# docs_fts_content

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c2: DataSet 8
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c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020688.pdf
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=== Page 1 ===
From:
(NY) (FBI)"
To:
"
)"
"
,
)"
Cc:
"
(
)"
Subject:
302
Date: Tue, 23 Apr 2019 22:46:48 +0000
Attachments: Interview of
.pdf
Hi all,
Attached is
302. See y'all tomorrow!
Special Agent
FBI New York
VCAC/Human Trafficking
EFTA00020688


c1: EFTA00023162
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023162.pdf
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=== Page 1 ===
From:
To:
)"
Cc:
)"
Subject: RE:
follow-up request
Date: Fri, 08 May 2020 20:20:45 +0000
No problem. We will speak to you tomorrow at 11:00 a.m. Eastern.
Best,
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Friday, May 8, 2020 3:55 PM
To:
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize
the sender.
Tomorrow morning would actually be fine - we'll send you a calendar invite for 11:00 a.m. Eastern time, including a
conference line number, and we'll plan to talk with you then. And just as a heads up, not that I particularly expect this will
be necessary, but similar to how we always tell witnesses that if they want to talk with their counsel privately during an in-
person meeting, we'll let her know that the same thing holds true for over the phone as well, that you two can always
have a side call at any point! And otherwise I think it will be the usual awkwardness of phone but hopefully not too bad.
thanks again,
From:
Sent: Friday, May 08, 2020 14:46
To:
Cc:
Subject: RE:
follow-up request
EFTA00023162

=== Page 2 ===
If that does not work she also said she could do it this Monday morning - 10:00 Eastern (9:00
if that is better for
your team.
Just let me know.
Thanks
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Friday, May 8, 2020 1:59 PM
To:
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize
the sender.
Thanks for getting back to us so quickly. Goes without saying that we of course would be happy for you to be on the call
as well-I should have mentioned that in my initial email. On timing, let us just check with the agents on the case to see if
that works for them, and we hope to be able to confirm with you in the next couple hours.
thanks,
From:
Sent: Friday, May 08, 2020 13:27
To:
Cc:
Subject: RE:
follow-up request
Hello
-
said she has time tomorrow if that would work for you team. She is in
so an hour behind us. I
would like to be on the call as well. Would it work to do something tomorrow at 11:00 EST? Let me know. If that does not
work I can try to get other times.
Partner
BOIES SCHILLER FLEXNER LLP
EFTA00023163

=== Page 3 ===
www.bsfllp.com
From:
[mailto:
Sent: Friday, May 8, 2020 11:02 AM
To:
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize
the sender.
I unfortunately was on trial during the previous interview, but I think somewhat less time than how long it went last time.
Ordinarily we try not to go longer than about 90 minutes in any event, so I think if she is able to block out that amount of
time, that would be great - and we'll try to be as efficient as possible and hopefully take less than that. If that sounds
alright?
thanks,
From:
Sent: Thursday, May 07, 2020 18:57
To:
Cc:
Subject: RE:
follow-up request
Hello
I am sure
will be happy to help in any way she can. Let me find out what her patient schedule is like for next week
and find a time that works. How much time do you think she should allot for the interview - just so she can plan?
Best,
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Thursday, May 7, 2020 6:41 PM
To:
Cc:
Subject: RE:
follow-up request
EFTA00023164

=== Page 4 ===
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
Hi
We wanted to follow up in connection with
- our supervisors have asked us to do an additional interview with her,
both to follow up on some specific aspects of her recollection but also do basically go through her experiences again. As
I'm sure you know, we have no doubts whatsoever, at all, about her candor and truthfulness in our previous interview,
which also was broadly consistent with what she has said in other interviews, but we are nevertheless hoping she might
be willing to speak with us sometime in the next week or two? Obviously due to the current situation we would plan to
do it via phone, and we would be happy to chat about logistics with you if that would be helpful, or to answer any
questions at all. And if
is willing to speak with us again, we're happy to work around her schedule, including talking
during an evening or weekend if that's easier for her than during the day-whatever you and she would prefer.
Please let us know if any questions, or if it would be useful to chat, and thanks very much.
From:
Sent: Thursday, January 16, 2020 14:35
To:
Cc:
y.
)
Subject: RE:
follow-up request
Got it, thanks.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From:
Sent: Thursday, January 16, 2020 2:29 PM
To:
Cc:
is
)
Subject: RE:
follow-up request
I checked back with
and she said that the last entry in her journal is in late February and she
went to
in April.
Thanks
EFTA00023165

=== Page 5 ===
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
Sent by Boxer
On January 16, 2020 at 1:05:54 PM EST,
)
wrote:
Thank you very much,
Just to confirm, does
have any journal entries regarding the time when she traveled to
? I
believe she told us during our interview that she does not have any entries from that time, but I just wanted to
make sure.
Thanks again,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From:
Sent: Thursday, January 16, 2020 12:31 PM
To:
Cc:
)
)
Subject: RE:
follow-up request
Hello - attached are the pages
sent me to provide to you. Here is a bit of an explanation and I also
asked her to take a copy of the front and back of the journal book which she did. Hope this helps. Please let
me know if you need anything else:
"The shortest page and the one that is the hardest to read is the first entry from 12/95. It is written in colored
pencil and is fading. There are then two pages from 01/07/1996 where I talk about the highlights of my NY
trip and going to Epstein's house and then the next entry from 01/25/1996 is where I talk about going to the
movies with him."
Best,
EFTA00023166

=== Page 6 ===
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 4:01 PM
To:
Cc:
)
i
)
Subject: RE:
follow-up request
Thanks very much,
Yes, we received the photographs from
,
which we very much appreciate.
Anything else she is willing to share, including her journal entries, would be very helpful.
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From:
Sent: Friday, January 10, 2020 3:59 PM
To:
)
Cc:
)
i
)
Subject: RE:
follow-up request
Hello
,
Let me follow up with
about her journal. I know she shared some pictures with you from around the
time period when she was with Epstein/Maxwell. I will ask her about the journal ASAP and will get back to
you and will check with her to see if she has anything else that might be helpful to the investigation.
All my best,
EFTA00023167

=== Page 7 ===
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 3:30 PM
To:
Cc:
)
)
Subject:
follow-up request
Hi
,
Hope you had a wonderful holiday season and very happy New Year. We wanted to follow up on a request we
made after interviewing
a few months ago. During her interview,
referred to several
entries in her journal that had helped refresh her recollection of the events involving Epstein and Maxwell. As
we mentioned at the end of the interview, it would be very helpful to our investigation if we could review
those journal entries, as well as any other records or documents
may have that relate to her experiences
with Epstein and Maxwell.
Would
be willing to share with us any relevant journal entries (or any other relevant documents she may
have) to assist in our investigation?
Happy to have a call to discuss if that would be helpful.
Thank you,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information
that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of
this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication
in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1
08201831BSF
EFTA00023168


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=== Page 1 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
Person Encounter Detail
09/21/2021 11:33 EDT
Generated By:
Page 1 of 1
Encounter Person Detail
Last Name
First Name
Middle Initial
Gender
Date of Birth
MAXWELL
GHISLAINE
Document Number
Document Type
Document Country
Class of Admission
Admit Until Date
U.S. ALIEN REGISTRATION
UNITED STATES
CARD
Encounter Person Detail
Encounter Line Type
Encounter Date
Encounter Time (Eastern)
Terminal Lane
Site/Encounter Location
AIRLINE (NOT API)
12/18/1999
16:26
QB02
A511 - CBP-CYRIL E
KING, INTL AIRPORT
Inbound/Outbound
Inspector
Processing Result
Primary Query Result
Referred To Agency
INBOUND
N
NOT REFERRED
Manifest Data
Manifest Indicator
Passenger Status
Updated Passenger Status
Flight/Vessel Number
Departure Location
N
1
Transmitted By
Carrier Code
Arrival Location
PV
For Official Use Only / Law Enforcement Sensitive
EFTA00021190


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=== Page 1 ===
From:
)"
To:
)"
,
Subject: RE: Prince Andrew 'maybe has something to hide': Epstein butler
Date: Sun, 31 May 2020 17:36:44 +0000
Definitely less than ideal. At least he doesn't mention
Original Message
From:
Sent: Saturday, May 30, 2020 7:42 PM
To:
)
;
Subject: Prince Andrew 'maybe has something to hide': Epstein butler
Not good.
https://nypost.com/2020/05/30/prince-andrew-maybe-has-something-to-hide-epstein-butler/
Sent from my iPhone
EFTA00022343


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=== Page 1 ===
From: "Weinstein, Marc A."
To:
Cc: Andrew Tomback
Bcc: "USAHUB-USAJournal111"
Subject: RE: SDNY investigation
Date: Wed, 30 Sep 2020 16:04:15 +0000
Embedded: RE:_SDNY_investigation.msg
Sender:
Subject: RE: SDNY investigation
Message-Id:
Recipient:
EFTA00020864


c1: EFTA00021983
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Discovery Tasks for Maxwell on Epstein Relativity Databases
Date: Wed, 14 Oct 2020 18:27:50 +0000
Hi,
Just the documents tagged as listed below, please (not the full family).
Thanks very much,
From:
Sent: Wednesday, October 14, 2020 12:48 PM
To:
Cc:
Subject: RE: Discovery Tasks for Maxwell on Epstein Relativity Databases
Hello,
For item three on this list. Did you want to produce the full family of documents or just the documents tagged as listed
below (ex. produce as is, produce as is and confidential, produce as is and highly confidential)?
Thank you.
From
Sent: Tuesday, October 13, 2020 11:17 PM
To:
Cc:
Subject: Discovery Tasks for Maxwell on Epstein Relativity Databases
Thanks very much for speaking earlier today. As discussed, we are asking for the following three productions to be
prepared for the Maxwell case. I've listed those tasks below in the order in which we discussed them, but, as we
discussed, if you and the vendor believe a different order would be more efficient, please just let me know.
EFTA00021983

=== Page 2 ===
As we've discussed, we need all of these materials to be delivered to 1 St. Andrews by the end of October in order to
meet our discovery deadline.
Finally, I believe
should be sending you a drive containing the scans of boxes of files from the USAO-SDFL.
We need all of those files loaded into the US V Epstein database on Relativity in a new folder entitled "USAO-SDFL Files,"
ASAP so that we can review them, please.
Thanks very much, as always for your help, and please do not hesitate to reach out if there are any questions or
confusion. I'm always happy to chat.
Thanks so much,
EFTA00021984


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=== Page 1 ===
FD-395
FEDERAL BUREAU OF INVESTIGATION
Revised
11-05-2002
ADVICE OF RIGHTS
LOCATION
Place:
Date:
Time:
teter borb Airport
7/6/19
6:10pm
YOUR RIGHTS
Before we ask you any questions, you must understand your rights.
You have the right to remain silent.
Anything you say can be used against you in court.
You have the right to talk to a lawyer for advice before we ask you any questions.
You have the right to have a lawyer with you during questioning.
If you cannot afford a lawyer, one will be appointed for you before any questioning if you wish.
If you decide to answer questions now without a lawyer present, you have the right to stop answering at any time.
CONSENT
I have read this statement of my rights and I understand what my rights are. At this time, I am willing to answer
questions without a lawyer present.
Signed:
WITNESS
Witness: SA
Witness: Det
Time:
6:11PM
FD-395 (Revised 11-05-2002)
Page 1 of 1
FEDERAL BUREAU OF INVESTIGATION
EFTA00021520


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=== Page 1 ===
EXHIBIT 2

=== Page 2 ===
Lisa M. Rocchio, Ph.D.
EDUCATION
1995
Ph.D. Clinical Psychology
University of Rhode Island, Kingston, RI
1992
MA Clinical Psychology
University of Rhode Island, Kingston, RI
1989
BA Psychology and English
Emory University, Atlanta, Georgia
1988
Visiting Student
Westfield College, London, England
ACADEMIC APPOINTMENT
2020 present
Clinical Instructor
Department of Psychiatry and Human Behavior
Alpert Medical School of Brown University
Providence, RI
LICENSURE
11/14 - present
Licensed Psychologist (MA) #10025
02/12 present
Licensed Psychologist (NY) #019490
12/97 present
Licensed Psychologist (RI) #00631
CLINICAL EXPERIENCE
7/98 present
Clinical Director and Owner, Inter-Disciplinary Independent Group Practice
Lisa M. Rocchio, Ph.D. & Associates, Inc. Johnston, RI
Psychotherapy, Assessment, Consultation, Education and Training,
Forensic Assessment, Forensic Consultation, Expert Testimony
12/97 6/98
Independent Practice
Associates in Psychotherapy, North Kingstown, RI
Psychotherapy, Assessment, Education and Training
7/96 11/97
Post-Doctoral Fellow in Psychology
Ann Begin, Ph.D., Associates in Psychotherapy, North Kingstown, RI
Women's Day Hospital Program, Butler Hospital, Providence, RI
3502-006
Page 1 of 11
EFTA00021953

=== Page 3 ===
Lisa Marie Rocchio, Ph.D. 2
7/94 7/95
Pre-Doctoral Intern in Psychology
Yale University School of Medicine, New Haven, CT
New Haven Hospital and Yale Psychiatric Institute
9/93 5/94
Clinical Psychology Extern
Counseling Center, University of Rhode Island, Kingston, RI
5/91 5/94
Clinical Psychology Trainee
Psychological Consultation Center, University of Rhode Island, Kingston, RI
9/92 5/93
Clinical Psychology Extern
Psychological Services, Brown University, Providence, RI
6/90 8/90
Family Service Student Counselor
7/91 8/91
Pre-Natal Clinic, St. Joseph's Hospital
Department of Family Service, Providence, RI
TRAINING AND CONSULTATION EXPERIENCE
2000 2002
Psychological Consultant
North Providence School Department
Performed comprehensive psychological evaluations of elementary school students
to determine the impact of psychological difficulties on school performance and
functioning. Evaluations involved clinical diagnostic interviews, psychological
testing, classroom observations and collateral interviews.
2000 2001
Psychological Consultant
Diagnostic Assessment Services, Middletown, RI
Performed comprehensive psychological evaluations of adolescents who had been
court ordered for outpatient psychological, cognitive and educational testing.
1999 2002
Consultant: Professional Development, Education and Training
Department of Children, Youth, and Families, Providence, RI
Developed and presented workshops to DCYF employees in the areas of trauma,
vicarious traumatization, and stress management.
1994
Mock Trial Expert Witness
Yale University School of Medicine, New Haven, CT
1992 1994
Workshop Leader
College Counseling Center, University of Rhode Island, Kingston, RI
Eating Disorders Workshops presented across campus to various student groups
and organizations
1992
Mock Trial Expert Witness
Travelers Worker's Compensation Trial Advocacy Program, Hartford, CT
RESEARCH EXPERIENCE
1999 2003
Research Group Member
Trauma Science Research Group, Providence, RI
6/93 9/93
Research Assistant
3502-006
Page 2 of 11
EFTA00021954

=== Page 4 ===
Lisa Marie Rocchio, Ph.D. 3
Outpatient Eating Disorders Research Group, Butler Hospital, Providence, RI
10/89 8/91
Research Project Coordinator
The Social Behavior of Developmentally Disabled Children, Bradley Hospital,
East Providence, RI
TEACHING EXPERIENCE
9/96 12/96
Adjunct Assistant Professor
University of Rhode Island, College of Continuing Education, Providence, RI
Introduction to Women's Studies (2 sections)
1/96 5/96
Special Instructor in Psychology
Providence College, Providence, RI
Psychology of Women (2 sections)
9/92 5/94
Instructor
Counseling Center, University of Rhode Island, Kingston, RI
Workshop Training for Eating Disorders Prevention
5/92 and 5/93
Teaching Assistant
University of Rhode Island, Continuing College of Education, Providence, RI
Psychology of Sexual Equality
9/91 5/92
Teaching Assistant
University of Rhode Island, Kingston, RI
Towards Self Understanding
SELECTED SPECIALIZED PROFESSIONAL TRAINING
2011 - 2012
Leadership Institute for Women in Psychology
Sponsored by the American Psychological Association, Committee on Women in
Psychology
Selected (through a competitive selection process) to participate in a leadership
training program for women in psychology, the mission of which
"is to prepare, support, and empower women psychologists as leaders to promote
positive changes in institutional and organizational life and increase the diversity,
number, and effectiveness of women psychologists as leaders".
2011
Continuing Education in Forensic Psychology (14 hours)
American Academy of Forensic Psychology (AAFP)
Comprehensive Assessment of Feigning in Forensic Settings
Forensic & Correctional Applications of the Personality Assessment Inventory
2006
Continuing Education in Forensic Psychology (28 hours)
American Academy of Forensic Psychology (AAFP)
Stalking: The State of the Science
Assessment of Response Style in Forensic Contexts
Excusing and the New Excuses
Psychological Evaluation and Testimony in Cases of Clergy or Teacher Sexual
Abuse
2005 2006
Psychotherapy Training Course for Dissociative Disorders (22.5 hours)
3502-006
Page 3 of 11
EFTA00021955

=== Page 5 ===
Lisa Marie Rocchio, Ph.D. 4
International Society for the Study and Treatment of Trauma and Dissociation
(ISSTD)
2004
Continuing Education in Forensic Psychology (21 hours)
American Academy of Forensic Psychology (AAFP)
Advanced Topics in Criminal Forensic Assessment
Forensic Consultation, Expertise & Testimony
Forensic Mental Health Assessment: Principles and Cases
2001
Eye Movement Desensitization and Reprocessing, Levels I & II (34 hours)
Eye Movement Desensitization and Reprocessing International Association
(EMDRIA)
1999 2000
Dialectical Behavior Therapy, Intensive Training, Parts I & II (72 hours)
Behavioral Technology Transfer Group
PUBLICATIONS
Bailey, T.D. & Rocchio, L.M. (2020). Evaluating the effects of repeated psychological injury: Introduction to the
Special Issue. Psychological Injury and the Law. NY: Springer
Rocchio, L.M. (2020). Ethical and professional considerations in the forensic assessment of complex trauma and
dissociation. Psychological Injury and the Law. NY: Springer
Rocchio, L.M. (Fall, 2015). Ethics corner: Psychologists Coping with Serious Health Concerns: Ethical,
Professional, and Risk Management Issues. The Newsletter of the Rhode Island Psychological Association.
Rocchio, L.M. (Spring 2011). Ethics corner: Ethical Considerations in Trauma Psychology: Vicarious
Traumatization and Self-Care. The Newsletter of the Rhode Island Psychological Association.
Rocchio, L.M. (Spring 2009). Ethics corner: How should I respond to a subpoena? The Newsletter of the
Rhode Island Psychological Association.
Lott, B. & Rocchio, L. M. (1998). Standing up, talking back, and taking charge: Strategies and outcome in
collective action against sexual harassment. In L.H. Collins, J. Chryslers, and K. Quina (Eds.) Career
strategies for women academics: Arming Athena. NY: Sage.
Lott, B. & Rocchio, L. M. (1997). Individual and collective action: Social approaches and remedies for
sexist discrimination. In H. Landrine and E. A. Klonoff (Eds.) Sexist discrimination: Prevalence,
correlates, and remedies. CA: Sage.
Rocchio, L. M., Feinstein, C., & Appareddy, V. (1997). The sibling of the psychiatrically disturbed child. In
J. Nashpitz (Ed), Handbook of Child and Adolescent Psychiatry.
Baker's Dozen (1997). Feminist student voices. In J. Worell and N. Johnson (Eds.) Feminist visions: New
directions for education and practice. American Psychological Association.
PROFESSIONAL PRESENTATIONS
Rocchio, L.M. (August, 2020). Ethical and professional considerations in the forensic assessment of trauma and
PTSD. In J. Scroppo (Chair), Ethics and Risk Management in Forensic Evaluations and Settings. Symposium
conducted virtually at the National Meeting of the American Psychological Association, Washington, DC.
3502-006
Page 4 of 11
EFTA00021956

=== Page 6 ===
Lisa Marie Rocchio, Ph.D. 5
Rocchio, L.M. (August, 2020). Ethical challenges when a client is engaged in a lawsuit: Dr. Helpful wants to help.
In APA Ethics Committee, Ethics Hot Topics. Panel presentation conducted virtually at the National Meeting of
the American Psychological Association, Washington, DC.
Rocchio, L.M. (August, 2015). Ethical dilemmas in the treatment of trauma in independent practice settings. In
Rocchio (Chair), Trauma treatment in independent practice settings: Ethical and relational issues. Skill
Building session conducted at the National Meeting of the American Psychological Association,
Washington, DC
Rocchio, L.M. (August, 2014). Trauma psychologists with serious health concerns: Ethical issues. In L. Rocchio
(Chair), Trauma psychologists with serious health concerns: Ethical, clinical and professional issues.
Symposium conducted at the National Meeting of the American Psychological Association, Washington,
DC.
Hughes, D.M. & Rocchio, L.M. (August, 2014). Essentials of forensic assessment of trauma in civil and
criminal litigation. Skill building session presented at the National Meeting of the American
Psychological Association, Washington, DC.
Rocchio, L.M. (August, 2013). Trauma in the treatment room: What the independent practitioner needs
to know. Skill building session presented at the National Meeting of the American Psychological
Association, Honolulu, HI
Rocchio, L.M. (August, 2012). The forensic evaluation of traumatic stress and dissociation in civil
litigation. In L. Rocchio (Chair), The forensic evaluation of traumatic stress and dissociation:
Malpractice and personal injury cases. Symposium conducted at the National Meeting of the American
Psychological Association, Orlando, FL.
Rocchio, L.M. (April, 2012). Trauma psychology: Legal considerations and ethical dilemmas in treatment.
Workshop presented at the 32nd Annual Meeting of the Anxiety Disorders Association of America,
Arlington, VA.
Courtois, C.A. & Rocchio, L.M. (April, 2012). Relationship dimensions and ethical factors in the
treatment of complex trauma. Workshop presented at the 32nd Annual Meeting of the Anxiety Disorders
Association of America, Arlington, VA.
Anthony, J., Feil, L., Rocchio, L.M., Plante, W., Sabo, R., and Spencer, M. (March 2012). Mental health
professionals in transition: Clinical, ethical, and practical considerations when life changes.
Professional Continuing Education Workshop sponsored by the Rhode Island Psychological
Association, Providence, RI.
Rocchio, L.M. (November 2011). Conceptualization and assessment of sexual harassment in civil
litigation. In D. Hughes (Chair), The conceptualization of trauma in a forensic context. Symposium
conducted at the 27th Annual Meeting of the International Society for Traumatic Stress Studies,
Baltimore, MD
Rocchio, L.M. (August 2011). Assessment of complex trauma in a clinical setting. In L. Rocchio (Chair),
Assessment of complex trauma and dissociation in clinical, forensic and research settings. Symposium
conducted at the National Meeting of the American Psychological Association, Washington, D.C.
Rocchio, L.M. (March 2011). Conceptualization, assessment, and treatment of trauma and dissociation:
Translating research into practice. In K. Rose (Chair), Advancing the applications and boundaries of
traumatic stress research: Translation between empirical inquiry and clinical case findings.
Symposium conducted at the National Meeting of the American Anxiety Disorders Association, New
Orleans, LA.
3502-006
Page 5 of 11
EFTA00021957

=== Page 7 ===
Lisa Marie Rocchio, Ph.D. 6
Rocchio, L.M. (March, 2011). The effects of trauma on the therapist. Paper presented at the National
Meeting of the American Anxiety Disorders Association, New Orleans, LA.
Hughes, D.M. & Rocchio, L.M. (November 2010). Forensic assessment of psychological trauma and PTSD.
Workshop presented at the 26th Annual Meeting of the International Society for Traumatic Stress
Studies, Montreal, Canada.
Rocchio, L.M. (August 2010). Professional and ethical considerations in trauma psychology: Psychotherapy.
In L. Rocchio (Chair), Professional and ethical considerations in trauma psychology: Psychotherapy,
forensics, research. Symposium conducted at the National Meeting of the American Psychological
Association, San Diego, CA.
Rocchio, L.M. (March 2010). Trauma psychology: What the anxiety disorders specialist needs to know.
Paper presented at the National Meeting of the American Anxiety Disorders Association, Baltimore,
MD.
Ethics Committee of the Rhode Island Psychological Association (June 2008). From In Treatment to our
treatment: Ethical considerations raised in the television program In Treatment. Continuing education
salon presentation sponsored by the Rhode Island Psychological Association, Providence, RI.
Ethics Committee of the Rhode Island Psychological Association (January 2007). Sex, lies &
confidentiality: A discussion of the top ten ethical issues posed to the RIPA Ethics Committee.
Professional Continuing Education Workshop sponsored by the Rhode Island Psychological Association,
Providence, RI.
Rocchio, L.M. (October 1999). The effects of trauma on the professional. Workshop presented at the Fifth
Annual Conference of the RI Coalition Against Domestic Violence, Providence, RI.
Rocchio, L.M. (April 1999). Discussant. In J.C. Chrisler (Chair), Addressing fat oppression: Research and
practice. Symposium conducted at the National Meeting of the Eastern Psychological Association,
Providence, RI.
Rocchio, L.M. (October 1997). Discussant. In J.C. Chrisler (Chair), Current issues in feminist therapy.
Symposium conducted at the National Meeting of the New England Psychological Association, Easton,
MA.
Johnston-Robledo, I., Rocchio, L. M., & Chrisler, J. C. (March 1997). AWP program content 1981 - 1996:
Where we 've been, where we 're heading. Discussion facilitated at the National Meeting of the
Association for Women in Psychology, Pittsburgh, PA.
Rocchio, L.M. (October 1996). Discussant. In J.C. Chrisler (Chair), Women and weight: Gendered
messages from the media. Symposium conducted at the National Meeting of the New England
Psychological Association, New London, CT.
Rocchio, L. M. (August 1996). The pursuit of beauty through thinness and the impact of advertising on
college women's attitudes. In C. Smith (Chair), Empirical investigations of women's pursuit of beauty.
Symposium conducted at the National Meeting of the American Psychological Association, Toronto,
Canada.
Cogan, J. & Rocchio, L. M. (March 1995). Fat oppression and body hatred: Strategies for change. One-half
day training workshop presented at the National Meeting of the Association for Women in Psychology,
Indianapolis, IN.
3502-006
Page 6 of 11
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=== Page 8 ===
Lisa Marie Rocchio, Ph.D. 7
Cogan, J. & Rocchio, L. M. (March 1994). Celebrating and redefining our diverse beauty: Rejecting body
hatred. Workshop presented at the National Meeting of the Association for Women in Psychology,
Oakland, CA.
Rocchio, L. M. (March 1993). Battered women who kill, psychology, and the law. Paper presented at the
National Meeting of the Association for Women in Psychology, Atlanta, GA.
Gregory, C.J., Minugh, P. A., Riedford, M., Rocchio, L. M., & Saris, R. (March 1993). Women Against
Sexual Harassment (WASH): Working to eliminate sexual harassment from the academic community.
Workshop presented at the National Meeting of the Association for Women in Psychology, Atlanta, GA.
Silver, B., Rocchio, L. M., & Gregory, C.J., (November 1992). A model for gender role assessment. Paper
presented at the meeting of the New England Psychological Association, Fairfield, CT.
Rocchio-Giordano, L. M. (February 1992). Moral reasoning related to gender and dilemma content. Paper
presented at the National Meeting of the Association for Women in Psychology, Long Beach, CA.
INVITED ADDRESSES
Rocchio, L.M. (January, 2021). Trauma psychology: What the trauma psychotherapist needs to know. Invited
presentation to the PGY 3 Residency Seminar at Brown Alpert School of Medicine. Providence, RI.
Rocchio, L.M. (March, 2016, 2017, 2018). Vicarious traumatization: The effect of trauma exposure on the
helping professional. Invited continuing education presentation to the New England Society for the
Treatment of Trauma and Dissociation workshop: Fundamentals of Complex Trauma and Dissociation,
Cambridge, MA.
Rocchio. & Mills, M.A.M. (May, 2017). The anxiety and obsessive compulsive disorders: Overview and
treatment strategies. Invited continuing education presentation to the members of the Behavioral
Health Pod of the Rhode Island Primary Care Physician's Corporation, Cranston, RI.
Hughes, D.M. & Rocchio, L.M. (August, 2016). Forensic work with trauma populations. Invited hospitality
suite presentation sponsored by Division 56 of the American Psychological Association. Presented at the
National Meeting of the American Psychological Association, Denver, CO.
Rocchio, L.M. (2016). Trauma psychology: What the therapist needs to know. Invited continuing education
presentation to the members of the Behavioral Health Pod of the Rhode Island Primary Care Physician's
Corporation, Cranston, RI
Rocchio, L.M. (2016, 2015, 2013, 2012, 2011, 2010, 2009, 2008). Ethical considerations in the practice of
clinical and forensic psychology: Business and forensic issues. Invited presentation to the participants
of the Fellows Ethics Workshop, Brown University, Providence, RI.
Rocchio, L.M. (2015, 2014). Ethical considerations in the practice of clinical and forensic psychology:
Multiple Relationships. Invited presentation to the participants of the Fellows Ethics Workshop, Brown
University, Providence, RI.
Brown, LS., Gold, S., & Rocchio, L.M. (August, 2014). The forensic assessment of trauma. Invited
hospitality suite presentation sponsored by Division 56 of the American Psychological Association.
Presented at the National Meeting of the American Psychological Association, Washington, DC
Brown, LS., Gold, S., & Rocchio, L.M. (August, 2013). The forensic assessment of trauma. Invited
hospitality suite presentation sponsored by Division 56 of the American Psychological Association.
3502-006
Page 7 of 11
EFTA00021959

