States V. Trzaska, 111 F.3d 1019, 1024-25 (2d Cir. 1997) (citations and internal quotation
marks omitted). In Trzaska, the Circuit explained that a witness's statement on one occasion that
his son was willing to give away certain guns was not inconsistent with the witness's statement on
another occasion that his son was obsessed with different guns, or guns in general. Id. Similarly,
that Minor Victim-4 described to Dr. Hall certain aspects of Epstein's abuse that did not involve
the defendant is not inconsistent with describing other aspects that did involve the defendant.
In addition, the defendant does not need Dr. Hall's testimony to inform the jury that Minor
Victim-4 has not always disclosed the defendant's role in Epstein's abuse. Minor Victim-4 also
failed to mention the full extent of the defendant's role during her first FBI interview. Because
the Government believes that in this interview-unlike the Hall interview-Minor Victim-4 was
asked questions that would have referenced the defendant in a complete answer, the Government
18
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=== Page 21 ===
expects to elicit the failure to mention her on direct, and does not object to reasonable cross
examination on the subject.
It may nonetheless be that after Minor Victim-4 testifies the defendant will be able to argue
that some statement made to Dr. Hall satisfies the multiple prerequisites for introducing extrinsic
evidence of a prior inconsistent statement. See generally United States V. Ghailani, 761 F. Supp.
2d 114, 117-19 (S.D.N.Y. 2011) (discussing requirements). 10 As the Court has noted, any
argument on that score must await the presentation of evidence. (See Nov. 11, 2021 Sealed Tr., at
194). But at present, the defendant has identified no relevant fact testimony that Dr. Hall could
offer. Because his expert testimony is similarly inadmissible, he should be excluded as a witness
absent further developments at trial.
10
To be clear, although Dr. Hall could conceivably testify as to his recollection of some prior
inconsistent statement by Minor Victim-4, the rough transcript of his interview with her cannot
become admissible as extrinsic evidence of Minor Victim-4's statements regardless how she
testifies. That label-"rough transcript"-comes from the document itself. (3505-035, at 1). And
it is quite obviously rough. The document contains numerous errors, including on material points.
Because the rough transcript is not a verbatim transcript, it cannot be offered as extrinsic
evidence of prior inconsistent statements. See United States V. Almonte, 956 F.2d 27, 29 (2d Cir.
1992) (per curiam) ("[A] 'third party's characterization' of a witness's statement does not
constitute a prior statement of that witness unless the witness has subscribed to that
characterization."); United States V. Leonardi, 623 F.2d 746, 757 (2d Cir. 1980) (FBI notes offered
to impeach not attributable to witness because "a witness may not be charged with a third party's
characterization of his statements unless the witness has subscribed to them"); see also Ghailani,
761 F. Supp. 2d at 117-18, 120 (excluding testimony about prior witness interviews offered as
prior inconsistent statements due to, among other things, concerns about translation errors).
19
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=== Page 22 ===
III.
THE COURT SHOULD PRECLUDE THE TESTIMONY OF BENNETT
GERSHMAN
The defense proposes to call Bennett Gershman, a professor of law at Pace University, for
the following testimony:
We expect Professor Gershman to provide testimony on best
practices to ensure the integrity of any prosecution, focusing on
investigation, witness preparation, media contact, neutrality,
obligations to provide accurate information, and relationship
with crime victims, their counsel, and case-related civil
litigation.
(Ex. A at 12).
This testimony should be precluded as irrelevant. At the conference on November 1, 2021,
the Court precluded "affirmative evidence by the defense that goes to the thoroughness of the
investigation," (11/01/21 Tr. at 17:15-17), including "evidence of the public outcry and scrutiny
that preceded the decision to charge the defendant," (id. at 21:1-9), as well as evidence regarding
"why and when the government conducted the investigation," including any defense evidence that
the Government "has a legally improper motive for prosecuting [the defendant] or somehow [is]
fabricating evidence or suborning perjury or the like," (id. at 23:2-6). The Court reaffirmed the
settled law in this Circuit that "the government is not on trial." (Id. at 23:10-11 (quoting United
States V. Knox, 687 F. App'x 51 (2d Cir. 2017))). To the extent evidence similar to this evidence
is permissible, the Court concluded that it was permitted only as "relevant cross-examination of
the government's witnesses." (Id. at 27:19-29:24).