=== Page 9 ===
Lisa Marie Rocchio, Ph.D. 8
Presented at the National Meeting of the American Psychological Association, Honolulu, HI.
Rocchio, L.M. (August 2011). Development of a successful independent group practice in psychology.
Hospitality suite conversation hour sponsored by Division 42 of the American Psychological Association.
Presented at the National Meeting of the American Psychological Association, Washington, D.C.
Rocchio, L.M. (April 2009). Practical, legal and ethical considerations in establishing an independent
practice in psychology. Invited salon presentation to Early Career Psychologists sponsored by the
Rhode Island Psychological Association, Providence, RI.
Rocchio, L.M. (April 1996). The pursuit of beauty through thinness and the impact of advertising on
college women's attitudes. Invited colloquium presented to the Providence College Department of
Psychology, Providence RI.
Rocchio, L.M., Gregory, C.J., & Minugh, P.A. (1993). Women Against Sexual Harassment (WASH):
Dealing with sexual harassment in the workplace. Invited presentation to the participants of the Feminist
Lecture Series, Butler Hospital, Providence, RI.
Rocchio, L.M. (April 1993). Women and weight. Panel discussion participant, Brown University,
Providence, RI.
Rocchio, L.M. (May 1991). Images of women in the media, the pursuit of beauty, and eating disorders.
Invited presentation to Psychology of Sexual Equality class, University of RI, Kingston, RI.
DISSERTATION AND THESIS
Rocchio, L. M. (1995). The pursuit of beauty through thinness and the impact of advertising on college
women's attitudes. Doctoral dissertation, University of RI, Kingston, RI.
Rocchio, L. M. (1993). Moral reasoning related to gender and dilemma content. Master's thesis, University
of RI, Kingston, RI.
PROFESSIONAL ACTIVITIES
American Psychological Association
2021 - present
Division 56 (Trauma Psychology) President-Elect
2020 present
APA Ethics Committee Member: Forensic Slate
2014 - present
Division 56 Journal, Trauma Psychology: Theory, Research, Practice and Policy,
Editorial Review Board Member
2019 - 2020
Division 56 Member at Large
2013 - 2019
Division 56 Treasurer
2009 - 2019
Division 56 Representative to the Committee on Women in Psychology (CWP)
2015 2016
APA Committee for State Leaders, Past-Chair
2014 - 2015
State Leadership Convention (SLC) 2020 Initiative Task Force, CSL
Representative
2013 - 2015
APA Committee for State Leaders, Chair
2012 2013
APA Committee for State Leaders, Member-at-large
2010 - 2013
Division 56 Membership Chair; Program Review Committee Member
1996 2000
Division 35 Student Research Prize Reviewer
1992 1995
Division 35 Student Committee Member
3502-006
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=== Page 10 ===
Lisa Marie Rocchio, Ph.D. 9
Association for Women in Psychology
2011, 1992 - 2000
Program Review Committee Member
1996 2000
Student Research Prize Review Committee Member
1999
Conference Planning Committee Member
1991 1995
Co-Coordinator, RI Chapter
1992 1995
Student Caucus Coordinator
Blue Cross Blue Shield of RI
2020 present
Grant Recipient for Behavioral Health Provider Quality Support
Grant Pilot Program
2015 present
Quality Measures Workgroup Member
Coalition of Mental Health Providers in RI
2004 - present
Founding Committee Member
Healthsource RI
2014 - 2015
Expert Advisory Panel, Member
New England Psychological Association
1995
Program Review Committee, Member
Rhode Island Primary Care Physicians Corporation Behavioral Health Network
2014 - present
Vision Committee Member
2013 - present
Communications Committee Member
Rhode Island Psychological Association
2020 - present
Social Justice Committee Member
2016 — present
APA Council Representative
2013 - present
Healthcare Task Force/Committee Member
2011 - present
Legislative Affairs Committee Member
1996 present
Ethics Committee Member
2015 2016
Secretary
2010 - 2014
Colleague Assistance Task Force/Committee Member
2014 2015
Past-President
2012 - 2014
President
2011 - 2012
President-Elect
2006 2008
Ethics Committee Chair
Rhode Island and Southeastern Massachusetts Trauma Study Group
2010 - 2016
Co-founder and member
3502-006
Page 9 of 11
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=== Page 11 ===
Lisa Marie Rocchio, Ph.D. 10
PROFESSIONAL ADVOCACY
Congressional Visits
Visits organized by the American Psychological Association:
March, 2016
Medicare and Mental Health Reform. Senators Jack Reed and Sheldon Whitehouse
(Rhode Island)
March, 2016
Medicare and Mental Health Reform. Representatives David Cicilline and James
Langevin (Rhode Island)
March, 2015
Medicare. Senators Jack Reed and Sheldon Whitehouse (Rhode Island)
March, 2015
Medicare. Representatives David Cicilline and James Langevin (Rhode Island)
March, 2014
Medicare. Senators Jack Reed and Sheldon Whitehouse (Rhode Island)
March, 2014
Medicare. Representatives David Cicilline and James Langevin (Rhode Island)
Feb., 2012
Medicare and Healthcare Reform. Senators Jack Reed and Sheldon Whitehouse
(Rhode Island)
Feb., 2012
Medicare. Representatives David Cicilline and James Langevin (Rhode Island)
Rhode Island Legislative Advocacy
09/2013 - 02/ 2014
Special Joint Commission to Study the Integration of Primary Care and Behavioral
Health, Co-Chaired by Senator Joshua Miller and Representative David Bennett,
Commission Member.
2004 present
Advocacy regarding legislation:
The increased oversight of Blue Cross/Blue Shield of RI by the office of the Insurance
Commissioner. Changes to the RI licensing law for psychologists
The inclusion of psychologists in corporate practice of medicine legislation
Ensuring that psychologists' scope of practice was not restricted by the passage of
statutes related to the practice of applied behavioral analysis
Local mental health parity legislation
Marriage equality in the state of RI.
PROFESSIONAL AFFILIATIONS
American Psychological Association (APA), Fellow Divisions 42 and 56
3502-006
Page 10 of 11
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=== Page 12 ===
Lisa Marie Rocchio, Ph.D. 11
American Psychological Association (APA), Member Divisions 12, 29, 31, 35, 41,
Association for Women in Psychology (AWP)
Eye Movement Desensitization and Reprocessing International Association (EMDRIA)
International Society for the Study of Trauma and Dissociation (ISSTD)
International Society for Traumatic Stress Studies (ISTSS)
Massachusetts Psychological Association
New England Society for the Treatment of Trauma and Dissociation (NESTTD)
Rhode Island Psychological Association (RIPA)
COMMUNITY ACTIVITIES
2019 - present
Governance Committee Member, Moses Brown School, Providence, RI
2011 - 2019
Nominating Committee Member, Moses Brown School, Providence, RI
2013 - 2017
Clerk, Nominating Committee, Moses Brown School, Providence, RI
2013 -2017
Executive Committee Member, Moses Brown School, Providence, RI
2011 - 2017
Board of Trustees, Moses Brown School, Providence RI
2008 - 2015
Trustee Committee Member, Moses Brown School, Providence, RI
2002 - 2006
Founding Director, Board of Directors, Quest Montessori School, Exeter.
3502-006
Page 11 of 11
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=== Page 1 ===
Event: Epstein Team Meeting
Start Date: 2019-10-30 20:30:00 +0000
End Date: 2019-10-30 21:30:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2019-10-30 13:05:55 +0000
Date Modified: 2019-10-30 13:05:55 +0000
Priority: 5
DTSTAMP: 2019-10-30 12:58:03 +0000
Attendee:
EFTA00021287


c1: EFTA00022435
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c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022435.pdf
c6: pdf
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c0:
=== Page 1 ===
From:
)"
To: "McGorty, Glen"
Cc:
)"
"Zelenko, Daniel"
"Giffuni, Danielle"
(USANYS)"
Subject: RE: Wednesday's WebEx
Date: Fri, 07 May 2021 16:44:48 +0000
Hi Glen,
Thanks very much, and we'll definitely keep that in mind.
Best,
Original Message
From: McGorty, Glen
Sent: Friday, May 7, 2021 12:34 PM
To:
)
Cc:
Zelenko, Daniel
Giffuni, Danielle
(USANYS)
Subject: RE: Wednesday's WebEx
,
We spoke with
and explained the government's interest in calling him as a witness for Ms. Maxwell's trial.
He has no specific plans which cannot be moved at this point, but we would only ask that you keep in mind that
he's going to need to fly up to NY
Please keep us posted as scheduling proceeds and, obviously,
please let us know if and when you want to meet with him in advance of trial.
Best,
Glen
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
I
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3c3c0812918150f4&q=1&e=933a0917-9adb-4b96-b7eb-
545ade9fe2f1&u=http%3A%2F%2Fwww.crowell.com%2F | Web Bio
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This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO
NOT READ IT.
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Original Message
EFTA00022435

=== Page 2 ===
From:
Sent: Thursday, May 6, 2021 1:10 PM
To: McGorty, Glen
Cc:
>; Zelenko, Daniel
Giffuni, Danielle
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Thanks, that would be great. We can use this conference line:
,
passcode
Original Message
From: McGorty, Glen
Sent: Thursday, May 6, 2021 12:55 PM
To:
Cc:
>; Zelenko, Daniel
Giffuni, Danielle
i
(USANYS)
Subject: Re: Wednesday's WebEx
Of course. How is 3 pm?
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
<x-apple-data-detectors://6/1>
<mailto:
|
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prohibited.
On May 6, 2021, at 12:50 PM,
)
wrote:
External Email
Hi Glen,
Hope you're doing well. Do you have time for a quick call this afternoon or tomorrow?
Thanks very much,
From:
Sent: Wednesday, November 18, 2020 10:52 AM
To: McGorty, Glen
Cc: Zelenko, Daniel
; Giffuni, Danielle
(USANYS)
Subject: RE: Wednesday's WebEx
Glen,
Attached please find the fully executed proffer agreement with the agent's initials and my initials added.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
EFTA00022437

=== Page 4 ===
From:
)
Sent: Tuesday, November 17, 2020 9:30 PM
To: McGorty, Glen
<mailto:
)
<mailto:
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
Received, thank you very much, Glen.
Best,
Assistant United States Attorney
Southern District of New York
<mailto:
From: McGorty, Glen
<mailto:
Sent: Tuesday, November 17, 2020 8:21 AM
To:
<mailto:
<mailto:
Cc: Zelenko, Daniel
<mailto:
>;
Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
sorry for the delay. Here is the executed proffer agreement from our last meeting.
Best,
Glen
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
<mailto:
I
https://protect2.fireeye.com/v1/url?k=404d5859-
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EFTA00022438

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EFTA00022439

=== Page 6 ===
5FT7XCVardfvyVA4USCDMtMTJH-5F-5F9MCwLk-2526e-
253D%26d%3DDwIGaQ%26c%3DAnw7wKLFSGyH7zEzIqo-zgMRy5HE-AH-
SibmOy3H7xE%26r%3Dz3qSdxmKBzz6GPGylfF-
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DBc6HsIYghPlsVjbZolpXL2OPkD7K7DBf3awq0bZu4Kk%26e%3D>
From:
)
<mailto:
Sent: Wednesday, November 11, 2020 1:43 PM
To: McGorty, Glen
<mailto:
)
<mailto:
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
External Email
Glen,
We will be joined by two FBI agents who are focusing on the CBP topics that we have previously discussed. I
expect one of those agents will take the lead on questioning Mr.
The topics we expect to cover include:
*
The identities of any CBP employees Mr.
recalls interacting with Jeffrey Epstein in the Virgin Islands.
* Any steps Mr.
recalls any CBP employees in the Virgin Islands taking to help Epstein and those
traveling with Epstein to enter the country, including any steps that allowed Epstein or those traveling with him
to avoid processing that travelers would normally undergo.
* Any favors Mr.
recalls Epstein doing for CBP employees in the Virgin Islands, such as trips to
Epstein's island.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
From: McGorty, Glen
<mailto:
Sent: Tuesday, November 10, 2020 1:16 PM
To:
<mailto:
<mailto:
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
just wanted to circle back with you in advance of Thursday's meeting. We want
to be fully
prepared, so if there is any more granularity on this topic (or any additional topic or topics), please let us know.
EFTA00022440

=== Page 7 ===
Thanks,
Glen
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
<mailto:
I
https://protect2.fireeye.com/v1/url?k=1c17f113-
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EFTA00022441

=== Page 8 ===
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839a7b16d7befe52&q=1&e=933a0917-9adb-4b96-b7eb-
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From:
)
<mailto:
Sent: Monday, October 26, 2020 6:19 PM
To: McGorty, Glen
<mailto:
)
<mailto:
Cc: Zelenko, Daniel
<mailto:
>; Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
EFTA00022442

=== Page 9 ===
Subject: RE: Wednesday's WebEx
External Email
Thanks very much, Glen. Let's plan for 1pm on Thursday, 11/12. I will circulate WebEx invitation shortly.
We expect to ask Mr.
about his interactions with
the U.S. Customs and Border
.
Protection employee who worked in Saint Thomas and who had Mr.
listed as
contact in his phone. I
expect we will ask for an approximate timeline of when Mr.
met and interacted with
, the nature
of those interactions, and any interactions
may have had with Epstein (to the best of Mr.
knowledge).
Best,
Assistant United States Attorney
Southern District of New York
<mailto:
From: McGorty, Glen
<mailto:
Sent: Monday, October 26, 2020 11:58 AM
To:
<mailto:
>;
)
<mailto:
Cc: Zelenko, Daniel
<mailto:
>; Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
Sorry for the delay. Looks like we can do between 11
and 2 p.m. on Tuesday, 11/10, or any time on
Thursday, 11/12. Let us know if anything in that range will work.
So as to make sure Mr.
is prepared, can you give us an overview of what you expect to cover?
Thanks,
Glen
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
<mailto:
I
https://protect2.fireeye.com/v1/url?k=d514b2f8-
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EFTA00022443

=== Page 10 ===
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EFTA00022444

=== Page 11 ===
2D2D2D252Fwww.crowell.com-2D2D2D252Fprofessionals-2D2D2D252FGlen-2D2D2D2DMcGorty-
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Dt4UWitiN_BYtgjif7MysQAP2qgRZfcimKQ7kyripSi2c%26e%3D>
Privileged and Confidential Attorney-Client Communication Attorney Work Product This message contains
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Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
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Center<https://protect2.fireeye.com/v1/urlPk=ca66e66e-95fdde9e-ca61c28b-0cc47adc5fd8-
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EFTA00022445

=== Page 12 ===
253DDwMFAg-2526c-253DAnw7wKLFSGyH7zEzIqo-2DzgMRy5HE-2DAH-2DSibmOy3H7xE-2526r-
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D3bpaIcOJpplbU_IT2KMC-mHb_EZuywFGXt5dR9HZbJM%26e%3D>
From:
)
<mailto:
Sent: Thursday, October 22, 2020 10:33 AM
To:
<mailto:
McGorty, Glen
<mailto:
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
External Email
Glen,
As I believe we mentioned when we last spoke, we would like to schedule time for a second interview with Mr.
via WebEx. Are there any days the week of November 9th when your team and Mr.
would be
available? We would expect this proffer to be much shorter than our first, and certainly no more than two hours
at most.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
From:
<mailto:
Sent: Friday, October 9, 2020 4:42 PM
To: McGorty, Glen
<mailto:
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
)
<mailto:
Subject: RE: Wednesday's WebEx
Hi Glen,
Thanks very much. I'm attaching the fully executed copy.
Thanks,
EFTA00022446

=== Page 13 ===
From: McGorty, Glen
<mailto:
Sent: Thursday, October 8, 2020 9:31 AM
To:
<mailto:
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
)
<mailto:
Subject: RE: Wednesday's WebEx
Hi all.
Attached please find the signed proffer agreement. It was nice seeing everyone yesterday.
Thanks,
Glen
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
<mailto:
I
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EFTA00022447

=== Page 14 ===
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Privileged and Confidential Attorney-Client Communication Attorney Work Product This message contains
privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com<mailto:postmaster@crowell.com> by reply e-
mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
EFTA00022448

=== Page 15 ===
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource
Center<https://protect2.fireeye.com/v1/url?k=81f51725-de6e2fd5-81f233c0-0cc47adc5fd8-
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From:
)
<mailto:
Sent: Monday, October 5, 2020 4:14 PM
To: McGorty, Glen
<mailto:
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
)
<mailto:
Subject: RE: Wednesday's WebEx
External Email
Hi Glen,
Not a problem at all -- I've added everyone to the calendar invitation. Please let us know if any other tech issues
crop up, and we'd be happy to work through them.
Thanks,
EFTA00022449

=== Page 16 ===
From: McGorty, Glen
<mailto:
Sent: Monday, October 5, 2020 12:48 PM
To:
<mailto:
)
<mailto:
(USANYS)
<mailto:
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
mailto:
>;
Morrissey, Josh
<mailto:
Subject: Wednesday's WebEx
,
Thanks for sending the WebEx invitation for Wednesday's meeting to me. For whatever reason, the system is not
permitting me to forward the invite, so I would ask that you separately invite those copied on this e-mail: Dan,
Danielle and Mr.
,
but also Josh Morrissey who is in our IT group and will make sure we are good to go
for our meeting.
Thanks,
Glen
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
|
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EFTA00022450

=== Page 17 ===
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EFTA00022451

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EFTA00022452

=== Page 19 ===
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EFTA00022453


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=== Page 1 ===
From:
USANYS)"
To:
)"
)"
Subject: Forfeiture doc
Date: Wed, 24 Apr 2019 15:56:23 +0000
Importance: Normal
Attachments: TVPA_and_Forfeiture(2).docx
FYI - an updated version of the forfeiture doc. Also on the share.
I am excited to hear about how tonight goes!
Abby
Assistant United States Attorney
Human Trafficking Co-Coordinator
Money Laundering & Transnational Criminal Enterprise Unit
Southern District of New York
EFTA00020701


c1: EFTA00021141
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021141.pdf
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c0:
=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: RE: travel approval request
Date: Thu, 13 Feb 2020 18:47:36 +0000
Inline-Images: image001.png
Is it a requirement that our domestic flights be refundable? I knew that was true for international flights but I thought we
could book nonrefundable flights traveling domestically?
From:
Sent: Thursday, February 13, 2020 13:46
To:
-
is
Cc:
is
Subject: RE: travel approval request
Importance: High
the Delta departing flight you chose leaving LGA at 9:00am, arriving in Pensacola, FL at 12:49pm is not refundable, so
you'll need to choose another flight option. While checking out your flight options, I found a flight that will get you into
Pensacola, FL around the same time as your preferred option that's fully refundable. The difference is that the flight
leaves at 8:11am instead of 9:00am. I've placed the departing flight below for your review.
American Airlines
Contract carrier
Feb 19
ew York, NY (LGA), 8:11 AM
harlotte, NC (CLT), 10:35 AM
3 miles
A 1252
bach Lowest available including Penalty fares.
rbus A319
eview seat map
Layover (55m)
Charlotte, NC (CLT)
American Airlines
Contract carrier
Feb 19
harlotte, NC (CLT), 11:30 AM
ensacola, FL (PNS), 12:23 PM
0 miles
5298 (Operated by PSA AIRLINES AS AMERICAN
AGLE)
bach Lowest available including Penalty fares.
RJ900
eview seat map
Top of Form
All available fares for Option 28
$161.70
CA
Govt contract fare limited availability
Bottom of Form
EFTA00021141

=== Page 2 ===
Please let me know if you would like me to reserve this flight instead and I'll continue with your reservation. Thanks as
always.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Thursday, February 13, 2020 1:26 PM
To:
is
Cc:
is
Subject: RE: travel approval request
Apologies for the slight delay yesterday on this travel, we had a witness scheduling issue so the travel will be a day later
than originally anticipated. The city is Pensacola, Florida, and it will be me and
(rather than
and
if you could please book me on the following flights:
Feb. 19: Delta, LGA to PNS, 9:00 a.m. (arriving 12:49 p.m.)
Feb. 20: Delta, PNS to LGA, 4:06 p.m. (arriving 9:41 p.m.)
And the following hotel, for the night of Feb. 19:
-
Hilton Garden Inn (listed in E2 as "HGI PENSACOLA AIRPORT MEDICAL")
We will also need a conference room at the Hilton Garden Inn for February 19, starting at 5:00 p.m. for three hours (or for
the entire day, if that's the only way they'll do it).
Please let us know if any questions or issues, and thanks as always.
From:
Sent: Wednesday, February 12, 2020 09:02
To:
is
;
i
Cc:
Subject: Re: travel approval request
Hi,
Which specific city will the hotel be in?
If
could push the travel authorizations thru to
& I today, that would be great As well as sending the
conference room payment request to Nick Siu.
Remember to take the FL tax exempt form along with you.
Thanks
EFTA00021142

=== Page 3 ===
Sent from my iPhone
On Feb 12, 2020, at 6:43 AM,
wrote:
Approved
Sent from my iPad
On Feb 11, 2020, at 7:53 PM,
wrote:
Similar to prior requests in connection with the Epstein investigation (2018R01618),
and I would like to please
request permission for the two of us to travel next week for an interview of a witness in Pensacola, Florida on 2/19.
We'd plan to fly down on 2/18 and fly back on 2/19. Also, similar to prior requests, we'd like to request approval to get
a conference room on 2/19.
Thank you,
From:
Sent: Tuesday, January 21, 2020 2:56 PM
To:
Cc:
is
is
is
i
Subject: RE: travel approval request
Approved
From:
Sent: Tuesday, January 21, 2020 2:49 PM
To:
>
Cc:
>;
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), but with an added international
element, we'd like to please request permission for the team to travel next week for an interview near Stockholm,
Sweden, next week on January 29th and/or 30th. We expect to be traveling, respectively, some combination of the
27th (overnight) to the 31st, depending on when the interview ends up being scheduled, and we'll put final dates on
our formal applications. Also similar to prior trips, we'd like to request approval to get a conference room for one of
those days at a hotel for the interview itself.
Also based on our discussion earlier we'll be mindful of looking for domestic (or domestic-flagged) carrier flights, as
well as the costs of any alternatives, in looking at possible specific bookings. Thanks as always for your help and input
on that.
thank you,
EFTA00021143

=== Page 4 ===
From:
Sent: Wednesday, December 11, 2019 09:58
To:
Cc:
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16
and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior
trips, we'd like to request approval to get a conference room for one of those days.
thank you,
From:
Sent: Tuesday, November 05, 2019 16:53
To:
Cc:
>;
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be
traveling, respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip).
thanks,
From:
Sent: Tuesday, October 22, 2019 13:55
To:
Cc:
is
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel on that Monday for the interview, please.
thanks very much,
EFTA00021144

=== Page 5 ===
From:
Sent: Wednesday, June 12, 2019 14:51
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no
later than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference
room at the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling
allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will
either be me and
or
and
,
but we wanted to ask for permission now either way so we weren't
doing it super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
EFTA00021145

=== Page 6 ===
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
)
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors
for sexual activity,
and I would like to please request permission to travel for approximately three days next
week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday
night and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
)
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West
Palm Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return
on Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00021146


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=== Page 1 ===
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 19, 2020
BY FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Enclosed is discovery pertinent to the following inmate:
Ghislaine Maxwell: 02879-509
Please allow her access to the materials enclosed.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
Enclosure
EFTA00022054


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=== Page 1 ===
U.S. Department of Justice
Criminal Division
VAA:WHG:TNB:AF:ss
Office of International Affairs
Embassy of the United States of America
75008 Paris
Tel.:
Fax:
December 30, 2020
Via Email
Assistant United States Attorney
One St. Andrews Plaza
New York, New York 10007-1791
Re:
Request for Legal Assistance from France in the Investigation of
OIA Reference Number: CRM-182-74832; French MOJ/BEPI
Number: 2020002015
Dear AUSA
Please find enclosed a request from France for legal assistance in a foreign criminal
matter. The United States is obligated to assist in such matters pursuant to the 1998 U.S.-France
Mutual Legal Assistance Treaty, as supplemented by the 2004 U.S.-France Mutual Legal
Assistance Instrument. Consistent with the requirements of 18 U.S.C. § 3512, the United States
Attorney's Office (USAO) is authorized to seek any requisite court orders and to take other steps
necessary to execute the above-referenced request. This matter has been referred to the USAO
for execution because your office is pursuing a related investigation. Please note that this matter
should be kept confidential, and all filings with the court should be under seal.
The Facts
The facts of the case are set forth in detail in the enclosed request. In sum, French
authorities have begun an investigation into the actions of Jeffrey EPSTEIN and his accomplices,
notably
The French investigation has focused on
, and French
authorities executed as search warrant at EPSTEIN's Paris residence in September 2019, where
they obtain evidence and information relating to
and Ghislaine MAXWELL. French
authorities have identified multiple victims, though a number of charges related to these victims
are barred by France's statute of limitations.
EFTA00023110

=== Page 2 ===
2
In furtherance of its investigation, and as outlined in the request, French authorities seek a
wide variety of information from the United States that may be useful to their investigation.
Request for Assistance
To further the investigation, and as outlined in the request, French authorities have
requested information in possession of U.S. authorities of use to their information related to
designated individuals, including
MAXWELL, and other specified victims.
Execution of Request
Based on the information provided by French authorities, the AUSA to whom this request
is assigned is not expected to need to compel any entities to produce records. Nevertheless, if
such a step is required, the AUSA should file an application in the U.S. District Court seeking an
order, pursuant to 18 U.S.C. $ 3512, appointing him/her to serve as a commissioner. If the court
grants the application, the AUSA should serve a "commissioner subpoena(s)" compelling the
entity to produce the records. A sample pleading is available upon request.
Coordination with OIA
Please provide me with the name and telephone number of the AUSA to whom this
request is assigned and ask him or her to analyze the request and notify me immediately if it
contains insufficient information to permit execution or there are special considerations that will
result in limited or delayed execution of the request or possible denial of the request. For
example, if execution would result in harm to a U.S. investigation or prosecution or compromise
a confidential source, assistance can be delayed or denied or conditions on use can be imposed.
If such considerations arise with respect to this request, please contact me as soon as possible to
discuss available options.
Please keep me apprised of the progress made in executing this request. I will serve as
the main point of contact for both your office and France. I can be reached by e-mail at
or by telephone at
if you have any
questions regarding the execution of the request or need further information from French
authorities. You may also contact the International Affairs Specialist to whom this matter is
assigned,
by e-mail at
or by telephone at
EFTA00023111

=== Page 3 ===
3
Both the Office of International Affairs and law enforcement authorities in France
appreciate your assistance in this international criminal matter relating to
Sincerely,
Director
Office of International Affairs
By:
Justice Attaché
Attachments:
Mutual Legal Assistance Request (in French and English)
Cc:
EFTA00023112


c1: EFTA00022331
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022331.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: RE: Epstein search warrant documents
Date: Tue, 02 Jun 2020 18:17:27 +0000
Only thing I still need for the SW is a list of the location in the house where each item was recovered, which I believe
and
were going to put together. So this is all I need from
From:
Sent: Monday, June 1, 2020 4:10 PM
To:
Cc:
Subject: FW: Epstein search warrant documents
I confess I'm having a hard time tracking the updates to this - but in particular,
do you now have what you need
for the updated SW? Or still no? Thanks for helping with this as you can probably tell from my emails today, I'm going
a little nuts just trying to drag the FBI toward any usefulness with the financials and electronics
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial numbers.
Any questions, let me know.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
EFTA00022331

=== Page 2 ===
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of information
we need is the serial number, or some other specific identifier, ideally for each device but at least for any device that there
is more than one of the same thing. So for example, we need to be able to somehow differentiate the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the USVI
spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the USVI
list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to reproduce
all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we aren't able to
match any of the prior productions to specific devices - so if we're able to match them up by Bates number now, that
might work, but otherwise I think it makes sense for us to get everything. But let us know if any issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I could to
convey the information. If you are confused by anything, please let me know. In the column for approximate
size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I put what load
file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If there is no entry
in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't have as well as an
iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to beef them up. I will
get you the Island stuff tomorrow.
FBI NY CART Coordinator
EFTA00022332

=== Page 3 ===
Senior Examiner
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any FBI
tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which both
we and the agents can access. We're required to have the files in a format that we can produce them to defense counsel.
I've done that in many other cases and it hasn't previously been an issue. My understanding from
is that the best
way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will process-by which
I just mean converting into file formats that are loadable onto Relativity. It doesn't really have anything to do with the
taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents earlier
this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9. Again, I
understand from
that the best way forward is to just get copies of the materials in their original formats, which I
understand will be segregated and designated by device. That should work for us! I was just trying to understand the
approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
-
is
(USANYS) [Contractor]
Cc:
is
)
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was
already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
EFTA00022333

=== Page 4 ===
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece
by piece as things are processed, I was unaware that you didn't want to review as things were processed, that
you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a differentiation of
methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
)
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just basically
sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago, but
regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that
means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
is
Cc:
is
Subject: RE: Epstein search warrant documents
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
is
EFTA00022334

=== Page 5 ===
Cc:
is
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it on
our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data and
where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and send
it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
BYRNE,
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
EFTA00022335

=== Page 6 ===
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review the
returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
in
)
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
BYRNE,
>;
>;
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you.
If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks-it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
i
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
BYRNE,
is
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems to
do so.
Also,
, please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
EFTA00022336

=== Page 7 ===
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're waiting
on that list to be able to do an updated search warrant on all of those devices. Please let us know the current timeline -
and also the current timeline on producing the results from those August and September searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months from our call, which
would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
)
is
(USANYS)
is
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
is
)
>;
BYRNE,
is
)
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
) [mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>; BYRNE,
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
(NY) (FBI)
is
EFTA00022337

=== Page 8 ===
>;
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
BYRNE,
y
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Are you available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
BYRNE,
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
EFTA00022338

=== Page 9 ===
Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers
and no way to match up anything-that is, even if we were to try to go hunt down every individual large file in the
native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get
a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million
documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
)
is
BYRNE,
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
in
(USANYS)
is
(NY) (FBI)
in
(USANYS)
Cc:
(USANYS) [Contractor]
is
>; BYRNE,
i
=
in
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
EFTA00022339

=== Page 10 ===
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
is
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
BYRNE,
is
)
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
)
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
)
>;
BYRNE,
i
)
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think FBI
was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to be
able to review them as well.)
many thanks,
EFTA00022340

=== Page 11 ===
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
is
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
BYRNE,
i
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
>; BYRNE,
is
is
Subject: RE: Epstein search warrant documents
EFTA00022341

=== Page 12 ===
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
EFTA00022342


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=== Page 1 ===
From:
To:
Cc
:
Subject: Re: bail
Date: Mon, 01 Mar 2021 19:07:51 +0000
Thank you.
Sent from my iPhone
On Mar 1, 2021, at 1:10 PM,
wrote:
Hi
We wanted to let you know that Ghislaine Maxwell has submitted a third motion for bail. We currently anticipate that
this motion will be resolved on the papers, but we will let you know if a hearing is scheduled.
Best,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York NY 10007
EFTA00021552


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=== Page 1 ===
From: Bruce Barket
To:
Cc:
"tonyricco
"Michael Bachrach
Subject: Re: proposed schedule.
Date: Sat, 21 Sep 2019 10:53:27 +0000
Unfortunately Friday does not work. How about the 30th or the 2nd?
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
Garden City, NY 11530
Barket Epstein.com
On Sep 20, 2019, at 9:15 PM,
wrote:
We are free next Friday afternoon if that works for you all.
Assistant U.S. Attorney
On Sep 20, 2019, at 12:16, Bruce Barket
wrote:
I think we will be ready to propose a schedule sometime early next week. Is there a day and time when you can meet
to discuss? We will send you a proposed briefing schedule ahead of the meeting. I hope to have ours finalized no later
than Tuesday.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
, Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not
clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
EFTA00021694


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=== Page 1 ===
From:
To:
)"
Cc:
Subject: RE: travel approval request
Date: Thu, 13 Feb 2020 18:56:50 +0000
Inline-Images: image001.jpg; image002.png
Hi,
Any Flights denoted by CA, YCA or Govt. DG are approved.
Thanks
From:
Sent: Thursday, February 13, 2020 1:56 PM
To:
is
Cc:
Subject: RE: travel approval request
Thanks
for clarifying the travel procedure to
please let me know if the fully refundable flight option I
sent to you in the previous email is okay and l'll continue with your booking. Note, the return flight on 2/20 you chose is
also not refundable, so I'm looking into other options for that flight as well. I'll send you those options shortly.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Thursday, February 13, 2020 1:51 PM
To:
)
Cc:
Subject: RE: travel approval request
We steer away from penalty flights in all instances. The change fees & cancellation risk is rarely ever worth it. Most
penalty fees are $300.
In the booking screen always scroll down and set the travel preferences for fare type preference to "unrestricted coach"
That way the penalty fares won't even show up in your search.
EFTA00021133

=== Page 2 ===
.
From
. To
* Depart
. Time
mm/dd/yy
Leaves at
Select time
.
Return
.
Time
mm/dd/yy
Leaves at
Select time
Advanced search
Class of Service Preference:
Coach
Lowest available including Penalty fares.
Unrestricted
1st Airline Preference:
From:
Sent: Thursday, February 13, 2020 1:48 PM
To:
i
Cc:
>;
-
Subject: RE: travel approval request
Is it a requirement that our domestic flights be refundable? I knew that was true for international flights but I thought we
could book nonrefundable flights traveling domestically?
From:
Sent: Thursday, February 13, 2020 1:46 PM
To:
)
is
Cc:
is
Subject: RE: travel approval request
Importance: High
the Delta departing flight you chose leaving LGA at 9:00am, arriving in Pensacola, FL at 12:49pm is not refundable, so
you'll need to choose another flight option. While checking out your flight options, I found a flight that will get you into
Pensacola, FL around the same time as your preferred option that's fully refundable. The difference is that the flight
leaves at 8:11am instead of 9:00am. I've placed the departing flight below for your review.
American Airlines
Contract carrier
Feb 19
ew York, NY (LGA), 8:11 AM
harlotte, NC (CLT), 10:35 AM
3 miles
EFTA00021134

=== Page 3 ===
A 1252
bach Lowest available including Penalty fares.
rbus A319
eview seat map
Layover (55m)
Charlotte, NC (CLT)
American Airlines
Contract carrier
Feb 19
harlotte, NC (CLT), 11:30 AM
ensacola, FL (PNS), 12:23 PM
0 miles
5298 (Operated by PSA AIRLINES AS AMERICAN
AGLE)
bach Lowest available including Penalty fares.
RJ900
eview seat map
Top of Form
All available fares for Option 28
$161.70
CA
Govt contract fare limited availability
Bottom of Form
Please let me know if you would like me to reserve this flight instead and I'll continue with your reservation. Thanks as
always.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
)
Sent: Thursday, February 13, 2020 1:26 PM
To:
is
Cc:
is
)
<
Subject: RE: travel approval request
Apologies for the slight delay yesterday on this travel, we had a witness scheduling issue so the travel will be a day later
than originally anticipated. The city is Pensacola, Florida, and it will be me and
(rather than
and
).
if you could please book me on the following flights:
Feb. 19: Delta, LGA to PNS, 9:00 a.m. (arriving 12:49 p.m.)
Feb. 20: Delta, PNS to LGA, 4:06 p.m. (arriving 9:41 p.m.)
And the following hotel, for the night of Feb. 19:
-
Hilton Garden Inn (listed in E2 as "HGI PENSACOLA AIRPORT MEDICAL")
We will also need a conference room at the Hilton Garden Inn for February 19, starting at 5:00 p.m. for three hours (or for
the entire day, if that's the only way they'll do it).
Please let us know if any questions or issues, and thanks as always.
EFTA00021135

=== Page 4 ===
From:
Sent: Wednesday, February 12, 2020 09:02
To:
is
i
i
Cc:
Subject: Re: travel approval request
Hi,
Which specific city will the hotel be in?
If
could push the travel authorizations thru to
& I today, that would be great As well as sending the
conference room payment request to Nick Siu.
Remember to take the FL tax exempt form along with you.
Thanks
Sent from my iPhone
On Feb 12, 2020, at 6:43 AM,
wrote:
Approved
Sent from my iPad
On Feb 11, 2020, at 7:53 PM,
)
wrote:
Similar to prior requests in connection with the Epstein investigation (2018R01618),
and I would like to please
request permission for the two of us to travel next week for an interview of a witness in Pensacola, Florida on 2/19.
We'd plan to fly down on 2/18 and fly back on 2/19. Also, similar to prior requests, we'd like to request approval to get
a conference room on 2/19.
Thank you,
From:
Sent: Tuesday, January 21, 2020 2:56 PM
To:
Cc:
is
is
is
is
Subject: RE: travel approval request
Approved
From:
Sent: Tuesday, January 21, 2020 2:49 PM
To:
EFTA00021136

=== Page 5 ===
Cc:
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), but with an added international
element, we'd like to please request permission for the team to travel next week for an interview near Stockholm,
Sweden, next week on January 29th and/or 30th. We expect to be traveling, respectively, some combination of the
27th (overnight) to the 31st, depending on when the interview ends up being scheduled, and we'll put final dates on
our formal applications. Also similar to prior trips, we'd like to request approval to get a conference room for one of
those days at a hotel for the interview itself.
Also based on our discussion earlier we'll be mindful of looking for domestic (or domestic-flagged) carrier flights, as
well as the costs of any alternatives, in looking at possible specific bookings. Thanks as always for your help and input
on that.
thank you,
From:
Sent: Wednesday, December 11, 2019 09:58
To:
Cc:
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16
and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior
trips, we'd like to request approval to get a conference room for one of those days.
thank you,
From:
Sent: Tuesday, November 05, 2019 16:53
To:
Cc:
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be
traveling, respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip).
thanks,
EFTA00021137

=== Page 6 ===
From:
Sent: Tuesday, October 22, 2019 13:55
To:
>
Cc:
is
>;
is
(
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel on that Monday for the interview, please.
thanks very much,
From:
Sent: Wednesday, June 12, 2019 14:51
To:
>
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no
later than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
,
as previously. And also same as last time, we'd like to ask permission to reserve a conference
room at the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling
allows).
EFTA00021138

=== Page 7 ===
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will
either be me and
or
and
,
but we wanted to ask for permission now either way so we weren't
doing it super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
)
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors
for sexual activity,
and I would like to please request permission to travel for approximately three days next
week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday
night and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West
Palm Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return
on Saturday.
Please let us know if any other information would be helpful, and thanks as always.
EFTA00021139

=== Page 8 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00021140


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=== Page 1 ===
From:
)"
To: "Weinstein, Marc A."
Andrew Tomback
Cc:
)"
)"
Subject: RE: SDNY investigation, re: estate
Date: Fri, 17 Jul 2020 22:26:45 +0000
Marc, Andy,
Following up on our conversation yesterday, we wanted to briefly confirm a few things we discussed and also respond to
your question. To reiterate, we agree that your plan with respect to the materials you have identified in the New York
residence makes sense, i.e., to have the photographs scanned and then produced to us in electronic format. To the extent
we need any originals of materials initially produced electronically in that fashion, we will of course follow up.
Additionally, and related, to the extent there are materials that are more conducive to being produced in their original
format, such as the photo book you mentioned specifically, we can receive those in hard copy. As a general matter, I think
those would only be materials that cannot be individually scanned or copied without removing them from some relevant
contextual placement or arrangement; that said, if you or your vendor believes individual items require a judgment call,
please feel free to check in with us on any specific questions.
Regarding loose, unlabeled discs, we are not requesting their production at this time. If there are discs that are labeled in
some way that indicates or suggests they contain photos in particular, please let us know, as we likely would request
production of those items. For discs that do not fit that description, we assume those will be retained by the estate in any
event, but please let us know if that is incorrect, or if at some subsequent point that status is expected to change.
Finally, I know we raised the issue of privilege for the first time on our call, so I just want to reiterate that the Government
is in no way requesting any waiver, but rather advising you and your clients that we may at some point in the coming
weeks seek a formal position on whether the estate intends to waive, on behalf of Jeffrey Epstein, any attorney-client
privilege for purposes of discovery review and production in connection with United States V. Maxwell, 20 Cr. 330 (AJN).
Prior to the Government seeking and obtaining the estate's position on such a question, we will assume that the privilege
remains applicable and in effect, and we will proceed with our usual practices in review and production of discovery in
that case, including producing materials obtained in connection with the Epstein investigation following any necessary
taint / privilege review.
Thank you again for speaking with us, and we will continue to be in touch with any other relevant issues or questions.
best,
Assistant U.S. Attorney
Southern District of New York
EFTA00020773


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=== Page 1 ===
STATE
STATES
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
June 21, 2021
BY EMAIL
Dana Bennett
Lockheed Martin Co.
6801 Rockledge Drive
Bethesda, MD 20817
RE:
Court Subpoena
Dear Ms. Bennett:
Please see the attached Court subpoena. You can reach me at the below phone number or
at
if you have any questions. Thank you for your cooperation in
this matter.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
Assistant United States Attorney
EFTA00022026


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: FW: US V. Maxwell, 20 Cr. 330 (AJN) - Letter Motion to file Reply Brief
Date: Mon, 22 Nov 2021 15:08:28 +0000
Attachments: 2021-11-22 Letter Motion_re_Daubert_reply.pdf_Ex._C.pdf;
Mot_to_Exclude
Reply_Br._final_[unredacted].pdf
- the brief was fantastic and very convincing. Thank you so much again for your help with this. We'll definitely let
you know what happens.
From:
)
Sent: Monday, November 22, 2021 10:07 AM
To: Nathan NYSD Chambers
Cc:
is
is
>; Christian Everdell
>;
; Jeff Pagliuca
>; Laura Menninger
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Letter Motion to file Reply Brief
Chambers,
Attached please find a letter motion to file a reply in support of the Government's motion to preclude the testimony of Dr.
Attached also are the proposed reply brief and exhibit. The Government submits these documents temporarily
under seal.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00023034


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=== Page 1 ===
From:
"
)"
To:
"
]"
Cc:
"
(USANYS)"
Subject:
Date: Sun, 03 Oct 2021 21:39:21 +0000
Embedded: FW:
.msg
Hi
Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00023455


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=== Page 1 ===
From:
To:
Subject: RE: Daily Beast has it
Date: Sun, 07 Jul 2019 01:40:34 +0000
Importance: Normal
Will do thanks
From:
Sent: Saturday, July 06, 2019 21:40
To:
Subject: Re: Daily Beast has it
Yeah think you should too
Sent from my iPhone
On Jul 6, 2019, at 9:38 PM,
wrote:
The FBI already called Kaplan Hecker without our knowledge, earlier (along with two other victims and their attorneys).
l'll call her as well, though.
From:
Sent: Saturday, July 06, 2019 21:37
To:
Subject: Re: Daily Beast has it
I think you should reach out to
tonight
Sent from my iPhone
On Jul 6, 2019, at 9:10 PM,
wrote:
Yeah they're literally just leaking the press release -
The case is being handled by the Public Corruption Unit of the Southern District of
New York, with assistance from the district's human-trafficking officials and the
FBI.
and the sealed indictment -
according to details of the arrest and indictment shared by two officials.
From:
Sent: Saturday, July 06, 2019 21:08
To:
Cc:
EFTA00021300

=== Page 2 ===
Subject: Re: Daily Beast has it
And now is reporting that it's our unit
Sent from my iPhone
On Jul 6, 2019, at 8:06 PM,
wrote:
https://www.thedailybeast.com/jeffrey-epstein-arrested-for-sex-trafficking-of-minors-source
FBI is leaking the content of the indictment.
Assistant U.S. Attorney
Southern District of New York
EFTA00021301


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=== Page 1 ===
From:
)"
To:
Subject: Re: post-arrest statements
Date: Fri, 19 Jul 2019 19:14:58 +0000
Inline-Images: Outlook-1510171437.png; Outlook-1510171974.jpg
Received, thank you.
Sent from my iPhone
On Jul 19, 2019, at 3:09 PM,
wrote:
Detective
NYPD Detective Bureau Child Exploitation/ Human Trafficking Task Force
N.Y. FBI Squad C20
Office
Desk
Fax
Cell
<Outlook-1510171437.png><Outlook-1510171974.jpg>
From:
Sent: Friday, July 19, 2019 12:46:53 PM
To:
Cc:
is
^
Subject: post-arrest statements
EFTA00020932

=== Page 2 ===
Hi
Could you please email me your notes and report of Epstein's post-arrest statements? Thanks.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
<Photocopy of working copy Epstein Arrest Folder.pdf>
DEPARTMENT OF JUSTICE
FEDERAL
D3
EFTA00020933


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: FW: 2018 Judge Sweet Opinion Right of Public Access Judicial Document
V
Maxwell.docx
Date: Wed, 17 Oct 2018 14:43:38 +0000
Importance: Normal
Attachments:
FYI
From:
(USANYS)
Sent: Wednesday, October 17, 2018 10:32 AM
To:
(USANYS)
is
(USANYS)
Subject: 2018 Judge Sweet Opinion Right of Public Access Judicial Document
V Maxwell.docx
Here's a fairly recent opinion that I just read about in the NYLJ.
EFTA00020540


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=== Page 1 ===
Event: Accepted: Epstein Team Meeting
Start Date: 2019-10-30 20:30:00 +0000
End Date: 2019-10-30 21:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-10-30 15:34:48 +0000
Date Modified: 2019-10-30 15:34:48 +0000
Priority: 5
DTSTAMP: 2019-10-30 15:21:13 +0000
Attendee:
EFTA00021289


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=== Page 1 ===
Comments
Date[mmddyyyy]
Box Number
Form Type = "CITADEL"
06252008
Doc Code Doc Code Doc Code Doc Code Account Numbers
942
Account Numbers
GOVERNMENT
EXHIBIT
508
$2 20 Cr. 330 (AJN)
Confidential Treatment Requested by
JPM-SDNY-00001839
JPMorgan Chase
EFTA00020596

=== Page 2 ===
The Morgan Account
Account type
Account number
/
/
Asset
Month
Date
Year
Account type
(CIRCLE ONE BELOW)
Account number
Social Security no. /Tax D no. Passport no.
Deposi
Account title
BAC 1
Jeffrey E Epstein
All Accountholders/Signers must sign this Signature Form exactly as the checks/Instructions will be signed.
Print (Accountholder/Signer, Trustee, Custodian, Director, etc.)
Title
If facsimile signature, check box
516%
Ghislaine Maxwell
HERE
X
R If facsimile signature, check box
Print (Joint Accountholder/Signer, Trustee, Custodian, Director, etc)
Title
SIGN
HERE
X
Print (other)
Title
If facsimile signature, check box
SIGN
HERE
X
Print (other)
Title
If facsimile signature, check box
SIGN
III
X
Is this an existing account?
yes
no
If yes, does this card replace all other cards against this account?
yes
no
Signing instructions (Please use back of card If necessary.)
SiNGLY
194
Confidential Treatment Requested by
JPM-SDNY-00001840
JPMorgan Chase
EFTA00020597

=== Page 3 ===
JPMorgan Account Durable Power of Attorney Form
JPMorgan
Private Bank
A Durable Power of Attorney is an important legal document. By Signing this Durable Power of Attorney, I am
authorizing another person (my "Agent") to act for me. I acknowledge these important facts:
My agent (notary public) has no duty to act unless my agent and I agree otherwise in writing.
The power I give my agent will continue to exist until I revoke it, or until my death. You may continue to rely on this Power of
Attorney until you receive written notification of my revocation or death.
The powers I give my agent will continue to exist even if I can no longer make my own decisions respecting the management of
my property.
I can amend or change this durable Power of Attorney only by executing a new Durable Power of Attorney or by executing an
amendment through the same formalities as an original. I have the right to revoke or terminate this durable Power of Attorney
at any time, so long as I am competent.
This durable Power of Attorney must be dated and must be acknowledged before a notary public.
I should read this Durable Power of Attorney carefully and obtain the assistance of an attorney or other qualified person If I do
not understand it.
"I," "me," or "Account holder" mean each Individual signing this document.
This authorization shall apply to all accounts at JPMorgan (as defined below in Subdivision A) over which I have signing
authority unless one of the following boxes is checked, in which case it shall apply only to the designated accounts:
a
Accounts
titled:
EPSTEIN JEFFREY
X Account numbers
I acknowledge my agent and notary public may utilize any Web site provided by JPMorgan (the "Site") via the Internet 24 hours a
day, seven days a week to act in the manner I indicate in the Subdivisions below provided the functionality is available via the Site.
Transactions requiring more than one signature to complete may not be available via the Site. Site usage by any Authorized Person
is subject to the agreements and disclosures detailed on the Site.
I hereby authorize HARRY BELLER
and
to act in the
manner indicated in the section titled "Specimen Signatures," as my agent and notary public (each, the "Atterney," and collectively,
the "Attorneys") with full power and authority on my behalf.
Please initial the line to the left of each of the following lettered Subdivisions as to which an agent will be given
authority. If the line to the left of a lettered Subdivision is not initialed, no authority will be granted for matters
included in that Subdivision. Alternately, the letter corresponding to each power to be granted may be written or typed
on the blank line in Subdivision B, and the line to the left of Subdivision B must be initialed in order to grant each of the
powers so indicated. (Checks or other marks may be substituted for initial(s)).
Operation of All Accounts
A. To open and operate all of my banking, brokerage, asset, custody, Investment management and other accounts
at one or more offices or subsidiaries or affiliates of JPMorgan Chase & Co. (individually or collectively, "3PMorgan"),
including J.P. Morgan Securities Inc., and to engage in transactions and activities identified in Subdivisions C
through M below, unless the Account holder, in writing, imposes limitations on such activities;
Specified Powers
B. To engage in each of the matters identified in Subdivisions lettered
Banking, Custody, Brokerage; Related Pledges
X
C. To operate any one or more deposit, custody or brokerage accounts in my name or any other name including
the name of the Attorney; to deposit money, checks, notes, and other instruments for the payment of money,
stocks, bonds, mortgages and other securities and property; to write or endorse as the case may be any of these
Instruments with my name for the purpose of cashing or depositing them or paying them to other persons,
including the Attorney; to write and sign checks and other instruments to be paid by me; to give orders for the
withdrawal, transfer or other use of money on deposit in my name, and grant JPMorgan a security interest in such
property otherwise available to me; to borrow money from JPMorgan secured by property held in accounts in my
name; to engage In foreign exchange transactions in any form with JPMorgan.
To receive and sign trading confirmations, advices, and statements or duplicate statements.
To execute and issue all necessary instruments for transfer of securities out of my name or out of any other
name(s) and into the name of any nominee of JPMorgan or into any other name(s);
11/1/07
JPMorgan Use Only
Title
SPN
CAS
1 of 3
Banker/Investor
11/06 US942
3pop.
Confidential Treatment Requested by
JPM-SDNY-00001841
JPMorgan Chase
EFTA00020598

=== Page 4 ===
JPMorgan Account Durable Power of Attorney Form
JPMorgan
Private Bank
Banking, Custody, Brokerage; Related Pledges (continued)
X
D. To purchase and borrow (on secured or unsecured basis) from, sell (including short sales in margin account),
and lend (on a secured or unsecured basis) to, and to otherwise enter into transactions of any kind with JPMorgan
with respect to any and all securities with financial instruments whatsoever in which JPMorgan may deal, broker or
act as counterparty from time to time, including (without limitation) stocks, bonds, debentures, notes, warrants,
loans and loan participations, mutual funds, unit trusts, real estate, investment trusts, other types of pooled
interest funds and commingled investment vehicles (including hedge funds), limited partnership interests, limited
liability company interests, forward contracts, option or futures contracts, repurchase (or reverse repurchase)
transactions, securities lending, or any other certificates or evidences or indebtedness or interest of any and every
kind whatsoever, whether publicly or privately offered, secured or unsecured, and any other financial instruments;
to enter into any derivative transactions with respect to the foregoing, including over the counter equity derivatives
and structured transactions (including, but not limited to options, swaps, collars, caps and floors); to pledge any
funds or instruments for the purposes of securing my obligations with respect to the foregoing; to enter into
foreign exchange or foreign currency transactions in any form; and to enter into, complete and execute
agreements and to take other actions, including but not limited to signing reconcilements of accounts and other
documents to carry out the purpose of this resolution; to vote in person or by proxy;
Banking, Custody and Brokerage Accounts - limited power (transfers to other JPMorgan Accounts only)
X
E. To withdraw monies or funds or to sell or exchange stocks, bonds, options or other securities and property and
transfer such monies, funds or proceeds of the sale or exchange only to another account at Morgan over which I
have signing authority;
Custody and Brokerage Accounts - limited powers (securities against payment only)
F. To buy OF sell securities or any other property described in Subdivision D above in which I may deal or which I
may hold against receipt of payment to us only;
Investment Management Account
G. To give any instruction with respect to any Investment Management Account; to modify the Asset Allocation
Strategy for any Investment Management Account; to deposit funds, securities or other property to any
Investment Management Account or to give orders for the withdrawal, sale, exchange, or other disposition
(collectively, "Disposition") of any funds, securities or other property from any Investment Management Account, in
accordance with any instructions as the Attorney may give; to give orders for the payment or other Disposition of
any income or proceeds of any Investment Management Account, or proceeds of any sale or other Disposition of
securities and other property in the Account;
Investment Management Account - limited power (transfers to other JPMorgan accounts only)
H. To deposit funds, securities or other property to any Investment Management Account or to give orders for the
withdrawal, sale, exchange, or other disposition (collectively "Disposition") of any funds, securities or other
property from any Investment Management Account, in accordance with any instructions as the Attorney may give,
but proceeds of any such Disposition will be credited only to an account of mine at JPMorgan over which I have
signing authority;
Mutual Funds
I. To buy, exchange, reinvest or redeem shares of beneficial interest in any mutual funds in accordance with your
terms and conditions for my account and risk and in my name; to give instructions with respect to any of the
above-described actions; to give orders to make payment to any party, including the Attorney;
Credit Pledge Security
3. To borrow money from JPMorgan, and to apply for and secure, from JPMorgan any forms of credit; to enter into any
notes or agreements with JPMorgan which result in direct or contingent liabilities to me, with or without security, to
negotiate or discount any instruments, negotiate otherwise with or through JPMorgan; to repay, discharge, settle,
adjust, compromise or liquidate any loan, obligation or liability; to pledge, mortgage, hypothecate, assign, transfer,
deposit or deliver, with or to JPMorgan, as security or as additional or substitute security, or for sale or other
disposition, stocks, bonds and other securities, deposit accounts, book accounts, chooses in action and any other
tangible or intangible property, and to make substitutions thereof, and to receive any thereof upon the release or
surrender thereof; to sign, execute and deliver any and all stock powers, bond powers, proxies, assignments, trust
receipts, pledge and security agreements and other contracts and instruments in writing, with or without seal; to
authorize, give, make, procure, accept and receive monies, payments, property, notices, demands, vouchers,
receipts, releases, compromises and adjustments; to waive notices, demands, protests and authorize and execute
waivers of every kind and nature; to enter into, make, execute, deliver and receive written agreements,
undertakings and instruments of every kind and nature;
JPMorgan Use Only
Title
SPN
CAS
2 of 3
Banker/Investor
11/06 US942
Confidential Treatment Requested by
JPM-SDNY-00001842
JPMorgan Chase
EFTA00020599