Gershman's proposed testimony is relevant only to the defense theories that the Court has
precluded. This testimony invites the jury to conclude that either the New York investigation or
Florida investigation-or both-lacked "integrity." (Ex. A at 12). Whether that supposed lack of
20
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=== Page 23 ===
"integrity" goes to an argument about thoroughness, or an argument about motive and the
corruption of evidence, the Court has already ruled that the defense may not offer affirmative
evidence of that point to the jury.
Even if this testimony was not plainly barred by the Court's prior ruling, it should still be
precluded for inadequate notice. The expert notice for this witness provides only general topics of
discussion and not Gershman's opinions, and it does not identify the bases for his testimony-
which are independent reasons to preclude Gershman or to require supplemental notice. It is likely
that such information would demonstrate the unreliability or further irrelevance of Gershman's
testimony. In a recent case, however, Gershman attempted to offer precisely the sort of testimony
that this Court has already excluded. See U.S. Securities and Exchange Comm'n V. Collector's
Coffee Inc., -- F. Supp. 3d --, 19 Civ. 4355 (VM) (GWG), 2021 WL 3418829, at *2 (S.D.N.Y.
Aug. 5, 2021) (excluding Gershman's testimony in a civil case that, inter alia, "the SEC
improperly obtained an ex parte order from the Court," and "the SEC's lawyers have "engaged in
a pattern of irregular, overzealous, unethical, and unlawful conduct' throughout this litigation").
The Court should not permit expert testimony on those subjects.
IV.
BEFORE THE DEFENDANT'S REMAINING WITNESSES OFFER EXPERT
TESTIMONY, THE DEFENDANT SHOULD BE REQUIRED TO PROVIDE
SUPPLEMENTAL NOTICE
The defense provided brief notice of four additional experts: Robert Kelso, who would
testify about computer forensics;
,
who would testify about financial records; and two
forensic document specialists. The defendant's expert notice is not clear regarding these witness's
expected testimony and the bases for that testimony. Insofar as Kelso and
will testify as
fact witnesses, the Government does not object to that testimony. If they are expected to testify as
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experts, however, and before any testimony by the forensic document specialists, the defense must
say more about these witnesses' opinions and the bases for them. The Government is not able to
take a position on the reliability or relevance of those opinions from the face of the expert notice.
Given the proximity to trial, any additional delay to provide sufficient notice should be closely
scrutinized by the Court, and entirely precluded if notice is not provided forthwith.
A. Robert Kelso and
The defendant anticipates calling Robert Kelso, a computer forensics specialist, to testify
about:
the user data associated with certain devices seized and
searched by the government's team in this case, documents
and photographs extracted from certain of those devices, and
the metadata associated with certain documents and
photographs. He may also testify generally about computer
forensic principles associated with the creation of documents,
storage and retrieval of digital documents and photographs,
including the limits to the information that can be gleaned
from the metadata. Mr. Kelso may testify in rebuttal to any
testimony offered by the government through
As trial preparation proceeds, the defense will update the
topics for Mr. Kelso if any arise.
(Ex. A at 12-13).
Similarly, the defendant anticipates
,
a financial investigator, to testify about:
his review of certain financial records provided by the
government in discovery. Specifically, Mr.
will discuss
various transfers of funds that are reflected in the financial
records and explain the information contained in the financial
records regarding those transfers.
(Id. at 13).
To the extent Kelso and
are expected to summarize evidence otherwise in the record,
that testimony is not expert testimony, and therefore its admission is not precluded by Rule 702.
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See United States V. Lebedev, 932 F.3d 40, 50 (2d Cir. 2019) (concluding that "an account and
litigation consultant" who "summar[ized]
the relevant financial records" was not an expert
witness). The Government has similarly provided expert notice in an abundance of caution for
,
an FBI computer forensic examiner who will testify as a fact witness about his
extraction of devices seized pursuant to court authorized search warrants and evidence recovered
from those devices. 11
To the extent Kelso and
would testify based on their "scientific, technical, or other
specialized knowledge," however, that testimony is expert testimony. Id. (quoting Fed. R. Evid.
702(a)). And any such testimony is not reflected in the expert notice. These expert notices provide
lists of "general and in some cases extremely broad topics," which is "plainly inadequate" under
Rule 16. Ulbricht, 858 F.3d at 115. For instance, the notice for Kelso states that he will testify
"generally about computer forensic principles associated with the creation of documents," and
testify "about user data associated with certain devices seized and searched by the government's
team in this case." (Ex. A at 12). It also states that the defense may "update the topics for Mr.