=== Page 5 ===
JPMorgan Account Durable Power of Attorney Form
JPMorgan
Private Bank
Account Administration
K. To inquire about and receive information relating to any Account, including but not limited to, balance,
X
withdrawal, payment and deposit information;
L. To give instructions for the withdrawal, internal and external transfer of money to an account in my name,
X
individually or jointly, and for which we are a, or it is my, legal or beneficial owner.
X
M. To pick up or otherwise receive mail or other information held by JPMorgan, subject to the terms of applicable
agreements with JPMorgan and to applicable law and regulation.
JPMorgan is entitled to rely on this Power of Attorney until JPMorgan actually receives my written revocation. A revocation will not
affect or impair any liability or obligation arising out of or related to the exercise by an Attorney of any power granted herein before
JPMorgan's actual receipt of a revocation. Each Attorney is authorized to act on my behalf, in the same manner and with the same
force and effect as If I had given any instruction myself, and to do anything necessary or incidental to or to effect such instructions.
This Power of Attorney shall not be affected by my subsequent disability, incapacity or incompetence or that of any other person
signing below. My death shall not affect the Power of Attorney granted by any other Account holder signing below. This Power of
Attorney shall be deemed made under the law of the State of New York for all purposes, including (without limitation), construction,
validity, and effect, and shall be governed by such law. I give each Attorney full authority to do anything he or she considers
necessary and proper to be able to act in accordance with this Power of Attorney, even If it is for the Attorney's own benefit, all as if
I were personally doing it. I hereby ratify and confirm everything that my Attorney has done or shall do by virtue of this Power of
Attorney.
Specimen Signature (s) of Attorney(s)
Each attorney shall sign as follows: Two or more attorneys may each act singly unless this box is checked
in
which
case
any two must act jointly, except my attorneys shall always act singly for brokerage trading transactions.
Signature (altorney-in-fact)
HARRY BELLER
11/1/07
Signature (attorney-in-fact)
Print Name
Date
Print Name
Date
Address
Address
NEW YORK
City
City
NY
10022
State
Zip
State
Zip
Signature(s)
IN WITNESS WHEREOF, I have hereunto set my hand and seal this on the
day of
20
12 Signature (Accountholder)
Signature (Accountholder)
JEFFREY E. EPSTEIN
Print Name
Date
11/1/03
Print Name
Date
Address
Address
NEW YORK
City
City
NY
10022
State
Zip
State
Zip
Notarization is required for accountholders.
STATE OF:
NY
COUNTY OF:
NY
I
certify
that
JEFFRey Epstein
it known or satisfactory proven to me the to be the individual who
signed the foregoing Power of Attorney, appeared before me on this the
14
day
of
Namember
2027
and
acknowledged that he/she/they executed the foregoing Power.
Signature Hamile (netary public)
11/1/07
HARRY I BELLER
Date
Print Name and Title
My commission expires:
HARRY 1. BELLER
Notary Public, State of New York
JPMorgan Use Only
No. 018E4853924
Banker/Investo Title Qualified in Rockland
SPN
CAS
3 of 3
Commission Expires Feb. County 10
11/06 US942
Confidential Treatment Requested by
JPM-SDNY-00001843
JPMorgan Chase
EFTA00020600

=== Page 6 ===
The Morgan Account
JPMorgan Private Bank
Durable Power of Attorney
MORGAN USE ONLY
US942 7/04
Title Jeffrey E Epstein
SPN
Primar
accAp
Account Number
A DURABLE POWER OF ATTORNEY is AN IMPORTANT LEGAL DOCUMENT. BY SIGNING THIS DURABLE POWER OF ATTORNEY. I AM
AUTHORIZING ANOTHER PERSON (MY "AGENT") TO ACT FOR ME. 1 ACKNOWLEDGE THESE IMPORTANT FACTS:
My agent (attorney-in-fact) has no duty to act unless my agent and I agree otherwise in writing.
The powers I give my agent will continue to exist until I revoke it, or until my death. You may continue to rely on this Power of Attorney until you
receive written notification of my revocation or death.
The powers I give my agent will continue to exist even if I can no longer make my own decisions respecting the management of my property.
I can amend or change this durable Power of Attorney only by executing a new durable Power of Attorney or by executing an amendment through
the same formalities as an original. I have the right to revoke or terminate this durable Power of Attorney at any time, so long as I am competent.
This durable Power of Attorney must be dated and must be acknowledged before a notary public.
I should read this durable Power of Attorney carefully and obtain the assistance of an attorney or other qualified person if I do not understand it.
"I," "me," or "Accountholder" mean each individual signing this document.
This authorization shall apply to all accounts at Morgan (as defined below in Subdivision A) over which I have signing authority unless one of the
following boxes is checked, in which case it shall apply only to the designated accounts:
Accounts Titled:
Account Numbers:
I acknowledge my agent and attorney-in-fact may utilize any website provided by Morgan (the "Site") via the Internet 24 hours a day, seven days a week
to act in the manner I indicate in the Subdivisions below provided the functionality is available via the Site. Transactions requiring more than one
signature to complete may not be available via the Site. Site usage by any authorized person is subject to the agreements and disclosures detailed on the
Site.
I hereby authorize each Ghislaine Maxwell
and
to act, in the manner indicated in the section titled "Specimen Signatures," as my agent and attorney-in-fact (each, the "Attormey," and collectively, the
"Attomeys") with full power and authority on my behalf:
PLEASE INITIAL THE LINE TO THE LEFT OF EACH OF THE FOLLOWING LETTERED SUBDIVISIONS AS TO WHICH AN AGENT WILL BE
GIVEN AUTHORITY. IF THE LINE TO THE LEFT OF A LETTERED SUBDIVISION IS NOT INITIALED, NO AUTHORITY WILL BE GRANTED
FOR MATTERS INCLUDED IN THAT SUBDIVISION. ALTERNATELY, THE LETTER CORRESPONDING TO EACH POWER TO BE GRANTED
MAY BE WRITTEN OR TYPED ON THE BLANK LINE IN SUBDIVISION B, AND THE LINE TO THE LEFT OF SUBDIVISION B MUST BE
INITIALED IN ORDER TO GRANT EACH OF THE POWERS so INDICATED. (CHECKS OR OTHER MARKS MAY BE SUBSTITUTED FOR
INITIAL(S)).
OPERATION OF ALL
A. To open and operate all of my banking, brokerage, asset, custody, investment management and other
ACCOUNTS
accounts at one or more offices or subsidiaries or affiliates of J.P. Morgan Chase & Co. (individually or
collectively, "Morgan"), including J.P. Morgan Securities Inc., and to engage in transactions and activities
identified in Subdivisions C through M below, unless the Accountholder, in writing, imposes limitations on
such activities;
SPECIFIED POWERS
B. To engage in each of the matters identified in Subdivisions lettered
10/12/2004
Page I of 4
942
Confidential Treatment Requested by
JPM-SDNY-00001844
JPMorgan Chase
EFTA00020601

=== Page 7 ===
The Morgan Account
JPMorgan Private Bank
Durable Power of Attorney
MORGAN USE ONLY
US942 7/04
Title Jeffrey E Epstein
SPN
Prima
Account Number
BANKING, CUSTODY,
C. To operate any one or more deposit, custody or brokerage accounts in my name or any other
BROKERAGE: RELATED
name including the name of the Attorney; to deposit money, checks, notes, and other instruments for the
PLEDGES
payment of money, stocks, bonds, mortgages and other securities and property; to write or endorse as the case
may be any of these instruments with my name for the purpose of cashing or depositing them or paying them to
other persons, including the Attorney: to write and sign checks and other instruments to be paid by me; to give
orders for the withdrawal, transfer or other use of money on deposit in my name, and grant Morgan A security
interest in such property otherwise available to me; to borrow money from Morgan secured by property held in
accounts in my name, to engage in foreign exchange transactions in any form with Morgan;
To receive and sign trading confirmations, advices, and statements or duplicate statements;
To execute and issue all necessary instruments for transfer of securities out of my name or out of any other
name(s) and into the name of any nominee of Morgan or into any other name(s);
BANKING, CUSTODY,
D. To purchase and borrow (on a secured or unsecured basis) from, sell (including short sales in a margin
BROKERAGE: RELATED
account), and lend (on a secured or unsecured basis) to, and to otherwise enter into transactions of any kind
PLEDGES (CONT'D.)
with Morgan with respect to any and all securities and financial instruments whatsoever in which Morgan may
deal, broker or act as counterparty from time to time, including (without limitation) stocks, bonds, debentures,
notes, warrants, loans and loan participations, mutual funds, unit trusts, real estate, investment trusts, other
types of pooled interest funds and commingled investment vehicles (including hedge funds), limited partnership
interests, limited liability company interests, forward contracts, option or futures contracts, repurchase (or
reverse repurchase) transactions, securities lending, or any other certificates or evidences of indebtedness or
interest of any and every kind whatsoever, whether publicly or privately offered, secured or unsecured, and any
other financial instruments; to enter into any derivative transactions with respect to the foregoing, including
over the counter equity derivatives and structured transactions (including, but not limited to options, swaps,
collars, caps and floors); to pledge any funds or instruments for the purposes of securing my obligations with
respect to the foregoing: to enter into foreign exchange or foreign currency transactions in any form, and, to
enter into, complete and execute agreements and to take other actions, including but not limited to signing
reconcilements of accounts and other documents to carry out the purpose of this resolution; to vote in person or
by proxy.
BANKING, CUSTODY AND
E. To withdraw monies or funds or to sell or exchange stocks, bonds, options or other securities and property
BROKERAGE ACCOUNTS
and transfer such monies, funds or proceeds of the sale or exchange only to another account at Morgan over
LIMITED POWER
(TRANSFERS TO OTHER
which I have signing authority;
MORGAN ACCOUNTS
ONLY)
CUSTODY AND
F. To buy or sell securities or any other property described in Subdivision D above in which I may deal or
BROKERAGE ACCOUNTS
which I may hold against receipt of payment to me only,
LIMITED POWER
(SECURITIES AGAINST
PAYMENT ONLY)
INVESTMENT
G. To give any instruction with respect to any Investment Management Account:
MANAGEMENT ACCOUNT
To modify the Asset Allocation Strategy for any Investment Management Account;
To deposit funds, securities or other property to any Investment Management Account or to give orders for
the withdrawal, sale, exchange, or other disposition (collectively, "Disposition") of any funds, securities
or other property from any Investment Management Account, in accordance with any instructions as the
Attorney may give;
To give orders for the payment or other Disposition of any income or proceeds of any Investment Management
Account, or proceeds of any sale or other Disposition of securities and other property in the Account;
INVESTMENT
H. To deposit funds, securities or other property to any Investment Management Account or to give orders for
MANAGEMENT ACCOUNT
the withdrawal, sale, exchange, or other disposition (collectively, "Disposition") of any funds, securities or
LIMITED POWER
TRANSFERS TO OTHER
other property from any Investment Management Account, in accordance with any instructions as the Attorney
MORGAN ACCOUNTS ONLY
may give, but proceeds of any such Disposition will be credited only to an account of mine at Morgan over
which I have signing authority;
Page 2 of 4
942
Confidential Treatment Requested by
JPM-SDNY-00001845
JPMorgan Chase
EFTA00020602

=== Page 8 ===
The Morgan Account
JPMorgan Private Bank
Durable Power of Attorney
MORGAN USE ONLY
US942 7/04
Title Jeffrey E Epstein
SPN
Prim
Account Number
MUTUAL FUNDS
I. To buy, exchange, reinvest or redeem shares of beneficial interest in any mutual funds in accordance with
your terms and conditions for my account and risk and in my name, to give instructions with respect to any of
the above-described actions; to give orders to make payment to any party, including the Attorney;
CREDIT: PLEDGE
J. To borrow money from Morgan, and to apply for and secure, from Morgan any forms of credit; to enter into
SECURITY
any notes or agreements with Morgan which result in direct or contingent liabilities to me, with or without
security, to negotiate or discount any instruments, negotiate otherwise with or through Morgan, to repay,
discharge, settle, adjust, compromise or liquidate any loan, obligation or liability; to pledge, mortgage,
hypothecate, assign, transfer, deposit or deliver, with or to Morgan, as security or as additional or substitute
security, or for sale or other disposition, stocks, bonds and other securities, deposit accounts, book accounts,
choses in action and any other tangible or intangible property, and to make substitutions thereof, and to receive
any thereof upon the release or surrender thereof, to sign, execute and deliver any and all stock powers, bond
powers, proxies, assignments, trust receipts, pledge and security agreements and other contracts and
instruments in writing, with or without seal; to authorize, give, make, procure, accept and receive monies,
payments, property, notices, demands, vouchers, receipts, releases, compromises and adjustments; to waive
notices, demands, protests and authorize and execute waivers of every kind and nature; to enter into, make,
execute, deliver and receive written agreements, undertakings and instruments of every kind and nature;
ACCOUNT
ADMINISTRATION
V
K. To inquire about and receive information relating to any Account, including but not limited to, balance,
withdrawal, payment and deposit information;
fe
L. To give instructions for the withdrawal, internal and external transfer of money to an account in my name,
individually or jointly, and for which I am a legal or beneficial owner;
19
To pick up or otherwise receive mail or other information held by Morgan, subject to the terms of
agreements with Morgan and to applicable law and regulation.
Morgan is entitled to rely on this Power of Attorney until Morgan actually receives my written revocation. A revocation will not affect or impair any
liability or obligation arising out of or related to the exercise by an Attorney of any power granted herein before Morgan's actual receipt of a revocation
Each Attorney is authorized to act on my behalf, in the same manner and with the same force and effect as if I had given any instruction myself, and to do
anything necessary or incidental to or to effect such instructions.
In order to induce Morgan to act in accordance with this Power of Attorney, I agree to hold Morgan harmless from any loss or liability resulting from
acting or purporting to act in accordance with this Power of Attorney until Morgan's actual receipt of written notice of my revocation or of my death.
This Power of Attorney shall not be affected by my subsequent disability, incapacity or incompetence or that of any other person signing below. My
death shall not affect the Power of Attorney granted by any other Accountholder signing below.
This Power of Attorney shall be deemed made under the law of the State of New York for all purposes, including (without limitation), construction,
validity, and effect, and shall be governed by such law.
I give each Attorney full authority to do anything he or she considers necessary and proper to be able to act in accordance with this Power of Attorney,
even if it is for the Attorney's own benefit, all as if I were personally doing it. I hereby ratify and confirm everything that my Attorney has done or shall
do by virtue of this Power of Attorney.
SPECIMEN SIGNATURES
Each Attorney shall sign W follows: Two or more Attorneys may each act singly unless this box is checked
in
OF ATTORNEY(S)
which case any jointly,
X
Ghislaine Maxwell
Signature (Atterne) (in-Fact)
Print Name
Date
Address:
Specimen Signatures continued on following page
Page 3 of 4
942
Confidential Treatment Requested by
JPM-SDNY-00001846
JPMorgan Chase
EFTA00020603

=== Page 9 ===
The Morgan Account
JPMorgan Private Bank
Durable Power of Attorney
MORGAN USE ONLY
US042 7/04
Title Jeffrey E Epstein
SPN
Prima
Account Number
SPECIMEN SIGNATURES
OF ATTORNEY(S),
X
CONT'D.
Signature (Attorney-in-Fact)
Print Name
Date
Address:
IN WITNESS WHEREOF 1 have hereunto set my hand and seal this 12 day of october
2009
SIGN HERE
X
Signature N (Accountholder)
Jeffrey E Epstein
10/12/04
Print Name
Date
X
Signature (Accountholder)
Print Name
Date
X
Signature (Accountholder)
Print Name
Date
NOTARIZATION IS REQUIRED FOR ACCOUNTHOLDERS
STATE OF:
COUNTY OF:
I certify
that Jeffrey Eptn
. known or satisfactorily proven to me to be the individual(s) who signed
the foregoing Power of Amorney, appeared before me on this
12 day of
October 2004 and acknowledged
that he/she/they executed the foregoing Power.
Signature of Natury Public
Hang I pile
10/1/04
Print Name & Title
Date
My Commission expires:
HARRY 1. BELLER
Notary Public. State of New York
No. 018E4853924
Qualified in Rockland County
Commission Expires Feb. 17. 20.
06
Page 4 of 4
942
Confidential Treatment Requested by
JPM-SDNY-00001847
JPMorgan Chase
EFTA00020604

=== Page 10 ===
The Morgan Account
JPMorgan Private Bank
Durable Power of Attorney
MORGAN USE ONLY
US942 7/04
Title Jeffrey E Epstein
SPI
Prit
acchA
Account Number
A DURABLE POWER OF ATTORNEY is AN IMPORTANT LEGAL DOCUMENT. BY SIGNING THIS DURABLE POWER OF ATTORNEY. 1 AM
AUTHORIZING ANOTHER PERSON (MY "AGENT") TO ACT FOR ME. 1 ACKNOWLEDGE THESE IMPORTANT FACTS:
My agent (attorney-in-fact) has no duty to act unless my agent and I agree otherwise in writing.
The powers I give my agent will continue to exist until I revoke it, or until my death. You may continue to rely on this Power of Attorney until you
receive written notification of my revocation or death.
The powers I give my agent will continue to exist even if I can no longer make my own decisions respecting the management of my property.
I can amend or change this durable Power of Attorney only by executing a new durable Power of Attorney or by executing an amendment through
the same formalities as an original. I have the right to revoke or terminate this durable Power of Attorney at any time, so long as I am competent.
This durable Power of Attorney must be dated and must be acknowledged before a notary public.
I should read this durable Power of Attorney carefully and obtain the assistance of an attorney or other qualified person if I do not understand it.
"I," "me," or "Accountholder" mean each individual signing this document.
This authorization shall apply to all accounts at Morgan (as defined below in Subdivision A) over which I have signing authority unless one of the
following boxes is checked, in which case it shall apply only to the designated accounts:
Accounts Titled:
Account Numbers:
I acknowledge my agent and attorney-in-fact may utilize any website provided by Morgan (the "Site") via the Internet 24 hours a day, seven days a week
to act in the manner I indicate in the Subdivisions below provided the functionality is available via the Site. Transactions requiring more than one
signature to complete may not be available via the Site. Site usage by any authorized person is subject to the agreements and disclosures detailed on the
Site.
I hereby authorize each Ghistaine Maxwell
and
to act, in the manner indicated in the section titled "Specimen Signatures," as my agent and attorney-in-fact (each, the "Attormey," and collectively, the
"Attomeys") with full power and authority on my behalf:
PLEASE INITIAL THE LINE TO THE LEFT OF EACH OF THE FOLLOWING LETTERED SUBDIVISIONS AS TO WHICH AN AGENT WILL BE
GIVEN AUTHORITY. IF THE LINE TO THE LEFT OF A LETTERED SUBDIVISION is NOT INITIALED, NO AUTHORITY WILL BE GRANTED
FOR MATTERS INCLUDED IN THAT SUBDIVISION. ALTERNATELY, THE LETTER CORRESPONDING TO EACH POWER TO BE GRANTED
MAY BE WRITTEN OR TYPED ON THE BLANK LINE IN SUBDIVISION B, AND THE LINE TO THE LEFT OF SUBDIVISION B MUST BE
INITIALED IN ORDER TO GRANT EACH OF THE POWERS so INDICATED. (CHECKS OR OTHER MARKS MAY BE SUBSTITUTED FOR
INITIAL(S)).
OPERATION OF ALL
A. To open and operate all of my banking, brokerage, asset, custody, investment management and other
ACCOUNTS
accounts at one or more offices or subsidiaries or affiliates of J.P. Morgan Chase & Co. (individually or
collectively, "Morgan"), including J.P. Morgan Securities Inc., and to engage in transactions and activities
identified in Subdivisions C through M below, unless the Accountholder, in writing, imposes limitations on
such activities;
SPECIFIED POWERS
B. To engage in each of the matters identified in Subdivisions lettered
10/12/2004
Page I of 4
942
Confidential Treatment Requested by
JPM-SDNY-00002348
JPMorgan Chase
EFTA00020605

=== Page 11 ===
The Morgan Account
JPMorgan Private Bank
Durable Power of Attorney
MORGAN USE ONLY
US942 7/04
Title Jeffrey E Epstein
SPN
Prim
Account Number
BANKING, CUSTODY,
C. To operate any one or more deposit, custody or brokerage accounts in my name or any other
BROKERAGE: RELATED
name including the name of the Attorney; to deposit money, checks, notes, and other instruments for the
PLEDGES
payment of money, stocks, bonds, mortgages and other securities and property; to write or endorse as the case
may be any of these instruments with my name for the purpose of cashing or depositing them or paying them to
other persons, including the Attorney: to write and sign checks and other instruments to be paid by me; to give
orders for the withdrawal, transfer or other use of money on deposit in my name, and grant Morgan A security
interest in such property otherwise available to me; to borrow money from Morgan secured by property held in
accounts in my name, to engage in foreign exchange transactions in any form with Morgan;
To receive and sign trading confirmations, advices, and statements or duplicate statements;
To execute and issue all necessary instruments for transfer of securities out of my name or out of any other
name(s) and into the name of any nominee of Morgan or into any other name(s);
BANKING, CUSTODY,
D. To purchase and borrow (on a secured or unsecured basis) from, sell (including short sales in a margin
BROKERAGE: RELATED
account), and lend (on a secured or unsecured basis) to, and to otherwise enter into transactions of any kind
PLEDGES (CONT'D.)
with Morgan with respect to any and all securities and financial instruments whatsoever in which Morgan may
deal, broker or act as counterparty from time to time, including (without limitation) stocks, bonds, debentures,
notes, warrants, loans and loan participations, mutual funds, unit trusts, real estate, investment trusts, other
types of pooled interest funds and commingled investment vehicles (including hedge funds), limited partnership
interests, limited liability company interests, forward contracts, option or futures contracts, repurchase (or
reverse repurchase) transactions, securities lending, or any other certificates or evidences of indebtedness or
interest of any and every kind whatsoever, whether publicly or privately offered, secured or unsecured, and any
other financial instruments; to enter into any derivative transactions with respect to the foregoing, including
over the counter equity derivatives and structured transactions (including, but not limited to options, swaps,
collars, caps and floors); to pledge any funds or instruments for the purposes of securing my obligations with
respect to the foregoing: to enter into foreign exchange or foreign currency transactions in any form, and, to
enter into, complete and execute agreements and to take other actions, including but not limited to signing
reconcilements of accounts and other documents to carry out the purpose of this resolution; to vote in person or
by proxy.
BANKING, CUSTODY AND
E. To withdraw monies or funds or to sell or exchange stocks, bonds, options or other securities and property
BROKERAGE ACCOUNTS
and transfer such monies, funds or proceeds of the sale or exchange only to another account at Morgan over
LIMITED POWER
(TRANSFERS TO OTHER
which I have signing authority;
MORGAN ACCOUNTS
ONLY)
CUSTODY AND
F. To buy or sell securities or any other property described in Subdivision D above in which I may deal or
BROKERAGE ACCOUNTS
which I may hold against receipt of payment to me only,
LIMITED POWER
(SECURITIES AGAINST
PAYMENT ONLY)
INVESTMENT
G. To give any instruction with respect to any Investment Management Account:
MANAGEMENT ACCOUNT
To modify the Asset Allocation Strategy for any Investment Management Account;
To deposit funds, securities or other property to any Investment Management Account or to give orders for
the withdrawal, sale, exchange, or other disposition (collectively, "Disposition") of any funds, securities
or other property from any Investment Management Account, in accordance with any instructions as the
Attorney may give;
To give orders for the payment or other Disposition of any income or proceeds of any Investment Management
Account, or proceeds of any sale or other Disposition of securities and other property in the Account:
INVESTMENT
H. To deposit funds, securities or other property to any Investment Management Account or to give orders for
MANAGEMENT ACCOUNT
the withdrawal, sale, exchange, or other disposition (collectively, "Disposition") of any funds, securities or
LIMITED POWER
TRANSFERS TO OTHER
other property from any Investment Management Account, in accordance with any instructions as the Attorney
MORGAN ACCOUNTS ONLY
may give, but proceeds of any such Disposition will be credited only to an account of mine at Morgan over
which I have signing authority;
Page 2 of 4
942
Confidential Treatment Requested by
JPM-SDNY-00002349
JPMorgan Chase
EFTA00020606