Kelso" before trial. (Id. at 13 (emphasis added)). Similarly,
will "discuss various transfers
of funds that are reflected in the financial records and explain the information contained in the
financial records." (Id.). These lists of topics do not permit the Government to identify Kelso and
opinions, determine whether the proffered experts are in fact expert on those subjects, and
litigate the reliability and relevance of those opinions.
11 The Government also pointed to four other cases in this District and the Eastern District in which
testified, including United States V. Kelly, 19 Cr. 286 (AMD) (E.D.N.Y.).
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Accordingly, the Court should preclude expert testimony from Kelso and
unless and
until the defense to provides supplemental expert notice forthwith. 12 If the defense does so, the
Government should have an opportunity at that time to litigate its admissibility. And if the defense
does not do so, those witnesses should be limited to purely factual testimony. See Lebedev, 932
F.3d at 50 (affirming a limiting instruction clarifying that the witness was not providing an expert
opinion).
B. Forensic Document Specialists
Finally, the defendant has identified two forensic document specialists who she may call
as expert witnesses. Gerald LaPorte is a "Forensic Chemist and Document Dating Specialist," and
Jennifer Naso is a "Forensic Document Examiner." (Ex. A at 13-14). Regarding their expert
opinions, the defendant writes:
Defendant anticipates the receipt of documents produced by
the government and documents received pursuant to defense
subpoena included but not limited to journal pages by witness
[Minor Victim-2]. These documents may require analysis
regarding the dates of creation, completeness, alteration and
manipulation. When these documents are disclosed,
Defendant will seek to have them analyzed and present
testimony on the analysis as needed.
(Id. at 13-14).
This notice also does not provide the experts' "opinions" or "the bases and reasons for
those opinions." Fed. R. Crim. P. 16(b)(1)(C). It does not even identify the set of documents
12 Similarly, absent additional expert notice, Kelso and
should be required to limit their
testimony to facts in the record. Experts-but not other witnesses-may rely on facts or data that
are not admissible, and may disclose them to the jury in certain circumstances. See Fed. R. Evid.
703, 705.
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purportedly awaited or topics of testimony, besides documents that "may require analysis," leading
to whatever testimony is "needed." (Ex. A at 13-14). This is plainly inadequate under the rules,
and the Government cannot litigate the qualifications, reliability, or relevance of unknown
testimony about unidentified documents at this time.
Of course, the Court has the option of permitting the defense to clarify this notice mid-trial
whenever the defense receives and reviews the documents they have in mind. Doing so, however,
would almost certainly lead to mid-trial Daubert briefing, possibly a mid-trial Daubert hearing,
and late-breaking rebuttal expert notice by the Government.
The better course is to require the defense to identify, immediately, the documents they
expect to be the subject of forensic analysis and the precise forensic methodology that these experts
will use to analyze those documents. That may-depending on the details-permit some Daubert
litigation to occur now, because the Government may be able to agree with, or challenge, the notion
that these experts are qualified to use the methodology, that the methodology is reliable, or that
the document is relevant. See, e.g., Jennifer L. Mnookin, "Scripting Expertise: The History of
Handwriting Identification Evidence and the Judicial Construction of Reliability," 87 Va. L. Rev.
1723, 1726-27 (2001) (describing "major pretrial battles being waged over the admissibility of
expert evidence in handwriting identification"). 13
Here too, the Court should order the defendant to provide additional expert notice of the
methodology these experts intend to use, and the precise documents they expect to examine. Such
13 It would of course defeat the purpose of an order along these lines if the defendant gives expert
notice of numerous document examination methodologies, requiring extensive Daubert litigation
that may stretch into trial and would far exceed the scope any actual testimony that may be
presented at trial.
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an order will likely permit the Government to interpose a Daubert challenge now. Absent rapid
supplemental notice along these lines, the Court should preclude the forensic document specialists.
CONCLUSION
For the reasons set forth above, the Government respectfully requests that the Court
preclude the testimony of Dr. Ryan Hall and Bennett Gershman; preclude any expert testimony
(as opposed to fact testimony) by Robert Kelso or
; and preclude any testimony at all
from the forensic document specialists, unless and until the defendant provides supplemental
expert notice, which the Court should order the defense to provide forthwith.
Dated: November 15, 2021
New York, New York
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney for the
Southern District of New York
By:
/s/
Assistant United States Attorneys
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