=== Page 12 ===
The Morgan Account
JPMorgan Private Bank
Durable Power of Attorney
MORGAN USE ONLY
US942 7/04
Title Jeffrey E Epstein
Account Number
MUTUAL FUNDS
I. To buy, exchange, reinvest or redeem shares of beneficial interest in any mutual funds in accordance with
your terms and conditions for my account and risk and in my name, to give instructions with respect to any of
the above-described actions; to give orders to make payment to any party, including the Attorney;
CREDIT: PLEDGE
J. To borrow money from Morgan, and to apply for and secure, from Morgan any forms of credit, to enter into
SECURITY
any notes or agreements with Morgan which result in direct or contingent liabilities to me, with or without
security, to negotiate or discount any instruments, negotiate otherwise with or through Morgan, to repay,
discharge, settle, adjust, compromise or liquidate any loan, obligation or liability; to pledge, mortgage,
hypothecate, assign, transfer, deposit or deliver, with or to Morgan, as security or as additional or substitute
security, or for sale or other disposition, stocks, bonds and other securities, deposit accounts, book accounts,
choses in action and any other tangible or intangible property, and to make substitutions thereof, and to receive
any thereof upon the release or surrender thereof, to sign, execute and deliver any and all stock powers, bond
powers, proxies, assignments, trust receipts, pledge and security agreements and other contracts and
instruments in writing, with or without seal; to authorize, give, make, procure, accept and receive monies,
payments, property, notices, demands, vouchers, receipts, releases, compromises and adjustments; to waive
notices, demands, protests and authorize and execute waivers of every kind and nature; to enter into, make,
execute, deliver and receive written agreements, undertakings and instruments of every kind and nature;
ACCOUNT
v
K. To inquire about and receive information relating to any Account, including but not limited to, balance,
ADMINISTRATION
withdrawal, payment and deposit information;
fe
L. To give instructions for the withdrawal, internal and external transfer of money to an account in my name,
individually or jointly, and for which I am a legal or beneficial owner,
ng
To pick up or otherwise receive mail or other information held by Morgan, subject to the terms of
agreements with Morgan and to applicable law and regulation.
Morgan is entitled to rely on this Power of Attorney until Morgan actually receives my written revocation. A revocation will not affect or impair any
liability or obligation arising out of or related to the exercise by an Attorney of any power granted herein before Morgan's actual receipt of a revocation.
Each Attorney is authorized to act on my behalf, in the same manner and with the same force and effect as if I had given any instruction myself, and to do
anything necessary or incidental to or to effect such instructions.
In order to induce Morgan to act in accordance with this Power of Attorney, I agree to hold Morgan harmless from any loss or liability resulting from
acting or purporting to act in accordance with this Power of Attorney until Morgan's actual receipt of written notice of my revocation or of my death.
This Power of Attorney shall not be affected by my subsequent disability, incapacity or incompetence or that of any other person signing below. My
death shall not affect the Power of Attorney granted by any other Accountholder signing below.
This Power of Attorney shall be deemed made under the law of the State of New York for all purposes, including (without limitation), construction,
validity, and effect, and shall be governed by such law.
I give each Attorney full authority to do anything he or she considers necessary and proper to be able to act in accordance with this Power of Attorney,
even if it is for the Attorney's own benefit, all as if I were personally doing it. I hereby ratify and confirm everything that my Attorney has done or shall
do by virtue of this Power of Attorney.
SPECIMEN SIGNATURES
Each Attorney shall sign AS follows: Two or more Attorneys may each act singly unless this box is checked
in
OF ATTORNEY(S)
which case any jointly,
X
Ghislaine Maxwell
Signature (Atterney (in-Fact)
Print Name
Date
Address:
Specimen Signatures continued on following page
Page 3 of 4
942
Confidential Treatment Requested by
JPM-SDNY-00002350
JPMorgan Chase
EFTA00020607

=== Page 13 ===
The Morgan Account
JPMorgan Private Bank
Durable Power of Attorney
MORGAN USE ONLY
US042 7/04
Title Jeffrey E Epstein
SPN
Prima
Account Number
SPECIMEN SIGNATURES
OF ATTORNEY(S),
X
CONT'D.
Signature (Attorney-in-Fact)
Print Name
Date
Address:
IN WITNESS WHEREOF 1 have hereunto set my hand and seal this 12 day of october 2001
SIGN HERE
X
Signature N (Accountholder)
Jeffrey E Epstein
10/12/04
Print Name
Date
X
Signature (Accountholder)
Print Name
Date
X
Signature (Accountholder)
Print Name
Date
NOTARIZATION IS REQUIRED FOR ACCOUNTHOLDERS
STATE OF:
COUNTY OF:
I certify
that Jeffrey Eptn
. known or satisfactorily proven to me to be the individual(s) who signed
the foregoing Power of Attorney, appeared before me on this
12 day of
October 2004 and acknowledged
that he/she/they executed the foregoing Power.
Signature of Netary Public
Hang I pile
10/1/04
Print Name & Title
Date
My Commission expires:
HARRY 1. BELLER
Notary Public. State of New York
No. 018E4853924
Qualified in Rockland County
Commission Expires Feb. 17. 20.
06
Page 4 of 4
942
Confidential Treatment Requested by
JPM-SDNY-00002351
JPMorgan Chase
EFTA00020608

=== Page 14 ===
The Morgan Account
Account type
Account number
/
/
Asset
Month
Date
Year
Account type
(CIRCLE ONE BELOW)
number
Social Security no. /Tax D no. Passport no.
Deposi
Account title
BAC 1
Jeffrey E Epstein
All Accountholders/Signers must sign this Signature Form exactly as the checks/Instructions will be signed.
Print (Accountholder/Signer, Trustee, Custodian, Director, etc.)
Title
If facsimile signature, check box
516%
Ghislaine Maxwell
HERE
X
R If facsimile signature, check box
Print (Joint Accountholder/Signer, Trustee, Custodian, Director, etc)
Title
SIGN
HERE
X
Print (other)
Title
if facsimile signature, check box
SIGN
HERE
X
Print (other)
Title
H facsimile signature, check box
SIGN
III
X
Is this an existing account?
yes
no
If yes, does this card replace all other cards against this account?
yes
no
Signing instructions (Please use back of card If necessary.)
SiNGLY
194
Confidential Treatment Requested by
JPM-SDNY-00002352
JPMorgan Chase
EFTA00020609

=== Page 15 ===
Comments
Date[mmddyyyy]
Box Number
Form Type = "CITADEL"
06252008
Doc Code Doc Code Doc Code Doc Code Account Numbers
942
Account Numbers
Confidential Treatment Requested by
JPM-SDNY-00002386
JPMorgan Chase
EFTA00020610

=== Page 16 ===
U.S. VIRGIN ISLANDS
DRIVER'S LICENSE
A
M
.
175
NEW YORK
01/20/1963
License #
NONE BLUE GRY 0 04/07/2004 01/20/2005
CAUTION STOP FOR ALL SCHOOL, HC, & SA CITIZEN BUSES
This certificate must be carried when driving. If lost, destroyed, or stolen,
a duplicate must be obtained at once.
VIRGIN ISLANDS POLICE DEPARTMENT
MOTOR VEHICL BUREAU
Class A . Private
INDIEBY MAKE AM ANATOMICAL GFT, TO
Class 8 . School Bus
or EFFEC TIME UPON MY DEATH OF:
NO
Class C # Taxt or or Chauteur
A: Any readed organs or parts.
Class 0 * Motorcycle Only
8: The following body parts:
Class € . Heavy Equipment
Class $ . Special
c: Limitation(s):
Restrictions:
Eton Lews
Commissioner
/ page
10/25/04
925
Confidential Treatment Requested by
JPM-SDNY-00002387
JPMorgan Chase
EFTA00020611

=== Page 17 ===
For Secretary of State of ther United States of America
hereby requests all when a may concern to permit the citizen Instituted
w the United States named bereie to pass without delay - hindrams,
and in case of need - give all lawful aid and protection
La Secretary Amerique
Apr. les présentes faster completentes de laisser passe N dure
resportiesant des Etate - de présent passeport, sang
difficult as, - cas de aide of protection dg
Services de Estado de
Amtrica por el presents - .
oridades
competentes
cirditions
national de - Blades United
our membrade, ITS demore care necesidad, provide Inda la
your
Thitat
no NATURE OF BEARERISION ATURE DU THE LAIRE FIRMA DEL TITULAR
NOT VALID DNTIL SIGNED
PASSPORT
UNITEDS EMPESIOR AMERICA
MAXWELL
NOELLE
1 kinimated
#
Dec
I
FRANCE
10, Mar 2003
New York
Passport Agency
of Mar 2006
Cersonale
See Page N
P<USAMAXWELL
<<GHISCAINE
CNOEL
1127805996
SA61
2 pages
10/25/06
925
JPM-SDNY-00002388
Confidential Treatment Requested by
JPMorgan Chase
EFTA000206

=== Page 18 ===
SOCIAL SECURITY
FOR
CHISLAINE-MAXMELL
Ras
Confidential Treatment Requested by
JPM-SDNY-00002389
JPMorgan Chase

=== Page 19 ===
NEW YORK STATE
DRIVER'LICENSE
SS #
/ page
10/25/06
925
Confidential Treatment Requested by
JPM-SDNY-00002390
JPMorgan Chase
EFTA00020614

=== Page 20 ===
The Morgan Account
JPMorgan Private Bank
Application: Morgan Premier Banking
CAS 97104 10705
MORGAN USE ONLY
US840 04/06
SCAN
Title JEFFREY EPSTEIN
SPN #:
SPN
MMIA No.
ACCT. n
Primary CAS
Doc. ID # 771
Checking Acct. No.
Effective Date:
JPMorgan Representative (sent
THOMAS A. RICE
package)
A
ACCAST
unt
Entity Type
X
Individual
Tenants by the Entirety
SCAND EPSTEIN
Joint (JTWROS)
Community Property
Tenants in Common
UTMA/UGMA
SPN #:
In Trust For (Payable On Death for Texas residents)
ACCT.
Transfer on Death (TOD)
B
Doc. ID#
Checking with Interest Account
Premier Checking Account
Effective Date:
1
estment Account
CD (Certificate of Deposit): Investment features will be obtained by JPM Representative
C
PRIMARY
Name
Social Security Number
ACCOUNTHOLDER
INFORMATION
JEFFREY EPSTEIN
Current Mailing Address
City
State
NEW YORK
NY
Zip Code/Country
State of Legal Residence
Telephone
Fax
10022
NY
Date of Birth
Mother's Maiden Name/ Password
Citizenship
If non-U.S. Citizen:
X
U.S.
Other
Resident Alien
Non-Resident Alien*
*May have to complete International Client Application
BUSINESS
Type of Business
Business Telephone
Business Fax
INFORMATION
Name of Firm
Occupation/Position
Since
Address
City
State
Zip Code
D
SECONDARY
Name
Social Security Number
ACCOUNTHOLDER
INFORMATION
(Per Jeist Accounts)
Current Mailing Address
Telephone
Fax
City
State
Zip Code/Country
State of Legal Residence
Dute of Birth
Mother's Maiden Name/ Passwood
Citizenship
If non-U.S. Citizen:
U.S.
X
Other
Resident Alien
Non-Ressdent Alien*
*May have to complete International Client Application
840
Confidential Treatment Requested by
JPM-SDNY-00002391
JPMorgan Chase
EFTA00020615

=== Page 21 ===
BUSINESS
Type of Business
Business Telephone
Business Fax
INFORMATION FOR
SECONDARY
Name of Firm
Occupation/Position
Since
ACCOUNTHOLDER
Address
City
State
Zip Code
E
BENEFICIARY/MINOR
Name
Address
City
INFORMATION
(Required for UGMA/
UTMA. ITF/POD. TOD)
State
Zip Code / Country
Date of Birth
Social Security No
Relationship
F
ADDITIONAL
ACCOUNTHOLDER(S
Please send - the Additional Accountholder Form for more than one Additional Accountholder
G
CHECKS
Check Style (JPMorgan exclusive check stock):
Wallet (single check)
Newport Desk Book (spiral binder, ) checks per page)
Business-Style Book (ring binder. 3 checks per page)
Computer Checks (last software)
Other*
*Other check styles may incur additional fee
Check Imprist: Checks will be imprinted with Title of Account as it appears on this Application, and address as listed on the primary
accountholder information section of this application, or on file.
Please omit my address from the check imprint.
CHECKCARD /
H
I wish to add a
ATM CARD
JPMorgan Private Bank Visal blink Check Card or
JPMorgan Private Bank ATM Only Card to my account.
I
ALTERNATE CHECK
Alternate Check and Card Delivery Address:
AND CARD DELIVERY
Name
Company
ADDRESS
Address
City
State
Zip Code
Country
UPS and DHL cannot deliver to a P.O. Box Address
J
CHECK IMAGING
X
Reduced size images of the front and back of each check will be returned with statements unless otherwise indicated
Truncate checks and do not return
K
ACCOUNT LINKING
Note: Linking Agreement is contained in Subdivision M of this application
Lisk for Pricing: To maintain combined average monthly balances and avoid certain transaction fees as listed on my current fee schedule
Link my following Checking, Money Market Investment Account Certificate of Deposit. and applicable JPMorgan Money Market
Funds**
Account Number for lead Checking Account to be billed any monthly maintenance charges:
Link for Statementing: Combine summary and detailed information for accounts with the same ritle in one consolidated statement.
Link my following Checking, Money Market Investment Account, Certificate of Deposit Accounts with the same ratle:
Link for Coverage Now: Coverage New is a service offered by JPMorgan that automatically transfers available funds from
care Account (Checking or Money Market Investment Account) to your Checking Account in order to cover a negative balance
Use the account listed below as an automatic source of Funds if I accidentally overdraw my Checking account
Checking Account Number
Source Account Number
I JMR aware that Federal regulations limit the number of pre-authorized transactions such as these (rum Money Market
Investment Accounts (MMIA) to six (or three checks) per statement cycle.
Link for Automatic Dollar Transfers (ADT): ADTs are pre-established. on-going fixed or variable funds transfers between
JPMorgan accounts that facilitate the control and management of funds held in multiple collections and/or distrursement accounts
Use the accounts listed below as an automatic source of funds
840
Confidential Treatment Requested by
JPM-SDNY-00002392
JPMorgan Chase
EFTA00020616

=== Page 22 ===
L
ONLINE ACCOUNT
X
1 am # current
d this account to my access
ACCESS
(For more information
My User ID
regarding online
access. contact your
I would like to access my account via Morgan OnLine
JPMorgan Private Bank
(User IDs must contain 8-32 characters. They cannot be the same as your
Representative)
My Choices for an Internet access Login ID:
password or SSN. They may not include special characters such as &. % *,
etc.)
1" Choice
2nd Choice
3rd Choice
My Email Address is:
SECONDARY
I am a current USCT of Morgan OnLine/Chase OnLine, please add this account to my access.
ACCOUNTHOLDER
My User ID is:
ONLINE ACCOUNT
ACCESS
I would like to access my account via Morgan OnLine
(User IDs must contain 8-32 characters. They cannot be the same as your
My Choices for an Internet access Login ID:
password or SSN. They may net include special characters such as &. % *.
etc.)
1" Choice
2nd Choice
3rd Choice
My Email Address is:
M
ADDITIONAL
Additional Statement Recipients (Individuals to receive duplicate copies of statements):
STATEMENT
Name of Additional Statement Recipient
Address
RECIPIENTS
City
State
Zip Code
Country
Name of Additional Statement Recipient
Address
City
State
Zip Code
Country
Name of Additional Statement Recipient
Address
City
State
Zip Code
Country
Name of Additional Statement Recipient
Address
City
State
Zip Code
Country
THIS APPLICATION MUST BE COMPLETED BEFORE MORGAN WILL BE ABLE TO PROVIDE FINANCIAL SERVICES. IF ANY SECTION IS
INCOMPLETE. YOU MAY CONTACT ME TO OBTAIN ADDITIONAL INFORMATION. I MUST ALSO NOTIFY YOU OF ANY FUTURE CHANGES TO THE
INFORMATION IN THIS APPLICATION ABSENT NOTIFICATION THE INFORMATION CONTAINED IN THE APPLICATION WILL DE DEEMED
ACCURATE AND COMPLETE.
N
PLEDGE AGREEMENT
I agree that this account is an account under The General Terms for Accounts and Services and is pledged as collsteral for
all of my obligations and is subject to the security interest provisions in The General Terms for Accounts and Services, the
terms of which are incorporated by reference. The General Terms for Accounts and Services together with this application
are the security agreement under Article 9 of the Uniform Commercial Code, as amended from time to time.
840
Confidential Treatment Requested by
JPM-SDNY-00002393
JPMorgan Chase
EFTA00020617

=== Page 23 ===
o
LINKING AGREEMENT
is pay no monthly fee, provided that 1 maintain the combined average monthly balances with IPMorgan Private Bank 25 listed on
my current fee schedule.
By linking my multiple no-interest bearing Checking accounts, I can use the combined account bulances to avoid or minimize
interest charges incurred due to an overdraft in any one or more of the linked accounts. Note that linking can reduce (If eliminate
interest charges due to overdrafts, but does not prevent the overdrafts themselves. Each day, the collected balances in all linked
accounts are added together. If the ner balance is negative, overdraft interest charges will be calculated on that negative balance
I understand that linking Checking Accounts as described above may have legal, tax or other ramifications under applicable U.S.
or other laws or rules (owing to, for example, different legal entities owning linked accounts and incurring or paying charges on
behalf of each other or having their assets offset against each other's). By signing below. I represent that I and the other account
owners have consulted with my legal. financial, tax or other advisers on these matters, accept the linkage so created. and will
manage the accounts to prevent any negative repercussions. I agree to hold harmless from and indemnify JPMorgan Private Bank
and each of its affiliates, officers, directors, agents and other representatives against any liability relating in any way to its
provision of account linking services to myself or the owners of the linked Checking Accounts Other terms applicable to my
Accounts are contained in The General Terms for Accounts and Services, Account Agreements and Appendices
P
MORGAN
The General Terms for Accounts and Services and Appendices shong with this Application, including the Linking Agreement, the
AGREEMENT
Checking Account Agreement, the Money Market Investment Account Agreement, and any additional Account Agreements, Rate
and Fee Schedules, Appendices and Supplemental Forms, and all amendments and supplements to any of them in effect from time
to time comprise the Agreement between you and me.
By signing this Application, I acknowledge that I have. or will read all the various documents, including but not limited 10. the
General Terms for Accounts and Services. Account Agreements, Rate and Fee Schedules, and Appendices, and Supplemental
Forms which comprise the Agreement between you and me ("Agreement"). I further acknowledge that I will notify you
immediately if have any issues with the Agreement Otherwise. I will be deemed to concur with this Agreement between you and
me. I also agree that each of the Accounts I am applying for is pledged as Collateral for all of my obligations. I also acknowledge
that I have read and consent to the terms of the JPMorgan Private Bank Privacy Policy, including the mainer in which my
information is received and used and that upon opening an account with JPMorgan Private Bank my client information will be
used by one or more members of the IPMorgan Private Bank family of companies (as listed in the Policy) in order to make
available to me all the products and services available through the JPMorgan Private Bank. I understand that you do not give tax
or legal advice, and that I am advised to consult a lawyer or tax advisor about tax, legal, and estate-planning issues affecting my
Accounts, including the way Accounts are titled
Q
IMPORTANT TAX
A FOREIGN PERSON MAY HAVE TO COMPLETE IRS FORM W-8BEN OR FORM W-BIMY. A "FOREIGN PERSON" MEANS
INFORMATION
A NONRESIDENT ALIEN INDIVIDUAL, A FOREIGN CORPORATION, A FOREIGN PARTNERSHIP, A FOREIGN TRUST, A FOREIGN
ESTATE, AND ANY OTHER PERSON THAT IS NOT AN U.S. PERSON. If ALSO INCLUDES A FOREIGN BRANCH OR OFFICE OF AN
U.S. FINANCIAL INSTITUTION OR U.S. CLEARING ORGANIZATION F THE FOREIGN BRANCH IS A QUALIFIED INTERMEDIARY.
FOREIGN PERSONS
# AM A FOREIGN PERSON: THEREFORE, I ACKNOWLEDGE THAT YOU ADVISE ME TO READ THE IRS W-8
TAX STATUS
INSTRUCTIONS (ENCLOSED IN THIS PACKAGE) CAREFULLY AND THAT I HAVE BEEN ADVISED TO CONSULT MY TAX ADVISOR.
Please sign and return the attached W8 form(s).
U.S. CITIZENS AND
IF I HAVE NOT CHECKED THE FOREIGN PERSONS TAX STATUS BOX ABOVE
RESIDENT ALIENS
UNDER PENALTIES OF PERJURY CERTIFY, AS THE ACCOUNTHOLDER SIGNING BELOW. THAT (1) THE NUMBER SHOWN ON THIS
TAX CERTIFICATION
APPLICATION IS MY CORRECT TAXPAYER IDENTIFICATION NUMBER (OR I AM WAITING FOR A NUMBER TO BE ISSUED TO ME), AND (2)
THAT I AM NOT SUBJECT TO BACK-UP WITHHOLDING BECAUSE (A) I AM EXEMPT FROM BACKUP WITHHOLDING, OR (B) I HAVE NOT
BEEN NOTIFIED BY THE INTERNAL REVENUE SERVICE (IRS) THAT I AM SUBJECT TO BACK-UP WITHHOLDING AS A RESULT OF A
FAILURE TO REPORT ALL INTEREST AND DIVIDENDS OR (C) THE IRS HAS NOTIFIED ME THAT I AM NO LONGER SUBJECT TO BACK-UP
WITHHOLDING, AND (3) $ AM A U.S. PERSON INCLUDING A U.S. RESIDENT ALIEN).
0 UNDERSTAND THAT F I HAVE BEEN NOTIFIED BY THE IRS THAT AM SUBJECT TO BACK-UP WITHHOLDING AS A RESULT OF
DIVIDEND OR INTEREST UNDERREPORTING, AND I HAVE NOT RECEIVED A NOTICE FROM THE IRS ADVISING ME THAT BACK-UP
WITHHOLDING IS TERMINATED I MUST STRIKE OR CROSS OUT THE INFORMATION CONTAINED IN ITEM 2 IN THE PREVIOUS
PARAGRAPH.) THE IRS DOES NOT REQUIRE CONSENT TO ANY PROVISION OF THIS DOCUMENT OTHER THAN THE CERTIFICATION
REQUIRED TO AVOID BACK-UP WITHHOLDING
SIGN HERE
X
ALL ACCOUNTHOL No DERS ARE REQUIRED TO SIGN BELOW:
X
09/18/06
JEFFREY EPSTEIN
Signature (Attombelder)
Date
Prist Name
X
Signature (Additional Accountholder)
Date
Print Name
Deposit Accounts are with JPMorgan Chase Bank, N.A. or J.P. Morgan Trust Company. N.A. (ST Chase Bank USA. N.A.
840
Confidential Treatment Requested by
JPM-SDNY-00002394
JPMorgan Chase
EFTA00020618

=== Page 24 ===
U.S. VIRGIN ISLANDS
DRIVER'S LICENSE
This certificate must be carried when driving. If lost, destroyed, or stolen,
CAUTION STOP FOR ALL SCHOOL, HC, & SR CITIZEN BUSES
a duplicate must be obtained at once.
VIRGIN ISLANDS POLICE DEPARTMENT
MOTOR VEHICLE BUREAU,
Class A . Private
Class 8 a School Bus
= EFFECTIVE UPON MY DEATH OF:
I Drive and I 2
NO
Class c # Tax or Chauffeer
A: Any fieeded organs or parts.
Class D . Motorcycle Only
B: The following body parts:
Class I . Heavy Equipment
Class $ . Special
0
Restriction:
Elten Lews
Commissioner
Confidential Treatment Requested by
JPM-SDNY-00002395
JPMorgan Chase
EFTA00020619

=== Page 25 ===
RECEIVED
JUN 27 2008
W YORK STATE
DRIVER LICENSE
JPM-SDNY-00002
sidential Treatment Requested by
EFTA00020620


c1: EFTA00021010
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021010.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Cc:
(NY) (FBI)"
Subject: Re: Flight Logs.pdf
Date: Sat, 10 Aug 2019 21:48:49 +0000
Between January and November of 2005 records show
was in St Thomas approximately 9 separate times
not including commercial flights.
On Aug 10, 2019, at 15:44,
)
wrote:
Thanks, really appreciate the quick review. I'll add this to the application.
Sent from my iPhone
On Aug 10, 2019, at 3:42 PM,
wrote:
Looks to be that
traveler to St Thomas approximately once a month between October 2001-
November of 2005.
On Aug 10, 2019, at 15:06,
)
wrote:
and
could you please review so that we can add a summary of
flights to the USVI to the
warrant? A high level summary is fine, we don't need to list all the dates-just frequency and time span. Thanks.
<Flight Logs.pdf>
EFTA00021010


c1: EFTA00023033
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023033.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Thank you
Date: Thu, 04 Nov 2021 03:23:48 +0000
Attachments: 2021.11.03_Maxwell_RTC_[unredacted].docx
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00023033


c1: EFTA00021766
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021766.pdf
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=== Page 1 ===
From: Bruce Barket
To:
Aida Leisenring
Tony Ricco
"BRUCE KOFFSKY"
"michael@mbach
John Diaz
Cc:
Subject: RE: Tartaglione - Additional Information re Discovery Requests
Date: Thu, 09 Jan 2020 17:35:57 +0000
Thanks for the update. We will follow up with
-
As for the cell phone, we had discussed agreeing or attempting to agree on the process for such a review. Can you have
the taint team reach out to us before they begin their review?
It is our understanding that there were hand held videos used to film the inside or the cell on the night of the 23rd of July.
I understand your email, but in light of the inconsistent accounts of the surveillance video can you please make further
inquiries on this specific point?
Lastly, we are going to request a hearing on what happened to the surveillance video. Please let us know what your
position on that request.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments
From:
Sent: Thursday, January 09, 2020 11:12 AM
To: Bruce Barket; Aida Leisenring; Tony Ricco; BRUCE KOFFSKY;
michael@mbach
John Diaz
Cc:
Subject: Tartaglione - Additional Information re Discovery Requests
All -
1 - We have been informed by MCC that if you would like to inspect the makeshift rope from the July 23, 2019 incident (a
picture of which was contained in the report you reviewed at our office), you can arrange to do so by contacting
the new legal counsel at MCC. You will not be allowed to take photographs of the rope.
2 - We have been informed that in the course of its investigation into Mr. Tartaglione's contraband cellphone, BOP created
forensic reports of the phone and SIM card. We have not obtained or requested copies of these reports. If you would like
to review the reports, please let us know. In that case, in light of earlier claims of privilege raised by Mr. Barket, we will
EFTA00021766

=== Page 2 ===
ask BOP to provide the reports to a walled off team of AUSAs to review for privileged materials. That walled off team of
AUSAs will coordinate producing the reports to you and will work with you to determine what, if any, portions of the
report can be provided to the case AUSAs
3 - We have been informed by BOP that apart from the photographs contained in the materials you reviewed at our office
regarding the July 23 incident, no other pictures or videos were taken from inside the Tartaglione/Epstein cell.
4 - We have received additional information from BOP regarding the video outside of the Tartaglione/Epstein cell, and we
will be filing a letter with the Court shortly. As stated in the letter, the video that we have is available for review at our
office at your convenience.
EFTA00021767


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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
Use this form for all fact witnesses within the U.S. except government employees and military personnel, for whom a Request for
Armed Forces or Government-Employee Witness should be used. For foreign witnesses, use the International Witness Travel
Request. Complete an Early or Extended stay memo if the witness is being brought in more than 3 business days prior to court/GJ
testimony. Note that witnesses may only be brought in under the FEWS appropriation for grand jury testimony, court testimony,
or preparation for same. NB: as to grand jury, this applies only in the relatively infrequent occasions where time in the grand jury
has been scheduled and the witness is intended to testify. Any other witness travel for investigative interviews must be covered
by the investigating component from litigative funds (it is generally more common for investigators to travel to the witness). See
28 C.F.R. Part 21, Witness Fees; USAP 3-19.000, Fact Witnesses and Fees and Expenses of Witnesses (FEW) Appropriation;
Guiding Principles for Obtaining Witness Services Under the Fees and Expenses of Witnesses Appropriation,
http://dojnet.doj.gov/usao/eousa/ole/usabook/witn/index.htm
To:
SDNY Victim/Witness Unit
AUSA
United States V. Jeffrey Epstein
Court Docket Number: 19 Cr. 490 (RMB)
USAO No: 2018R01618
Witness Name:
Witness DOB:
(Name/DOB as printed here will be forwarded to travel agency and then to TSA and must exactly match the witness's driver's
license or other travel ID or TSA will not permit the witness to fly)
Witness Address:
Witness Telephone Numbers (mobile):
Witness e-mail:
Needed to Appear in SDNY on July 31, 2019 at 1 p.m.
date
time
For: Trial ( )
Grand Jury ( )
Trial/GJ Prep (x)
Trial Date
Date
Date
Is the person a Fact Witness and not an Expert Witness?
(Yes/No)
Yes
Current Federal Civilian or Military Employee?
(Yes/No)
No
Is the Witness Facing Criminal Charges?
(Yes/No)
No
Does the Witness Reside Outside the Continental United States?
(Yes/No)
No
Is this Witness a Victim-Witness
(Yes/No)
Yes
Hotel Required
(Yes/No)
Yes
Est. Date of Arrival
Est. Date of Departure
EFTA00020935


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=== Page 1 ===
From:
To: Sigrid McCawley
Cc:
Subject: RE: Interviews - 10/22 and 10/23
Date: Tue, 15 Oct 2019 20:04:56 +0000
Hi Sigrid,
Thanks very much for helping us coordinate these meetings.
Meeting with
from 2pm to 4pm will work for us, thank you. We'll plan to meet with her at our office (1 St.
Andrews Plaza) on 10/22 at 2pm.
Unfortunately, our schedules are a bit tight from 4pm to 6pm on 10/22 and for most of the day on 10/23. Would
and/or
be available on 10/22 before 2pm, on 10/22 after 6pm, or on 10/23 after
5pm?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Tuesday, October 15, 2019 10:34 AM
To:
Cc:
is
is
Subject: RE: Interviews - 10/22 and 10/23
Hello
- sorry for the delay but I have been trying to get a handle on who is coming for the meeting etc.
is a victim that I think will be helpful to your continuing investigation. She is working hard with your
victims' coordinator to see if she can get here for the meeting. If she gets her passport/visa clearance and gets to the US
then we could do an interview on the afternoon of Tuesday October 22rd starting at 2:00 if that works. I think she will
probably take a bit longer because she was brought to the US by Epstein a number of times so maybe a lot 2 hours for the
interview (from 2-4).
EFTA00021307

=== Page 2 ===
is going to be attending the meeting and she said she could interview with you right after the
meeting. I believe the notice says the meeting starts at 10:00 on October 23rd so maybe we plan to meet you at 12:00
depending on the length of the victims' meeting.
also wanted to come to the meeting. I know you met with her for a short while. If you would like to meet
with her for a more detailed interview we could do that on the afternoon of October 22nd from 4- 6 if that works.
is
She would like to try to attend via skype or some kind of conference line.
I know you interviewed her sister
If you would like to also interview
I can set something up.
Let me know if that works.
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Thursday, October 10, 2019 3:39 PM
To: Sigrid McCawley
Cc:
is
Subject: Interviews - 10/22 and 10/23
Hi Sigrid,
Hope you're doing well.
mentioned that some of your clients might be interested in being interviewed while they
are in New York on 10/22 and 10/23. We'd be happy to get times on the calendar. Would you please let us know who
would be available for interviews and what dates and times work for each client?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
EFTA00021308

=== Page 3 ===
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
EFTA00021309


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=== Page 1 ===
From:
)"
To:
Cc:
Subject: Re: Epstein
Date: Wed, 31 Jul 2019 12:21:38 +0000
Thanks
Until we receive a final report, we plan to tell the Court that the investigation is ongoing.
On Jul 31, 2019, at 7:58 AM,
wrote:
Hi
The investigation is nearing completion. He was given an incident report for self mutilation yesterday and is
expected to have his DHO hearing in the near future. The original claims against Tartaglione appear
unfounded, but we are still awaiting the final report.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
New York, New York 10007
)"
7/30/2019 7:11 PM
Hi
and
Is the investigation into Jeffrey Epstein's injuries still ongoing? I ask because we have a conference before Judge Berman
tomorrow morning, and we expect that he will ask us about what happened at the MCC. If the investigation is still
ongoing, we will tell him that. If it has been completed, would you please send us any new reports and whatever
documentation sets forth the conclusions that the investigators reached?
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00021529


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=== Page 1 ===
From:
To:
Subject: Travel Authorization 11061409 approved by
, now awaiting further
approval
Date: Wed, 19 Feb 2020 22:04:30 +0000
Importance: Normal
Dear
Travel authorization 11061409 has been approved by
, now awaiting further approval.
Trip ID: 11061409
Traveler name:
Purpose: R20NYS13400 - Epstein Investigation Witness interviews
Destination: Beverly Hills, CA, United States
Dates: 2020-02-26 - 2020-03-03
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0007
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00021148


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: [EXTERNAL] Transcript?
Date: Sat, 20 Nov 2021 21:30:31 +0000
Attachments: Rocchio_Daubert_Hearing_Testimony_Redacted.pdf
Dr. Rocchio,
Please see attached.
Best,
From:
Sent: Thursday, November 11, 2021 7:35 AM
To:
Subject: [EXTERNAL] Transcript?
Hello
Is there anyway for me to get a transcript of my testimony?
Lisa
Lisa M. Rocchio, Ph.D.
Clinical and Forensic Psychologist
Lisa M. Rocchio, Ph.D. & Associates, Inc.
Clinical Assistant Professor
Psychiatry and Human Behavior
Alpert Medical School of Brown University
EFTA00023358


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=== Page 1 ===
From: "
(USANYS)"
To:
"
(USANYS)"
Cc:
"
(USANYS)"
Subject: RE: Weekly Updates
Date: Fri, 07 Jun 2019 21:56:14 +0000
Importance: Normal
Got it. Thanks.
From:
(USANYS)
Sent: Friday, June 7, 2019 5:55 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Weekly Updates
Another update: related to the discussion we had, we are approaching 3 NY Epstein victims on Tuesday.
EFTA00022518

=== Page 2 ===
EFTA00022519


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: Subpoena requests
Date: Fri, 06 Dec 2019 20:35:47 +0000
Any uber and lyft accounts associated with Ghislaine Maxwell, DOB
.
Or associated with phone
number
and email address
Could we also see if there are accounts associated with the below addresses?
,
Boston, MA 02114
, Boston, MA 02108
,
Manchester by the Sea, Massachusetts 01944
Original Message
From:
Sent: Thursday, December 05, 2019 7:06 PM
To:
Cc:
Subject: Subpoena requests
Hey all,
Could we get some subpoenas for the below agencies for Ghislaine Maxwell, DOB
Uber
Uber Technologies, Inc.
San Francisco, CA 94103
Lyft
San Francisco, CA 94107
Thanks!
EFTA00020998


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: joint letter
Date: Sun, 07 Nov 2021 21:02:11 +0000
Attachments: 2021-11-08_joint_letter_regarding_juror_questionnaires.v2.docx.
Hi
Could you please withdraw our objection to the three highlighted jurors, and update the letter and the spreadsheet?
Thanks!
From:
Sent: Sunday, November 7, 2021 2:40 PM
To:
Cc:
is
Subject: RE: joint letter
Hey
- the draft letter is attached, with all four categories filled in with the respective juror numbers. I'm also
attaching the Excel sheet, containing defense and government objections, that contains all four lists in four different
sheets. This Excel sheet is also saved on the shared in the jury selection folder.
If anything needs to be edited, l'll be around for a bit longer today but I'm unavailable later this afternoon/evening, after
3:30pm today.
have kindly offered to handle any edits tonight when I'm offline,
so I can loop them in if necessary.
Thanks so much!
From:
Sent: Sunday, November 7, 2021 2:06 PM
To:
Cc:
is
Subject: joint letter
Hi
Thanks so much for all you're doing today, really appreciate it. Attached is a draft of the joint letter for today with the four
categories. Could you please fill those in after you've had a chance to enter all the data from the defense? I'm fine with
charts in each of the four questions (essentially just one row of cells with juror numbers). Also fine with bullet points.
Whichever is easiest.
Whenever you're at point when you have a sense of the timeline for this, that would be helpful to know - we'll need to
send this to the defense with ample time to review for accuracy, so hoping to do that later this afternoon.
Thanks!
EFTA00022179

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00022180


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=== Page 1 ===
CFN 20120001716
OR BK 24936 PG 0222
QUITCLAIM DEED RECORDED 01/04/2012 09:50:23
Palm Beach County, Florida
THIS QUITCLAIM DEED, made the 23RD day of December. 2011. by Jeffrey E. Epstein, a
single man, with an address of
St. Thomas. VI 00802
"Grantor"), to Laurel, Inc., a U.S. Virgin Islands corporation with an address of
Port
St. Thomas, VI 00802 ("Grantee").
WITNESSETH:
Grantor wafrants that at the time of this conveyance, the subject property is not the Grantor's
homestead within the meaning set forth in the constitution of the state of Florida, nor is it
Pgs 0222 224; (3pgs)
not
St. Thomas, VI 00802.
Sharon R. Bock, CLERK & COMPTROLLE
Doc Stamp 0.70
AMT 10.00 10.
contiguous to or a part of homestead property. Grantor's residence and homestead address is
&
THAT Grantor, for and in consideration of the sum of TEN DOLLARS ($10.00) and other good
and valuable consideration to Grantor in hand paid by Grantee, the receipt and sufficiency whereof
are hereby acknowledged, Grantor does hereby release and quitclaim unto Grantee, and Grantee's
successors and assigns forever, all the right, title, interest, claim and demand which the said Grantor
has in and to the following described lot, piece or parcel of land, situate, lying and being in the
County of Palm Beach County in the State of Florida
Being all of lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page
9, in the records of Palm Beach County, Florida, and
BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range
43 East, as recorded in Plat Book 2 Page 9, Public Records of Palm Beach County, Florida being
bounded on the West by the West side of an existing concrete seawall and the northerly extension
thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded
on the East by the shore line and shown on the plat of El Bravo Park, and bounded on the North
and South by the Westerly extensions of the North and South lines respectively of Lot 40,
containing 0.07 acres, more or less.
THE PROPERTY CONTROL NUMBER IS 50-43-43-27-06-000-0391.
THE GRANTOR'S TAX IDENTIFICATION NUMBER IS
TO HAVE AND TO HOLD, the same together with the appurtenances thereunto belonging and
all the estate, title and rights of Grantor in and to said premises.
Book24936/Page222
Page 1 of 3
EFTA00020949

=== Page 2 ===
IN WITNESS WHEREOF, the said Grantor has caused these presents to be executed the day and
year first above written.
WITNESSES
C JEFFREY E. EPSTEIN
GRANTOR:
Bott Joany
TERRITORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF SI. THOMAS/ ST. JOHN
) SS:
On the 23 day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared Jeffrey E. Epstein, personally known to me or proved to me on the basis of
satisfactory evidence to be the individual who subscribed to the withink
A
Kallerhals
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Notary Public
Territory of the U.S. Virgin Islands
TERRITORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF ST. THOMAS/ S. JOHN
) SS:
On the 23RD day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared greg Ferguson , personally known to me or proved to me on the
basis of satisfactory evidence to be a subscribing witness to the within instrument, who being by me
duly sworn, did depose and say that he resides in the United States Virgin Islands; that he knows
Jeffrey E. Epstein to be the individual who executed the within instrument; that said subscribing
witness was present and saw Jeffrey E. Epstein execute the same; and that said subscribing witness
at the same time subscribed his name as a witness thereto.
A Notary Public
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Territory of the U.S. Virg/ slands
Book24936/Page223
Page 2 of 3
EFTA00020950

=== Page 3 ===
TERRITORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF ST. THOMAS/ ST. JOHN
)
SS:
On the 23 day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared Brett Geary
, personally known to me or proved to me on the
basis of satisfactory evidence to be a subscribing witness to the within instrument, who being by me
duly wom, did depose and say that she resides in the United States Virgin Islands; that she knows
Jeffrey E. Epstein to be the individual who executed the within instrument; that said subscribing
witness was present and saw Jeffrey E. Epstein execute the same; and that said subscribing witness
at the same time subscribed her name as a witness thereto.
Erika A. Kellerhals
Notary Public
NOTARY PUBLIC LNP 013:10
Commission Expires 05/02/2014
Territory of the U.S. Virgin Islands
certified
Adoo
Book24936/Page224
Page 3 of 3
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=== Page 1 ===
From:
To:
Subject: NYTimes: Fund for Jeffrey Epstein's Accusers Gets Attorney General's Approval
Date: Sat, 30 May 2020 11:56:03 +0000
FYI. Kindly forward to all the right people
Associate U.S. Attorney
Southern District of New York
> Fund for Jeffrey Epstein's Accusers Gets Attorney General's Approval
>
https://www.nytimes.com/2020/05/29/business/jeffrey-epstein-victim-fund.html?referringSource-articleShare
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=== Page 1 ===
From:
To:
Subject: [EXTERNAL] Spreadsheets from Denver exports without thumbnails
Date: Wed, 13 Oct 2021 23:10:24 +0000
Attachments: Exports.zip
See attached.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
EFTA00020811


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: Re: SDNY investigation [FFW-DOCS.FID6003375]
Date: Thu, 30 Jul 2020 17:40:32 +0000
Inline-Images: image001.jpg; image002.png; image003.png
That works for me, thanks.
Sent from my iPhone
On Jul 30, 2020, at 1:33 PM,
)
wrote:
I'm planning to take the 10th off, so would be grateful if we could suggest the 12th.
From:
Sent: Thursday, July 30, 2020 1:10 PM
To:
is
)
Subject: FW: SDNY investigation [FFW-DOCS.FID6003375]
I could do literally any time that week. Should we suggest the morning of the 10th? Or 12th, in the alternative?
From: Jill Greenfield
>
Sent: Thursday, July 30, 2020 12:51
To:
)
>; Kyle Phillips
Cc: Louise Scott
is
is
Subject: RE: SDNY investigation [FFW-DOCS.FID6003375]
Thanks
I have been in discussions with my client and we ought to be in a position to provide you with more information in the
categories suggested. I am away next week but shall we schedule a call on my return, the week commencing 10th
August?
Kind regards,
Jill
Jill Greenfield
Partner
D:
M:
Click here for information relating to Covid-19 business impacts
<image001.jpg>
EFTA00020774

=== Page 2 ===
<image002.png><image003.png>
From:
Sent: Monday, July 20, 2020 4:19 PM
To: Jill Greenfield
>; Kyle Phillips
Cc: Louise Scott
Subject: RE: SDNY investigation
Jill, Kyle,
Following up on our recent WebEx discussion, and with apologies for the slight delay, we wanted to get you a list of
initial categories of question that we think might assist in your discussion with your client, with the goal of then doing an
attorney proffer, or attorney summary, and discussing possible next steps.
We note that the below questions are simply general thoughts and suggestions-some may not need to be asked at all,
others may prompt follow-up from you in the moment, etc. In any interviews with us, we ordinarily are guided both by
the comfort level and the narrative of the witness, but we hope these give you a sense of what we would be interested
in. We also note that we included questions about sexual contact because it is our very general understanding from you
that abuse occurred, but we do not make any presumptions about what happened, if anything, separate from what your
client recalls. On that note, as we've discussed, but to reiterate, if there are any questions or topics your client is
uncomfortable addressing, there will be no pressure from us to do so, including at this early stage.
With those caveats, possible questions are below, and please let us know if it would be useful for us to chat again before
you talk with your client, or otherwise please let us know when it would next be appropriate to check in.
Questions / topics:
1) General background queries: Where did you grow up? How far did you go in school? What is your date of birth?
How generally would you describe your upbringing and early professional life?
2) How did you initially meet Ghislaine Maxwell and Jeffrey Epstein, and how old were you at that time? What was the
nature of your work with them, and did the role change over time? How long did you work for Maxwell and/or
Epstein?
3) In general, what kinds of tasks did you perform for Maxwell or Epstein, and in what locations? Did you travel with
either of them? When you weren't traveling with them, where did you reside? Did you ever reside with Maxwell or
Epstein? If so, where - in what locations and at which properties?
4) Did there come a time when Epstein and/or Maxwell engaged in sexual contact with you? If so, how did that
happen the first time? Were there sexualized discussions or was there sexualized conduct leading up to any first
incident?
5) Were there other instances when you experienced sexual abuse or sexual contact while working for Maxwell? If so,
how did those incidents occur? Did they occur with Epstein alone, or was Maxwell ever directly involved in the
sexual contact? Did Maxwell ever observe, or was she present for, sexual contact that she herself was not
participating in? Were any other individuals present or participating?
6) Were you aware of any other girls or women who were subject to sexual abuse or contact by Epstein and/or
Maxwell, and if so, who? Did you ever see Epstein or Maxwell involved in sexual or other intimate contact with
other girls you believed or suspected may have been under the age of 18? And if so, under what circumstances
(when, where, etc.)?
7) How did your interactions with Epstein and Maxwell end? Did either of them contact you or attempt to contact you
when Epstein was under investigation in 2006-08? Did either of them contact you or attempt to contact you during
the New York investigation in 2018-20? If so, what was the nature of that contact? When is the last time you spoke
with or otherwise interacted with Epstein and/or Maxwell?
thank you,
EFTA00020775

=== Page 3 ===
Assistant U.S. Attorney
Southern District of New York
Fieldfisher, Riverbank House,
London EC4R 3TT.
,
www.fieldfisher.com
We do not intend to change our bank details. If you receive any communication that any of our bank details have changed, telephone us and speak to your
contact at our office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstances.
This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact the sender immediately, destroy
the email and any attachments and do not use, copy, store or disclose this email and any attachments for any purpose. Fieldfisher does not accept service of
documents by electronic means without express prior agreement.
For details about what personal information we collect and why, please see our Privacy Notice on our website at www.fieldfisher.com.
Fieldfisher is the trading name of Fieldfisher LLP, a limited liability partnership registered in England and Wales (registered number OC318472) and is authorised
and regulated by the Solicitors' Regulation Authority. A list of its members and their professional qualifications is available at its registered office, Riverbank
House,
London EC4R 3TT. We use the term partner to refer to a member of Fieldfisher LLP or an employee or consultant with equivalent standing
or qualifications.
f
in
EFTA00020776


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=== Page 1 ===
From:
"
To:
Cc:
Subject: MCC guards
Date: Wed, 30 Jun 2021 15:32:23 +0000
Hi,
Two things:
1. The guards that Noel named as not doing rounds/counts and pre-filling were COs
2. According to the notes of his interview with us,
said he knew but did not tell anyone that
was
released or Epstein was without a cellmate. He also stated that he was waiting for the captain or warden to put
someone new in the cell. In a recent interview with OIG, he says that he didn't know that
was gone and
denies his prior statement. Do you have a recollection of this interview? If so,
wants to know if we think the
notes/MOI are correct.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York. New York 10007
Tel
Ce
EFTA00022021


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=== Page 1 ===
Page 1 of 2
From:
Sent: Friday, September 6, 2019 6:52:15 PM
To:
Subject: FW: WF 4319870
Per the e-mail below, please assign to
in SDNY for handling.
Thanks in advance,
U.S. Department of Justice
From:
Sent: Friday, September 06, 2019 6:49 PM
To:
Cc:
Subject: Re: WF 4319870
Please send to
in SDNY.
On Sep 6, 2019, at 6:41 PM,
wrote:
Per the attachment, should this document be assigned to ODAG for handling?
Thanks,
U.S. Department of Justice
Office of the Deputy Attorney General
From:
Sent: Thursday, September 05, 2019 11:37 AM
To:
Cc:
Subject: WF 4319870
Per
assign to ODAG for assignment guidance.
https://iqapp.justapps.doj.gov/iq/StreamDownloader.aspx?path=&filename=1092019_1219...10/9/2019
EFTA00021159

=== Page 2 ===
Page 2 of 2
U.S. Department of Justice
Executive Secretariat
<Arlan Ettinger.pdf>
https://iqapp.justapps.doj.gov/iq/StreamDownloader.aspx?path=&flename=1092019_1219...10/9/2019
EFTA00021160


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=== Page 1 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
Person Encounter Detail
09/21/2021 11:31 EDT
Generated By:
Page 1 of 1
Encounter Person Detail
Last Name
First Name
Middle Initial
Gender
Date of Birth
MAXWELL
GHISLAINE
Document Number
Document Type
Document Country
Class of Admission
Admit Until Date
U.S. ALIEN REGISTRATION
CARD
Encounter Person Detail
Encounter Line Type
Encounter Date
Encounter Time (Eastern)
Terminal Lane
Site/Encounter Location
AIRLINE (NOT API)
07/24/1998
13:48
QB04
A511 CBP-CYRIL E
KING, INTL AIRPORT
Inbound/Outbound
Inspector
Processing Result
Primary Query Result
Referred To Agency
INBOUND
N
NOT REFERRED
Manifest Data
Manifest Indicator
Passenger Status
Updated Passenger Status
Flight/Vessel Number
Departure Location
N
1672
Transmitted By
Carrier Code
Arrival Location
AA
For Official Use Only / Law Enforcement Sensitive
EFTA00021188


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=== Page 1 ===
From:
To:
Subject: LOL
Date: Thu, 25 Apr 2019 22:45:03 +0000
Importance: Normal
FYI, decoding the legend --
CYYR: Newfoundland, Canada
KETB: Teterboro, NJ
you beat me to it
Original Message
From:
Sent: Thursday, April 25, 2019 18:37
To:
Cc:
Subject: Epstein Travel
Attached is a summary of Epstein's travel from 1.1.2015 to 4.21.19.
Special Agent
FBI New York
VCAC/Human Trafficking
C:
O:
EFTA00020690


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=== Page 1 ===
From:
"
To:
Subject: Accepted: Mark Epstein Meeting
Date: Thu, 24 Oct 2019 14:57:09 +0000
Importance: Normal
Attachments: unnamed
EFTA00023022


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=== Page 1 ===
From:
(NY) (FBI)"
To:
)"
Cc:
(NY) (FBI)"
(NY) (OGA)"
Subject: Re: Image/Video file review for Maxwell case
Date: Mon, 19 Oct 2020 14:02:19 +0000
Hi
I was out of the office when you sent this email. I also will be out of the office this full week. I know
and
are both back now but am happy to give you call to discuss logistics, as I will be helping on this when I'm
back.
Thanks,
From:
Sent: Friday, October 16, 2020 4:51 PM
To:
(NY) (FBI)
Cc:
(NY) (FBI)
is
(NYPD)
is
i
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Image/Video file review for Maxwell case
Following up on this, I'll be working this evening and all weekend, so I'm happy to have a call whenever works for you in
that timeframe. Ideally, I'd like to touch base before Monday so that we can hit the ground running with the review first
thing Monday morning.
Thanks very much,
From:
Sent: Friday, October 16, 2020 1:45 PM
To:
(NY) (FBI)
Cc:
(NY) (FBI)
is
(NYPD)
is
is
(USANYS)
Subject: Image/Video file review for Maxwell case
Hi
My supervisors gave me your name as the point of contact at the FBI to help coordinate the review of images and videos
from Jeffrey Epstein's devices for discovery in the Ghislaine Maxwell case. Thank you so much for being willing to help out
with this while
and
are traveling.
I've spoken with
about some of the logistics, and it would be great if you and I could have a call to talk about
next steps. Is there a time this afternoon when you would be free for a call?
EFTA00023335

=== Page 2 ===
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00023336


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=== Page 1 ===
From:
)"
To:
)"
,
Subject: RE: U.S. Department of Justice - VNS - Investigative Case 31E-NY-3027571 - Court Case
Date: Fri, 03 Jul 2020 22:05:07 +0000
Inline-Images: image001.jpg
Thanks,
is represented by Gloria Allred - could you please update VNS to make sure notifications go to
Gloria in the first instance? Thanks.
From:
Sent: Friday, July 3, 2020 5:59 PM
To:
is
>;
Subject: Fwd: U.S. Department of Justice - VNS - Investigative Case 31E-NY-3027571 - Court Case
Sent from my iPhone
Begin forwarded message:
From: Daniel Rose
Date: July 3, 2020 at 12:44:21 PM EDT
To:
Subject: FW: U.S. Department of Justice - VNS - Investigative Case 31E-NY-3027571 - Court Case
Good Afternoon
Please keep us informed and notified of this case.
Kind Regards
Daniel Rose
Daniel J. Rose, P.A.
323 NE 6th Avenue
Delray Beach, Florida 33483
NOTICE: This E-mail (including attachments) is covered by the Electronic Communications Privacy
Act, 18 U.S.C. 2510-2521, is confidential and may be ATTORNEY PRIVILEGED and CONFIDENTIAL.
It is intended only for the use of the individual or entity named as recipient. If the reader
of this message is not the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication or any of its contents, is strictly prohibited.
If you have received this communication in error, please notify sender immediately by re-sending
This communication to the sender and delete the original message and any copy of it from your
computer system.
Thank you for your cooperation.
From: U.S. Department of Justice - VNS
Sent: Thursday, July 2, 2020 4:23 PM
EFTA00021812

=== Page 2 ===
To: Daniel Rose
Subject: U.S. Department of Justice VNS Investigative Case 31E-NY-3027571 - Court Case
DO NOT REPLY TO THIS EMAIL.
U.S. Department of Justice
Southern District of New York
One St. Andrews Plaza
New York, NY 10007
Phone: (212) 637-1028
Fax: (212) 637-0421
July 02, 2020
Daniel Rose, P.A.
Re: Case Number 2018R01618 and Court Docket Number Docket 20 Cr. 330
Dear Daniel Rose, P.A.:
This notice is provided by the United States Department of Justice Victim Notification System. You have been designated
to receive notifications on behalf of the following victim(s) (or potential victims) identified by law enforcement during
the investigation of the case:
There is new information regarding the above referenced matter that can be viewed by accessing the VNS Web page at
https://www.notify.usdoj.gov and registering with VNS. Registering with VNS provides the ability to access all
notifications regarding this case, view any additional documents provided during the case as well as update your
personal contact information. You will need the following information to register with VNS: (1) your VNS ID and PIN that
was provided to you in the initial email you received from VNS. In addition, if you have received a letter from VNS, your
ID and PIN are included in the letter; (2) Your last name or business name as listed in the VNS letter or email.
If you want future email notices from VNS to contain the details regarding the case events, you can elect to "verify"
your email address when you register by providing that information during the registration process. Verifying your
email with the VNS will also allow you to be assured of receiving timely notifications regarding this matter.
If you do not want to register with VNS, but you want to receive VNS email notices that contain the details about recent
events, you should verify your email address by selecting this link to VNS. You will need to provide the following
information to verify your email address: VNS ID, your last name or business name, and your email address (you must
enter the same email address used for this message). Please understand that if you elect to verify your email address
without registering with VNS, you will not have access to the VNS Web site.
If you need assistance with this process, please contact the VNS Help Desk at
Defendant Ghislaine Maxwell was arrested and charged for her role in facilitating the abuse of minor victims by Jeffrey
Epstein. As alleged in the indictment, that abuse occured between approximately 1994 and 1997 in locations including
New York, Florida, New Mexico, and London, England. The lead prosecutors on the case are
and
Victim's Rights
Although the current charges against Maxwell may not contain allegations involving you personally, the Southern District
of New York previously identified you as a victim or potential victim in a related case involving Jeffrey Epstein.
EFTA00021813

=== Page 3 ===
Victims of all crimes under federal investigation are entitled to services under the Victims' Rights and Restitution Act
(VRRA), including notification of court events. For further details, please refer to Title 34 United States Code section
20141 or the VRRA link posted at https://www.notify.usdoj.gov.
Although you have not have been identified as a victim of the specific conduct charged in the Indictment, for your
awareness, this letter provides details regarding the rights of crime victims in federal cases. Now that charges have been
filed in federal court, victims of the charges filed are, in addition, entitled to the following rights, according to the Crime
Victims' Rights Act, Title 18 United States Code section 3771: (1) The right to be reasonably protected from the accused;
(2) The right to reasonable, accurate, and timely notice of any public court proceeding, or any parole proceeding,
involving the crime or of any release or escape of the accused; (3) The right not to be excluded from any such public
court proceeding, unless the court, after receiving clear and convincing evidence, determines that testimony by the
victim would be materially altered if the victim heard other testimony at that proceeding; (4) The right to be reasonably
heard at any public proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5) The
reasonable right to confer with the attorney for the Government in the case; (6) The right to full and timely restitution
as provided in law; (7) The right to proceedings free from unreasonable delay; (8) The right to be treated with fairness
and with respect for the victim's dignity and privacy; (9) The right to be informed in a timely manner of any plea bargain
or deferred prosecution agreement; and (10) The right to be informed of the rights under this section and the services
described in section 503(c) of the Victims' Rights and Restitution Act of 1990 (34 U.S.C. 20141(c)) and provided contact
information for the Office of the Victims' Rights Ombudsman of the Department of Justice. If you want to inform the
prosecutors of your views regarding any aspect of the case, please contact one of the prosecutors listed above or me at
Please understand that these rights apply only to victims of the specific counts charged in federal court, and thus you
may not be able to exercise all of these rights if the crime of which you are a victim is not within the scope of the
Indictment.
Because you have not been identified as a victim of the charges filed against Maxwell, we will not provide you with
additional individualized notifications about this specific case unless you request such notifications. If you wish to
receive ongoing notifications regarding this case, please contact me at
Even if you do not receive individualized notifications regarding this case, we will make our best efforts to ensure you
are provided the rights and services to which you are entitled. You may contact the Victim/Witness Coordinator at the
office listed above if you have questions about the progress of your case, your rights or the services to which you are
entitled, or how you can assert them during the proceedings. If you believe that a Justice Department employee has not
provided you with these rights, you may file a complaint with the Justice Department's Victims' Rights Ombudsman. For
more information, go to http://www.justice.gov/usao/resources/crime-victims-rights-ombudsmar If you have
questions about filing a complaint against an employee, you may contact the Ombudsman by email at
usaeo.VictimOmbudsman@usdoj.gov. Questions concerning this case should be directed to office listed above.
It is important to keep in mind that the defendant(s) are presumed innocent until proven guilty and that presumption
requires both the Court and our office to take certain steps to ensure that justice is served. While our office cannot act
as your attorney or provide you with legal advice, you can seek the advice of an attorney with respect to the rights
above or other related legal matters.
Hearing Information
There currently is not a date set for a next court conference. If you wish to receive ongoing notifications regarding this
case, including relating to scheduling matters, please contact me at the phone number or email listed above.
Information Regarding the Victim Notification System (VNS)
If, and only if, you elect to receive additional notifications regarding this case, then through the Victim Notification
System (VNS) we will continue to provide you with updated scheduling and event information as the case proceeds
EFTA00021814

=== Page 4 ===
through the criminal justice system.
Sincerely,
Audrey Strauss (Acting)
United States Attorney
If you do not want to receive email notifications from the Victim Notification System (VNS) please log into the VNS Web
site at https://www.notify.usdoj.gov, select "My Information", remove your email address and click the "update" button.
If you remove your email address, you will continue to receive letters from VNS except in those case which have large
numbers of victims. To change your email address, select "My Information", provide a new address and click the
"update" button.
If you do not want to receive any notifications in your case, select "Stop Receiving Notifications" and follow the
instructions on the screen.
If you believe you have received this email in error, please contact the office listed at top of the email message.
Please note, if this is the first notification you have received from VNS you will need to wait 4-8 hours from receipt of
this email before you can login to the VNS Internet site (https://www.notify.usdoj.gov). In addition, it will also be 4-8
hours before any documents which may have been uploaded to VNS as part of this notification are available under the
"Downloads/Links" section on the Web page.
Please call the Victim Notification System (VNS) Help Desk at phone number 1
for assistance and
questions.
EFTA00021815


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=== Page 1 ===
From:
)"
To: Roberta Kaplan
Subject: RE: The Estate of Jeffrey Epstein
Date: Tue, 10 Dec 2019 17:08:27 +0000
We did not, so I appreciate you sending it - thanks.
From: Roberta Kaplan
Sent: Tuesday, December 10, 2019 11:52
To:
Subject: Fwd: The Estate of Jeffrey Epstein
I assume you have this.
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
350 Fifth Avenue | Suite 7110
New York, New York 10118
From: Moskowitz, Bennet J.
Sent: Tuesday, December 3, 2019 9:36:45 PM
To: Andrew Villacastin
>; ; Sigrid McCawley
Cc:
is
>; Kate L. Doniger
>; Brad Edwards
>; Julie Fink
is
is
is
is
y.
;
Roberta Kaplan
>; Sabina Mariella
>; Jordan Merson
>; Josh Schiller
is
>; Laura Starr
>; Mariann Wang
Subject: RE: The Estate of Jeffrey Epstein
Counsel:
Please see the attached letter.
Thank you,
Bennet
Bennet J. Moskowitz*
troutman sanders
Direct:
*Licensed to practice law in New York and Connecticut
From: Andrew Villacastin
Sent: Friday, November 22, 2019 4:15 PM
EFTA00021001

=== Page 2 ===
To: Moskowitz, Bennet J.
>; Sigrid McCawley
Cc:
Brad Edwards
>; Julie Fink
is
Sabina Mariella
>; Jordan
Merson
>; Josh Schiller
>; Laura Starr
Mariann Wang
Subject: The Estate of Jeffrey Epstein
EXTERNAL SENDER
Counsel,
Please see attached.
Best,
Andrew
Andrew Villacastin
Associate
BOIES SCHILLER FLEXNER LLP
55 Hudson Yards
New York, NY 10001
(t)
www.bsfllp.com
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
This e-mail message (and any attachments) from Troutman Sanders LLP may contain legally privileged and confidential
information solely for the use of the intended recipient. If you received this message in error, please delete the message
and notify the sender. Any unauthorized reading, distribution, copying, or other use of this message (and attachments) is
strictly prohibited.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00021002


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 368 Filed 10/25/21 Page 1 of 2
USDC SDNY
UNITED STATES DISTRICT COURT
DOCUMENT
SOUTHERN DISTRICT OF NEW YORK
ELECTRONICALLY FILED
DOC #:
DATE FILED: 10/25/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
On October 18, 2021, the parties filed their respective motions in limine. Dkt. Nos. 355,
357, 358. Responses are due today, October 25, 2021. The parties are further ORDERED that
reply briefs, if any, are due by October 27, 2021. Each sides' responses and any replies must be
filed as a single document. For example, the Government should file an omnibus response brief
to all of the motions in limine filed by the Defendant, and the Defendant should file an omnibus
response brief to the Government's omnibus motion in limine. Similarly, any reply by the
Defendant should be an omnibus reply document and same for the Government.
The parties filed their motions in limine temporarily under seal to allow for the other
side's proposal and the Court's consideration of redactions. See Dkt. Nos. 358-59. Each side
should consider the other party's briefs-including any responses filed on October 25, and any
replies filed on October 27-and indicate whether they seek any additional redaction requests.
The parties are ORDERED to file on the public docket all briefing with both parties' proposed
redactions, and a joint letter justifying any requested redactions by reference to the three-part test
articulated by the Second Circuit in Lugosch V. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir.
2006), on or before October 29, 2021.
so ORDERED.
1
EFTA00023211

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 368 Filed 10/25/21 Page 2 of 2
Dated: October 25, 2021
Alim D. D.Netto
New York, New York
ALISON J. NATHAN
United States District Judge
2
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Date: Wed, 04 Sep 2019 20:47:50 +0000
Importance: Normal
Attachments: Professor_Green_letter,_19_Cr_490.pdf; Judge_Berman_letter_19_Cr_490.pdf
U.S. Attorney's Office for the
Southern District of New York
EFTA00023106


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=== Page 1 ===
From: Nathan NYSD Chambers
To:
Subject: 20cr330, US V. Maxwell
Date: Wed, 03 Nov 2021 22:34:39 +0000
Attachments: 20cr330_Order_1_11.3.21.pdf;20cr330_Order_2_11.3.21.pdf
Counsel:
Attached please find two orders issued by Judge Nathan, which will be docketed tomorrow morning.
Please confirm receipt.
Sincerely,
Chambers of the Hon. Alison J. Nathan
EFTA00022327


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=== Page 1 ===
From:
To:
Cc:
Subject: what is it with these guys and Icarus comparisons
Date: Wed, 22 May 2019 14:30:00 +0000
Importance: Normal
"It's the Icarus story, someone who flies too close to the sun," I said. "Did Icarus like massages?" Epstein asked.
http://nymag.com/news/features/41826/
"Some would argue at this point that I flew too close to the sun. As I sit here today, yes, absolutely, I know I did. No
question. Icarus."
https://www.vanityfair.com/news/2019/05/inside-the-epic-fall-of-michael-avenati
Assistant U.S. Attorney
Southern District of New York
EFTA00022480


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=== Page 1 ===
From:
(USANYS)'
To:
USANYS)
Cc:
USANYS)"
(USANYS)"
(USANYS)"
Subject: RE: Epstein FOIA - OCME Report of Autopsy
Date: Thu, 01 Jul 2021 15:18:18 +0000
Yes, all clear to release tomorrow. Thank you.
From:
(USANYS)
Sent: Thursday, July 1, 2021 10:58 AM
To:
USANYS)
Cc:
USANYS)
(USANYS)
(USANYS)
Subject: RE: Epstein FOIA - OCME Report of Autopsy
Sounds good and thanks.
Just confirming-we are all set in your view to release the production tomorrow, right? As in, we're clear in terms of the
UMR and with
and
? Please let us know if there is anything we need to discuss or follow up on at this stage.
Thank you!
From:
(USANYS)
Sent: Wednesday, June 30, 2021 12:34 PM
To:
(USANYS)
Cc:
(USANYS)
(USANYS)
(USANYS)
Subject: RE: Epstein FOIA - OCME Report of Autopsy
OCME asked whether we could send them a copy of the redacted autopsy report. Could you please send me a copy of it
on Friday so I can forward to them? Thank you!
From:
(USANYS)
Sent: Tuesday, June 29, 2021 6:46 PM
To:
USANYS)
Cc:
(USANYS)
(USANYS)
(USANYS)
Subject: RE: Epstein FOIA - OCME Report of Autopsy
Thanks,
Yes, we will ask BOP to redact that photo as well.
From:
(USANYS)
Sent: Tuesday, June 29, 2021 3:45 PM
To:
(USANYS)
Cc:
(USANYS)
(USANYS)
(USANYS)
Subject: RE: Epstein FOIA - OCME Report of Autopsy
and
EFTA00023398

=== Page 2 ===
I spoke with the GC of OCME, who appreciated the head's up. One note for you all: the photo of the hyoid bone on page
12 is in fact Epstein's hyoid bone. To the extent we're redacting the closeup photos from page 13, shouldn't we also
redact the entire photo on page 12?
Thanks,
From:
USANYS)
Sent: Monday, June 28, 2021 5:02 PM
To:
(USANYS)
Cc:
(USANYS)
(USANYS)
(USANYS)
Subject: Epstein FOIA - OCME Report of Autopsy
Please find attached the OCME Report of Autopsy. The boxes show where there will be redactions.
Thanks,
Assistant United States Attorney
EFTA00023399


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c0:
=== Page 1 ===
From:
To:
Subject: Little St James Island - Last Deed of Record
Date: Wed, 07 Aug 2019 13:50:57 +0000
Attachments: 2011009441_Deed_12232011_Little_St_James_LSJ_LLC_and_Nautilus_Inc.pdf
Attached is Last Deed of Record for Little St James Island, dated 12/23/2011, from L.S.J. LLC to Nautilus Inc.
The sole beneficial owner and President of Nautilus Inc is Jeffrey E. Epstein.
Squad C-40 (FAST) Senior Financial Investigator (SFI)
(o)
(c)(
EFTA00020958


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=== Page 1 ===
From: Esther Goldschlager
To:
Subject: Greetings from a law school graduate
Date: Mon, 15 Jul 2019 22:22:31 +0000
Dear
I hope that this note finds you well. I am a young professional (law school graduate) based in D.C. I have been
following the recent Epstein case developments in the media and I wanted to reach out to thank you for your
very meaningful work as a prosecutor.
Best regards,
Esther
EFTA00020989


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=== Page 1 ===
From:
"
To:
Subject: [EXTERNAL] Screenshots from
Date: Fri, 12 Nov 2021 01:44:27 +0000
Inline-Images: image0.png; imagel.png; image2.png
EFTA00023349

=== Page 2 ===
8:39
f
f
LTE
69%
...
E
Epstein Jef
1
Call
Text
Video
1
Mobile
Edit contact
EFTA00023350

=== Page 3 ===
8:35 f f f
LTE
70%
...
G
1
Call
Text
Video
A
Mobile
Edit contact
EFTA00023351

=== Page 4 ===
8:36
f
LTE
70%
...
1
Call
Text
Video
4
Home
Video call on Duo
Voice call on Duo
Edit contact
EFTA00023352


c1: EFTA00022509
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=== Page 1 ===
Page 1728
Epstein #76318-054
From
To
Date
2019/07/24 10:41
Subject:
Epstein #76318-054
Attachments:
TEXT.htm, 2019_07_24_10_40_50.pdf.
Lieutenants,
Please see attached.
Very respectfully,
Forensic Psychologist
LT, U.S. Public Health Service
U.S. Department of Justice
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
Office
Fax: 6
E-mail
"This message is intended for official use and may contain SENSITIVE information. If this message contains
SENSITIVE information, it should be properly delivered, labeled, stored, and disposed of according to
policy."
Page 8910
EFTA00022509

=== Page 2 ===
Page 1729
United States Government
MEMORANDUM
MCC NEW YORK
FEDERAL DEPARTMENT BUREAU OF OF JUSTICE
DATE:
July 24, 2019
TO:
Lieutenant's Office
FROM:
RE:
REMOVE FROM SUICIDE WATCH AND PLACE ON
PSYCHOLOGICAL OBSERVATION
Please remove inmate Epstein #76318-054 from Suicide Watch and place him on Psychological
Observation.
EFTA00022510


c1: EFTA00022456
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=== Page 1 ===
From:
)"
To:
"
)"
Cc:
(USANYS)"
Subject: RE: Wednesday's WebEx
Date: Tue, 03 Aug 2021 20:00:08 +0000
Yes, will do, thanks very much.
Original Message
From:
Sent: Tuesday, August 3, 2021 3:47 PM
To:
)
Cc:
(USANYS)
Subject: RE: Wednesday's WebEx
and
,
We are all set for tomorrow's WebEx with
at 3 p.m. However, we are having some difficulty
forwarding the WebEx to
personal email address. Is it possible for someone at the DOJ to send
the
WebEx invitation directly? His personal email address is
Thanks.
Best,
Original Message
From:
Sent: Wednesday, May 12, 2021 6:20 PM
To:
)
Cc:
i
i
(USANYS)
Subject: RE: Wednesday's WebEx
Well, Happy Thanksgiving to you all!
We will let
know.
Original Message
From:
Sent: Wednesday, May 12, 2021 6:19 PM
To:
Cc:
)
i
;
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
EFTA00022456

=== Page 2 ===
Hi
,
Thanks again for discussing scheduling with us last week. As an update, the Court has issued a scheduling order
for the trial. Jury selection will occur during the week of November 15th, and the trial will begin on November
29th.
Thanks,
Original Message
From:
Sent: Friday, May 7, 2021 12:34 PM
To:
)
Cc:
(USANYS)
Subject: RE: Wednesday's WebEx
,
We spoke with
and explained the government's interest in calling him as a witness for Ms. Maxwell's trial.
He has no specific plans which cannot be moved at this point, but we would only ask that you keep in mind that
he's going to need to fly up to NY
Please keep us posted as scheduling proceeds and, obviously,
please let us know if and when you want to meet with him in advance of trial.
Best,
|
Crowell & Moring LLP
Managing Partner, New York Office
reeye.com/v1/url?k=ca86dcb8-951de475-ca81f85d-ac1f6b017728-
e6396e2944757a19&q=1&e=ddfdafa5-d003-450c-b49a-
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Original Message
From:
Sent: Thursday, May 6, 2021 1:10 PM
To:
EFTA00022457

=== Page 3 ===
Cc:
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Thanks, that would be great. We can use this conference line:
passcode
Original Message
From:
Sent: Thursday, May 6, 2021 12:55 PM
To:
Cc:
X
i
(USANYS)
Subject: Re: Wednesday's WebEx
Of course. How is 3 pm?
|
Crowell & Moring LLP
Managing Partner, New York Office
<mailto:
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EFTA00022458

=== Page 4 ===
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On May 6, 2021, at 12:50 PM,
)
wrote:
External Email
Hi
,
Hope you're doing well. Do you have time for a quick call this afternoon or tomorrow?
Thanks very much,
From:
)
Sent: Wednesday, November 18, 2020 10:52 AM
EFTA00022459

=== Page 5 ===
To:
Cc:
(USANYS)
Subject: RE: Wednesday's WebEx
,
Attached please find the fully executed proffer agreement with the agent's initials and my initials added.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
From:
Sent: Tuesday, November 17, 2020 9:30 PM
To:
<mailto:
)
<mailto:
Cc:
<mailto:
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
Received, thank you very much,
Best,
Assistant United States Attorney
Southern District of New York
<mailto:
From:
<mailto:
Sent: Tuesday, November 17, 2020 8:21 AM
To:
<mailto:
>;
<mailto:
V
Cc:
<mailto:
<mailto:
(USANYS)
EFTA00022460

=== Page 6 ===
<mailto:
Subject: RE: Wednesday's WebEx
--- sorry for the delay. Here is the executed proffer agreement from our last meeting.
Best,
|
Crowell & Moring LLP
Managing Partner, New York Office
+1 212.895.4246 I F: 1212.895.4134
<mailto:
I
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cPrJ6XEFDI7juyMK2yPSEbHkRgK5ZxtLw3QNw0%26e3D> I Web Bio<https://protect2.fireeye.com/v1/url?
EFTA00022461

=== Page 7 ===
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f03o4JqALugzs4pXvJulN6O6ZB67ualzgqX-u0%26e%3D>
Privileged and Confidential Attorney-Client Communication Attorney Work Product This message contains
privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com<mailto:postmaster@crowell.com>) by reply e-
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Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource
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EFTA00022462

=== Page 8 ===
253DBc6HsIYghPlsVjbZolpXL2OPkD7K7DBf3awq0bZu4Kk-2526e-
253D%26d%3DDwIGaQ%26c%3DAnw7wKLFSGyH7zEzIqo-zgMRy5HE-AH-
SibmOy3H7xE%26r%3Dz3qSdxmKBzz6GPGylfF-
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h3CYkK6COxbJuv5_228deYPBnQzFjIxzdrA4P4%26e%3D>
From:
)
<mailto:
Sent: Wednesday, November 11, 2020 1:43 PM
To:
<mailto:
)
<mailto:
Cc:
<mailto:
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
External Email
,
We will be joined by two FBI agents who are focusing on the CBP topics that we have previously discussed. I
expect one of those agents will take the lead on questioning Mr.
The topics we expect to cover include:
*
The identities of any CBP employees Mr.
recalls interacting with Jeffrey Epstein in the Virgin Islands.
* Any steps Mr.
recalls any CBP employees in the Virgin Islands taking to help Epstein and those
traveling with Epstein to enter the country, including any steps that allowed Epstein or those traveling with him
to avoid processing that travelers would normally undergo.
* Any favors Mr.
recalls Epstein doing for CBP employees in the Virgin Islands, such as trips to
Epstein's island.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
From:
<mailto:
Sent: Tuesday, November 10, 2020 1:16 PM
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
just wanted to circle back with you in advance of Thursday's meeting. We want
to be fully
prepared, so if there is any more granularity on this topic (or any additional topic or topics), please let us know.
EFTA00022463

=== Page 9 ===
Thanks,
Crowell & Moring LLP
Managing Partner, New York Office
<mailto:
I
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EFTA00022464

=== Page 10 ===
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Xy0XS2Tm8QkxayqvMwKYzO5M_gF4CakxLTV3To%26e%3D>
Privileged and Confidential Attorney-Client Communication Attorney Work Product This message contains
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Instead, please notify the sender (or postmaster@crowell.com<mailto:postmaster@crowell.com> by reply e-
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Center<https://protect2.fireeye.com/v1/url?k=90b1f976-cf2ac1bb-90b6dd93-ac1f6b017728-
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EFTA00022465

=== Page 11 ===
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From:
)
<mailto:
Sent: Monday, October 26, 2020 6:19 PM
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
External Email
Thanks very much,
Let's plan for 1pm on Thursday, 11/12. I will circulate a WebEx invitation shortly.
We expect to ask Mr.
about his interactions with
the U.S. Customs and Border
Protection employee who worked in Saint Thomas and who had Mr.
listed as a contact in his phone. I
expect we will ask for an approximate timeline of when Mr.
met and interacted with
, the nature
of those interactions, and any interactions
may have had with Epstein (to the best of Mr.
knowledge).
Best,
EFTA00022466

=== Page 12 ===
Assistant United States Attorney
Southern District of New York
<mailto:
From:
<mailto:
Sent: Monday, October 26, 2020 11:58 AM
To:
<mailto:
>;
<mailto:
Cc:
<mailto:
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
Sorry for the delay. Looks like we can do between 11 a.m. and 2 p.m. on Tuesday, 11/10, or any time on
Thursday, 11/12. Let us know if anything in that range will work.
So as to make sure Mr.
is prepared, can you give us an overview of what you expect to cover?
Thanks,
|
Crowell & Moring LLP
Managing Partner, New York Office
<mailto:
I
https://protect2.fireeye.com/v1/url?k=62f6784f-
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EFTA00022467

=== Page 13 ===
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EFTA00022468

=== Page 14 ===
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EFTA00022469

=== Page 15 ===
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Ccsb-odrMbz9xriy4D6V3z_2w9fZWNTxB8pigA%26e)3D>
From:
)
<mailto:
Sent: Thursday, October 22, 2020 10:33 AM
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
External Email
,
As I believe we mentioned when we last spoke, we would like to schedule time for a second interview with Mr.
via WebEx. Are there any days the week of November 9th when your team and Mr.
would be
available? We would expect this proffer to be much shorter than our first, and certainly no more than two hours
at most.
Thanks,
EFTA00022470

=== Page 16 ===
Assistant United States Attorney
Southern District of New York
<mailto:
From:
<mailto:
Sent: Friday, October 9, 2020 4:42 PM
To:
<mailto:
Cc:
<mailto:
<mailto:
(USANYS)
<mailto:
)
<mailto:
Subject: RE: Wednesday's WebEx
Hi
,
Thanks very much. I'm attaching the fully executed copy.
Thanks,
From:
<mailto:
Sent: Thursday, October 8, 2020 9:31 AM
To:
<mailto:
Cc:
<mailto:
<mailto:
(USANYS)
<mailto:
)
<mailto:
Subject: RE: Wednesday's WebEx
Hi all.
Attached please find the signed proffer agreement. It was nice seeing everyone yesterday.
Thanks,
|
Crowell & Moring LLP
Managing Partner, New York Office
I
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EFTA00022471

=== Page 17 ===
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EFTA00022472

=== Page 18 ===
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Privileged and Confidential Attorney-Client Communication Attorney Work Product This message contains
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EFTA00022473

=== Page 19 ===
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource
Center<https://protect2.fireeye.com/v1/urlPk=04eb9138-5b70a9f5-04ecb5dd-ac1f6b017728-
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From:
<mailto:
Sent: Monday, October 5, 2020 4:14 PM
EFTA00022474

=== Page 20 ===
To:
<mailto:
Cc:
<mailto:
<mailto:
(USANYS)
<mailto:
)
<mailto:
Subject: RE: Wednesday's WebEx
External Email
Hi
,
Not a problem at all -- I've added everyone to the calendar invitation. Please let us know if any other tech issues
crop up, and we'd be happy to work through them.
Thanks,
From:
<mailto:
Sent: Monday, October 5, 2020 12:48 PM
To:
)
<mailto:
)
<mailto:
(USANYS)
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
Subject: Wednesday's WebEx
,
,
,
Thanks for sending the WebEx invitation for Wednesday's meeting to me. For whatever reason, the system is not
permitting me to forward the invite, so I would ask that you separately invite those copied on this e-mail: Dan,
and Mr.
, but also
who is in our IT group and will make sure we are good to go
for our meeting.
Thanks,
|
Crowell & Moring LLP
Managing Partner, New York Office
<mailto:
I
https://protect2.fireeye.com/v1/url?k=0f086285-
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EFTA00022475

=== Page 21 ===
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EFTA00022476

=== Page 22 ===
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EFTA00022477

=== Page 23 ===
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EFTA00022478

=== Page 24 ===
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EFTA00022479


c1: EFTA00021931
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021931.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
(USANYS) [Contractor]"
)"
)"
Subject: Re: Sunday Times news story on Ghislaine Maxwell federal indictment
Date: Fri, 24 Jul 2020 22:06:22 +0000
I spoke to him off-the-record (and made sure he knew what that means, that's been an issue with some of our UK
counterparts), he seemed reasonable and It looks like he won't go with the story, at least for now.
Sent from my iPhone
On Jul 24, 2020, at 5:17 PM,
)
wrote:
Hi
if you haven't yet spoken with this person, do you have a quick minute to discuss? I just wanted to
make clear that we have not in any way made public the identity of Victim 3, so I'm not sure what the ethical
basis would be for any reporter to claim to know who this person is. Thanks.
Sent from my iPhone
On Jul 24, 2020, at 1:55 PM,
(USANYS)
wrote:
I'll respond. Thanks.
Sent from my iPhone
On Jul 24, 2020, at 1:35 PM,
)
wrote:
I'm passing this on per our usual policy of forwarding all contacts from the press.
Sent from my iPhone
Begin forwarded message:
From: "Gadher, Dipesh"
Date: July 24, 2020 at 12:55:30 PM EDT
To:
Subject: Sunday Times news story on Ghislaine Maxwell federal indictment
Dear
and
Sorry to contact you out of the blue, but I've been working on the Ghislaine Maxwell sex trafficking
charges story for The Sunday Times newspaper in London over the past few weeks.
The federal indictment highlights three specific victims, identified as Minor Victim 1, 2 and 3.
EFTA00021931

=== Page 2 ===
I believe that "Minor Victim 3" is a British-born woman called
and plan to state this
in a news story on Sunday. She previously waived her right of anonymity at a court hearing attended by
victims of Jeffrey Epstein in New York last August and subsequently appeared on the NBC Dateline show.
Can you or one of your colleagues please urgently let me know if there are any legal issues that would
prevent me from naming Ms
as a key witness in this case?
Do prosecutors plan to publicly identify Ms Maxwell's victims at any point? If so, when?
I can be contacted via email or on
My deadline is 10pm GMT today.
Many thanks for your time and help.
Best wishes
Dipesh Gadher
Home Affairs Correspondent
The Sunday Times
London SE1 9GF
Tel:
Mob:
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EFTA00021932


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From:
)"
To:
Subject: Read: RE: Epstein search materials for upload and privilege review
Date: Wed, 12 Feb 2020 18:19:39 +0000
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 12, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
We write to notify you that the Government may seek to introduce certain evidence at trial.
In particular, the Government may offer certain exhibits at trial that demonstrate that, in addition
to the defendant's conduct with Jeffrey Epstein, the defendant took steps to provide other men
with access to women. We are producing these proposed exhibits today, marked with the
following exhibit numbers: [list].
In addition, please be advised that the Government may call
as a witness
at trial. Today, we are producing Jencks Act materials relating to Ms.
,
who was employed
by Jeffrey Epstein from approximately 2005-2006. The Government anticipates that Ms.
will testify about, among other things, certain documentary evidence relating to the charged
crimes. The Government further anticipates that Ms.
will testify about her role in
scheduling sexualized massages for Jeffrey Epstein with underage girls.
This evidence is admissible as direct evidence of the crimes charged and, in the alternative,
pursuant to Rule 404(b) as proof of the defendant's intent, preparation, plan, knowledge, identity,
and/or absence of mistake of accident with respect to the charges in the above-referenced case.
EFTA00021685

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Page 2
Please note that this letter and the information contained herein is governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential" under the
Protective Order.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
/s
EFTA00021686


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Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 1 of 4
EXHIBIT
27
EFTA00020762

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Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 2 of 4
DECLARATION OF
1. My name is
: and I was born in
2. I was paid by Jeffrey Epstein to interact sexually with him as a minor
on dozens of occasions in his mansion in Palm Beach, Florida from
around 2002 to 2005, and also to bring him other girls who were my
approximate age for the same purposes. I understand that evidence
collected from Epstein's home showed conclusively that I was there
as a minor, along with many other underage girls. Given how many
girls Epstein was sexually abusing, there could not have been any
doubt in anyone's mind that had access to the testimonial and other
evidence that Epstein sexually molested me as a minor (and many
others).
3. My son was very young when the FBI came to speak with me the first
time. I did not know what to do and I was scared. I called Epstein,
who told me not to worry and that he would hire an attorney for me. I
believed that if I told the truth about what happened at Epstein's
house, the police would take my baby from me. That made me really
scared.
4. Through the attorney that Jeffrey Epstein obtained for me, it was
arranged for me to give a statement to the prosecutor investigating
Epstein.
5. While with the attorney Epstein obtained for me I gave a statement to
the prosecutor that was favorable to Epstein. The prosecutors knew
the truth because of the volume of evidence they had, and they
continued to recognize me as a victim of Epstein's crimes.
6. I had been greatly intimidated, which is why I could not be truthful
initially and I wanted to end the threat of the possibility of my child
being taken. My involvement with Epstein from a very young age
was a deep, dark secret and Epstein told me to keep it a secret. I knew
that I was expected to keep it a secret.
7. The more I thought about what was going on, the more I realized that
what Epstein had done to both me and my friends was wrong and that
anyone who was not very wealthy would be punished. At this time, I
EFTA00020763

=== Page 3 ===
Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 3 of 4
wanted Epstein held accountable the same way anyone else would be.
I spoke about this with one of my friends around May 2008. I then
called an attorney, Brad Edwards, around June 2008, understanding
that he was hired to get the prosecutors to talk to us and hear the truth
from me. That was especially important to me because I was finally
represented by someone other than Epstein's attorney and wanted to
talk to the prosecutors about everything I knew.
8. The prosecutors had a lot of information revealing the truth about the
situation at Epstein's house. I had lot of information, too, because I
was one of the young teenagers who had brought many other young
teenagers to Epstein for the purpose of getting paid by Epstein. I
wanted to assist the prosecutors in the investigation. I hired Mr.
Edwards to let them know that I was cooperative and ready to tell
them all of the helpful information I had. I understood that Mr.
Edwards did that.
9. I authorized Mr. Edwards to join me in the lawsuit against the U.S.
Attorney's Office to enforce my rights and to try to get me my chance
to confer with the prosecutors before Mr. Epstein took a plea or the
case was resolved in any way. I just wanted to be treated fairly in the
process.
10. When Epstein pled guilty to a state crime at the end of June 2008,
no one notified me that his plea had anything to do with my case
against him. I did not know, for example, that this plea had some
connection to a crime he committed against me particularly. In fact,
at this young age, I had no idea what was going on and nobody tried
to explain it to me.
11. In July 2008, I attended a federal court hearing with Mr. Edwards.
It was then that I learned for the first time at that hearing that the
prosecutors worked out some sort of secret deal with Epstein that
might block his prosecution for crimes against me. It also appeared
that there was a lot of continued communication between Epstein and
the U.S. Attorney's Office. I was really upset that the U.S.
Attorney's Office seemed like it would not talk with me or the other
victims about what was going on. It was easier to get them to talk to
me when I was represented by Epstein's attorney.
EFTA00020764

=== Page 4 ===
Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 4 of 4
12. I wanted to see this secret deal that the Government had with
Epstein, but they would not give it to me at the hearing. Later, the
other victims and I finally got to see the secret deal after the judge
forced the prosecutors to show it to us.
13. I understand that I did not initially help the investigation by
speaking on Epstein's behalf untruthfully. But I was intimidated and
had good reason to protect myself and my son- - reasons that I think
everyone who was talking to me could obviously see. Also, the
agents and attorneys obviously had a lot of evidence that provided
proof of what Epstein had actually done. Epstein was still supporting
me, providing me a lawyer and in my mind protecting me, so I was in
a position where I felt I had to say certain things. And Epstein
expected me to say those things.
14. Once I wanted to cooperate and tried to cooperate, I was never
given the opportunity to confer with prosecutors from the time they
were informed by my attorney that I was a cooperating witness. I was
never told about the secret deal until after it was already concluded. I
would have had my attorney object if I had been given the chance.
15. I don't feel like I was treated fairly in this process. And I know
Epstein got a really good plea deal because he is rich and powerful.
That doesn't seem fair either.
Executed this 28th
, day of January, 2015.
EFTA00020765


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From: "
To:
)"
Cc:
Subject
Date: Thu, 23 Apr 2020 00:13:00 +0000
Attachments:
.pdf
and
Attached is the
Please treat this as confidential settlement material provided on the same terms as our submission (i.e. FOIA Confidential
treatment requested, Confidential Settlement Material Protected Under Fed. R. Evid 408 and 410, Fed. R. Crim. P. 11 and
state law analogues).
Let us know if there is anything you would like to discuss.
Best,
EFTA00023101


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From:
)"
To:
Cc:
)"
)"
Subject: RE: Epstein search materials for upload and privilege review
Date: Fri, 21 Feb 2020 21:55:48 +0000
Ah, possibly it's the "2020-01-23" folder under Subpoena Returns? If so,
can we please (1) move that to under the
Search Warrant Returns folder, and (2) if at all possible, combine the 37 different subfolders into one? There doesn't
appear to be any distinction between all of those folders so I don't think there's any utility in having so many subgroups.
But let us know if (2) is a problem and happy to discuss.
From:
Sent: Friday, February 21, 2020 16:53
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
I think they are in the Subpoena Returns folder, which I thought was strange. I'm heading to
now but will log in
after that to find them.
From:
Sent: Friday, February 21, 2020 4:32 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
just tried calling but didn't catch you - I don't see where these are located in Relativity? I think they should be under
"Search Warrant Returns" but I don't see them there (or anywhere else under the Epstein overall folder). Let me know if
I've just missed them, which is entirely possible, or if they're not accessible to us yet? Thank you!
From:
Sent: Thursday, February 20, 2020 21:12
To:
is
Cc:
is
Subject: Re: Epstein search materials for upload and privilege review
The NP folder has been released.
EFTA00020807

=== Page 2 ===
On Feb 20, 2020, at 2:28 PM,
wrote:
Here's the STR and the data should be released soon, it's just taking a while because the load is so large.
From:
Sent: Thursday, February 20, 2020 11:42 AM
To:
is
Cc:
is
Subject: RE: Epstein search materials for upload and privilege review
New data is loaded and we've segregated the PP hits; you should have access to the new data today. Will keep you
posted.
Thanks,
From:
Sent: Wednesday, February 12, 2020 1:04 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
wanted to follow up on this - is the data fully uploaded, or did it get delayed? Thanks.
From:
Sent: Friday, February 07, 2020 11:25
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
Great, thank you!
From:
Sent: Friday, February 07, 2020 09:34
To:
Cc:
is
)
is
Subject: RE: Epstein search materials for upload and privilege review
The data should be ready by Monday morning.
From:
Sent: Tuesday, February 4, 2020 6:58 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
EFTA00020808

=== Page 3 ===
Wanted to quickly check the status of the below - it's only been a couple weeks, so totally understand it may not be
complete, but hopefully we're getting close? If you could please check with the vendor and let us know, we'd be grateful
- and we'll plan to get it to
asap once we have access.
thanks,
From:
)
Sent: Tuesday, January 21, 2020 18:50
To:
Cc:
is
)
is
Subject: RE: Epstein search materials for upload and privilege review
We've received a hard drive from FBI CART, which they've processed from devices seized and searched in connection
with the Epstein case. Can we please get those materials uploaded to Relativity, for privilege review by
(copied
here)? I've left the hard drive with the materials on your chair. (And if we could please get that hard drive back once
the materials are uploaded, the FBI has another batch they want to transmit to us for the same process, so that will also
be coming shortly.)
And then
these will be subject to just the exact same privilege review you previously ran in connection with Epstein
search warrant returns.
Please let us know if any questions or issues at all? And thanks very much as always.
<STR_Epstein_Privilege Terms_02.14.2020.pdf>
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=== Page 1 ===
From
To: BOBBI C STERNHEIM
Cc:
Christian Everdell
"Mark S. Cohen"
Subject: URGENT RE: Ghislaine Maxwell 02879-509
Date: Mon, 28 Dec 2020 16:00:30 +0000
Good afternoon:
Ms. Maxwell has three blankets and had those blankets throughout the
weekend. Although one was removed, it was in fact replaced shortly
thereafter. Additionally, Ms. Maxwell was provided a holiday meal and
all additional meals she is entitled to. The temperature was checked on
the night of 12/26/20 and was reported to be 76.5 degrees.
Best,
Staff Attorney
Department of Justice
Federal Bureau of Prisons
Metropolitan Detention Center Brooklyn
80 29th Street
Brooklyn, New York 11232
SENSITIVE/PRIVILEGED COMMUNICATION
The information contained in this electronic message and any and all
accompanying documents constitutes sensitive information. This
information is the property of the U.S. Department of Justice. If you
are not the intended recipient of this information, any disclosures,
copying, distribution, or the taking of any action in reliance on this
information is strictly prohibited. If you received this message in
error, please notify us immediately to make arrangements for its return
to us.
>>> BOBBI C STERNHEIM
12/26/2020 4:37 PM
Good afternoon-
I am informed that Ms. Maxwell's blanket has been removed and that she
was not
provided a complete holiday meal.
She is cold and hungry.
I am urging you to immediately provide her with blankets.
She is cold, her isolation cell is not insulated, and the temperature
drops in the evening.
It is currently a freezing 32 degrees and the temperature is forecast
to drop to at least 28 degrees this evening.
It is inexcusable for her to be deprived of a blanket and proper
EFTA00022320

=== Page 2 ===
nutrition.
Despite repeated complaints, the MDC fails to provide basic
requirements to Ms. Maxwell.
I am requesting an emergency legal call with her. My number is
Promptly correct these problems, which will be reported to the Court.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
V
> *Covid-19 Notice: The West 19th Street office is currently closed
but we continue to work remotely.
> Please use email or fax, instead of regular mail, for all
correspondence during this time.
> We continue to work regular business hours throughout this situation.
> Thank you for your consideration. Our best wishes for your good
health and well being.
This message and any attached documents contain information from the
Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy,
distribute, or use this information.
If you have received this transmission in error, please notify the
sender immediately by reply e-mail and then delete this message. Thank
you.
EFTA00022321


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From:
(USANYS)"
To:
(USANYS)"
Subject: FW: RE: draft response to Epstein defense preservation requests
Date: Wed, 07 Aug 2019 13:47:27 +0000
I'm looking at this, by the way, as you probably guessed. Can send you my edits if you'd like to look next.
From:
(USANYS)
Sent: Wednesday, August 7, 2019 9:
is
(USANYS)
Cc:
>;
)
Subject: RE: RE: draft response to Epstein defense preservation requests
I'm not sure I had previously seen the 8/1 supplemental request. Let me know if one of you has a moment to discuss.
From:
Sent: Tuesday, August 6, 2019 3:01 PM
To:
(USANYS)
>;
(USANYS)
Cc:
in
)
Subject: RE: draft response to Epstein defense preservation requests
This has been in the works for a little while, due to various other things that have come up in the interim, but we didn't
want it to get lost given the discovery motion schedule. The attached is based on our conversations with
including
his email with suggested language for the prefatory language, and responds to the two attached defense letters. Happy to
discuss anytime and to incorporate comments and suggestions.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00022619


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EXHIBIT D
EFTA00023059

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DEPARTMENT OF JUSTICE
DEPARTMENT DEPA OFFICE * OF PROFESSIONAL OF JUSTER *
OFFICE OF
PROFESSIONAL RESPONSIBILITY
EXECUTIVE SUMMARY OF REPORT
Investigation into the
U.S. Attorney's Office for the Southern District of Florida's
Resolution of Its 2006-2008 Federal Criminal Investigation of
Jeffrey Epstein and Its Interactions with Victims during the Investigation
November 2020
EFTA00023060

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EXECUTIVE SUMMARY
The Department of Justice (Department) Office of Professional Responsibility (OPR)
investigated allegations that in 2007-2008, prosecutors in the U.S. Attorney's Office for the
Southern District of Florida (USAO) improperly resolved a federal investigation into the criminal
conduct of Jeffrey Epstein by negotiating and executing a federal non-prosecution agreement
(NPA). The NPA was intended to end a federal investigation into allegations that Epstein engaged
in illegal sexual activity with girls. 1 OPR also investigated whether USAO prosecutors committed
professional misconduct by failing to consult with victims of Epstein's crimes before the NPA was
signed or by misleading victims regarding the status of the federal investigation after the signing.
I.
OVERVIEW OF FACTUAL BACKGROUND
The Palm Beach (Florida) Police Department (PBPD) began investigating Jeffrey Epstein
in 2005, after the parents of a 14-year-old girl complained that Epstein had paid her for a massage.
Epstein was a multi-millionaire financier with residences in Palm Beach, New York City, and
other United States and foreign locations. The investigation led to the discovery that Epstein used
personal assistants to recruit girls to provide massages to him, and in many instances, those
massages led to sexual activity. After the PBPD brought the case to the State Attorney's Office, a
Palm Beach County grand jury indicted Epstein, on July 19, 2006, for felony solicitation of
prostitution in violation of Florida Statute § 796.07. However, because the PBPD Chief and the
lead Detective were dissatisfied with the State Attorney's handling of the case and believed that
the state grand jury's charge did not address the totality of Epstein's conduct, they referred the
matter to the Federal Bureau of Investigation (FBI) in West Palm Beach for a possible federal
investigation.
The FBI brought the matter to an Assistant U.S. Attorney (AUSA), who opened a file with
her supervisor's approval and with the knowledge of then U.S. Attorney R. Alexander Acosta.
She worked with two FBI case agents to develop a federal case against Epstein and, in the course
of the investigation, they discovered additional victims. In May 2007, the AUSA submitted to her
supervisors a draft 60-count indictment outlining charges against Epstein. She also provided a
lengthy memorandum summarizing the evidence she had assembled in support of the charges and
addressing the legal issues related to the proposed charges.
For several weeks following submission of the prosecution memorandum and proposed
indictment, the AUSA's supervisors reviewed the case to determine how to proceed. At a July 31,
2007 meeting with Epstein's attorneys, the USAO offered to end its investigation if Epstein pled
guilty to state charges, agreed to serve a minimum of two years' incarceration, registered as a
sexual offender, and agreed to a mechanism through which victims could obtain monetary
damages. The USAO subsequently engaged in additional meetings and communications with
Epstein's team of attorneys, ultimately negotiating the terms of a state-based resolution of the
federal investigation, which culminated in the signing of the NPA on September 24, 2007. The
I
As used in this Report, including in quoted documents and statements, the word "girls" refers to females who
were under the age of 18 at the time of the alleged conduct. Under Florida law, a minor is a person under the age
of 18.
EFTA00023061

=== Page 4 ===
NPA required Epstein to plead guilty in state court to the then-pending state indictment against
him and to an additional criminal information charging him with a state offense that would require
him to register as a sexual offender-specifically, procurement of minors to engage in prostitution,
in violation of Florida Statute $ 796.03. The NPA required Epstein to make a binding
recommendation that the state court sentence him to serve 18 months in the county jail followed
by 12 months of community control (home detention or "house arrest"). The NPA also included
provisions designed to facilitate the victims' recovery of monetary damages from Epstein. In
exchange, the USAO agreed to end its investigation of Epstein and to forgo federal prosecution in
the Southern District of Florida of him, four named co-conspirators, and "any potential
co-conspirators." Victims were not informed of, or consulted about, a potential state resolution or
the NPA prior to its signing.
The signing of the NPA did not immediately lead to Epstein's guilty plea and incarceration,
however. For the next nine months, Epstein deployed his extensive team of prominent attorneys
to try to change the terms that his team had negotiated and he had approved, while simultaneously
seeking to invalidate the entire NPA by persuading senior Department officials that there was no
federal interest at issue and the matter should be left to the discretion of state law enforcement
officials. Through repeated communications with the USAO and senior Department officials,
defense counsel fought the government's interpretation of the NPA's terms. They also sought and
obtained review by the Department's Criminal Division and then the Office of the Deputy Attorney
General, primarily on the issue of federal jurisdiction over what the defense insisted was "a
quintessentially state matter." After reviewing submissions by the defense and the USAO, on
June 23, 2008, the Office of the Deputy Attorney General informed defense counsel that the
Deputy Attorney General would not intervene in the matter. Only then did Epstein agree to fulfill
his obligation under the NPA, and on June 30, 2008, he appeared in state court and pled guilty to
the pending state indictment charging felony solicitation of prostitution and, pursuant to the NPA,
to a criminal information charging him with procurement of minors to engage in prostitution.
Upon the joint request of the defendant and the state prosecutor, and consistent with the NPA, the
court immediately sentenced Epstein to consecutive terms of 12 months' incarceration on the
solicitation charge and 6 months' incarceration on the procurement charge, followed by 12 months
of community control. Epstein began serving the sentence that day, in a minimum-security Palm
Beach County facility. A copy of the NPA was filed under seal with the state court.
On July 7, 2008, a victim, identified as "Jane Doe," filed in federal court in the Southern
District of Florida an emergency petition alleging that the government violated the Crime Victims'
Rights Act (CVRA), 18 U.S.C. $ 3771, when it resolved the federal investigation of Epstein
without consulting with victims, and seeking enforcement of her CVRA rights.² In responding to
the petition, the government, represented by the USAO, revealed the existence of the NPA, but did
not produce it to the petitioners until the court directed it to be turned over subject to a protective
order; the NPA itself remained under seal in the federal district court. After the initial filings and
hearings, the CVRA case was dormant for almost two years while the petitioners pursued civil
cases against Epstein.
2
Emergency Victim's Petition for Enforcement of Crime Victim's [sic] Rights Act, 18 U.S.C. Section 3771,
Doe V. United States, Case No. 9:08-cv-80736-KAM (S.D. Fla. July 7, 2008). Another victim subsequently joined
the litigation as "Jane Doe 2."
ii
EFTA00023062

=== Page 5 ===
Soon after he was incarcerated, Epstein applied for the Palm Beach County Sheriff's work
release program, and the Sheriff approved his application. In October 2008, Epstein began
spending 12 hours a day purportedly working at the "Florida Science Foundation," an entity
Epstein had recently incorporated that was co-located at the West Palm Beach office of one of
Epstein's attorneys. Although the NPA specified a term of incarceration of 18 months, Epstein
received "gain time," that is, time off for good behavior, and he actually served less than 13 months
of incarceration. On July 22, 2009, Epstein was released from custody to a one-year term of home
detention as a condition of community control, and he registered as a sexual offender with the
Florida Department of Law Enforcement. After victims and news media filed suit in Florida courts
for release of the copy of the NPA that had been filed under seal in the state court file, a state judge
in September 2009 ordered it to be made public.
By mid-2010, Epstein reportedly settled multiple civil lawsuits brought against him by
victims seeking monetary damages, including the two petitioners in the CVRA litigation. During
the CVRA litigation, the petitioners sought discovery from the USAO, which made substantial
document productions, filed lengthy privilege logs in support of its withholding of documents, and
submitted declarations from the AUSA and the FBI case agents who conducted the federal
investigation. The USAO opposed efforts to unseal various records, as did Epstein, who was
permitted to intervene in the litigation with respect to certain issues. Nevertheless, the court
ultimately ordered that substantial records relating to the USAO's resolution of the Epstein case
be made public. During the course of the litigation, the court made numerous rulings interpreting
the CVRA. After failed efforts to settle the case, the parties' cross motions for summary judgment
remained pending for more than a year.
In 2017, President Donald Trump nominated Acosta to be Secretary of Labor. At his
March 2017 confirmation hearing, Acosta was questioned only briefly about the Epstein case. On
April 17, 2017, the Senate confirmed Acosta's appointment as Labor Secretary.
In the decade following his release from incarceration, Epstein reportedly continued to
settle multiple civil suits brought by many, but not all, of his victims. Epstein was otherwise able
to resume his lavish lifestyle, largely avoiding the interest of the press. On November 28, 2018,
however, the Miami Herald published an extensive investigative report about state and federal
criminal investigations initiated more than 12 years earlier into allegations that Epstein had coerced
girls into engaging in sexual activity with him at his Palm Beach estate. 3 The Miami Herald
reported that in 2007, Acosta entered into an "extraordinary" deal with Epstein in the form of the
NPA, which permitted Epstein to avoid federal prosecution and a potentially lengthy prison
sentence by pleading guilty in state court to "two prostitution charges." According to the Miami
Herald, the government also immunized from prosecution Epstein's co-conspirators and
concealed from Epstein's victims the terms of the NPA. Through its reporting, which included
interviews of eight victims and information from publicly available documents, the newspaper
painted a portrait of federal and state prosecutors who had ignored serious criminal conduct by a
wealthy man with powerful and politically connected friends by granting him a "deal of a lifetime"
that allowed him both to escape significant punishment for his past conduct and to continue his
3
Julie K. Brown, "Perversion of Justice," Miami Herald, Nov. 28, 2018. https://www.miamiherald.com/
news/local/article220097825.html
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abuse of minors. The Miami Herald report led to public outrage and media scrutiny of the
government's actions.
On February 21, 2019, the district court granted the CVRA case petitioners' Motion for
Partial Summary Judgment, ruling that the government violated the CVRA in failing to advise the
victims about its intention to enter into the NPA. The court also found that letters the government
sent to victims after the NPA was signed, describing the investigation as ongoing, "mislead [sic]
the victims to believe that federal prosecution was still a possibility." The court also highlighted
the inequity of the USAO's failure to communicate with the victims while at the same time
engaging in "lengthy negotiations" with Epstein's counsel and assuring the defense that the NPA
would not be "made public or filed with the court." The court ordered the parties to submit
additional briefs regarding the appropriate remedies. After the court's order, the Department
recused the USAO from the CVRA litigation and assigned the U.S. Attorney's Office for the
Northern District of Georgia to handle the case for the government. Among the remedies sought
by the petitioners, and opposed by the government, was rescission of the NPA and federal
prosecution of Epstein.
On July 2, 2019, the U.S. Attorney's Office for the Southern District of New York obtained
a federal grand jury indictment charging Epstein with one count of sex trafficking of minors and
one count of conspiracy to commit sex trafficking of minors. The indictment alleged that from
2002 until 2005, Epstein created a vast network of underage victims in both New York and Florida
whom he sexually abused and exploited. Epstein was arrested on the charges on July 6, 2019. In
arguing for Epstein's pretrial detention, prosecutors asserted that agents searching Epstein's
Manhattan residence found thousands of photos of nude and half-nude females, including at least
one believed to be a minor. The court ordered Epstein detained pending trial, and he was remanded
to the custody of the Bureau of Prisons and held at the Metropolitan Correctional Center in
Manhattan.
Meanwhile, after publication of the November 2018 Miami Herald report, the media and
Congress increasingly focused attention on Acosta as the government official responsible for the
NPA. On July 10, 2019, Acosta held a televised press conference to defend his and the USAO's
actions. Acosta stated that the Palm Beach State Attorney's Office "was ready to allow Epstein to
walk free with no jail time, nothing." According to Acosta, because USAO prosecutors considered
this outcome unacceptable, his office pursued a difficult and challenging case and obtained a
resolution that put Epstein in jail, forced him to register as a sexual offender, and provided victims
with the means to obtain monetary damages. Acosta's press conference did not end the
controversy, however, and on July 12, 2019, Acosta submitted to the President his resignation as
4
See, e.g., Ashley Collman, "Stunning new report details Trump's labor secretary's role in plea deal for
billionaire sex abuser," The Business Insider, Nov. 29, 2018; Cynthia McFadden, "New Focus on Trump Labor
Secretary's role in unusual plea deal for billionaire accused of sexual abuse," NBC Nightly News, Nov. 29, 2018; Anita
Kumar, "Trump labor secretary out of running for attorney general after Miami Herald report," McClatchy Washington
Bureau, Nov. 29, 2018; Emily Peck, "How Trump's Labor Secretary Covered For A Millionaire Sex Abuser,"
Huffington Post, Nov. 29, 2018; Julie K. Brown, et al., "Lawmakers issue call for investigation of serial sex abuser
Jeffrey Epstein's plea deal," Miami Herald, Dec. 6, 2018.
5
Doe V. United States, 359 F. Supp. 3d 1201 (S.D. Fla., Feb. 21, 2019) (Opinion and Order, 9:08-80736-CIV-
Marra).
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=== Page 7 ===
Secretary of Labor. In a brief oral statement, Acosta explained that continued media attention on
his handling of the Epstein investigation rather than on the economy was unfair to the Labor
Department.
On August 10, 2019, Epstein was found hanging in his cell and was later pronounced dead.
The New York City Chief Medical Examiner concluded that Epstein had committed suicide.
As a result of Epstein's death, the U.S. Attorney's Office for the Southern District of
New York filed a nolle prosequi to dismiss the pending indictment against Epstein. On
August 27, 2019, the district court held a hearing at which more than a dozen of Epstein's
victims-including victims of the conduct in Florida that was addressed through the NPA-spoke
about the impact of Epstein's crimes. The court dismissed the Epstein indictment on
August 29, 2019.
After Epstein's death, the federal district court in Florida overseeing the CVRA litigation
denied the petitioners their requested remedies and closed the case as moot. Among its findings,
the court concluded that although the government had violated the CVRA, the government had
asserted "legitimate and legally supportable positions throughout this litigation," and therefore had
not litigated in bad faith. The court also noted it expected the government to "honor its
representation that it will provide training to its employees about the CVRA and the proper
treatment of crime victims," as well as honoring its promise to meet with the victims.
On September 30, 2019, CVRA petitioner "Jane Doe 1" filed in her true name a petition
for a writ of mandamus in the United States Court of Appeals for the Eleventh Circuit, seeking
review of the district court's order denying all of her requested remedies. In its responsive brief,
the government argued that "as a matter of law, the legal obligations under the CVRA do not attach
prior to the government charging a case" and thus, "the CVRA was not triggered in [the Southern
District of Florida] because no criminal charges were brought." Nevertheless, during oral
argument, the government conceded that the USAO had not been "fully transparent" with the
petitioner and had "made a mistake in causing her to believe that the case was ongoing when in
fact the NPA had been signed." On April 14, 2020, a divided panel of the Court of Appeals denied
the petition, ruling that CVRA rights do not attach until a defendant has been criminally charged.
On August 7, 2020, the court granted the petition for rehearing en banc and vacated the panel's
opinion; as of the date of this Report, a briefing schedule has been issued, and oral argument is set
for December 3, 2020.
II.
THE INITIATION AND SCOPE OF OPR'S INVESTIGATION
After the Miami Herald published its investigative report on November 28, 2018,
U.S. Senator Ben Sasse, Chairman of the Senate Judiciary Subcommittee on Oversight, Agency
Action, Federal Rights and Federal Courts, sent a December 3, 2018 letter to OPR, citing the Miami
Herald's report and requesting that OPR "open an investigation into the instances identified in this
reporting of possible misconduct by Department of Justice attorneys." On February 6, 2019, the
Department of Justice Office of Legislative Affairs advised Senator Sasse that OPR had opened
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an investigation into the matter and would review the USAO's decision to resolve the federal
investigation of Epstein through the NPA.⁶
After the district court issued its ruling in the CVRA litigation, on February 21, 2019, OPR
included within the scope of its investigation an examination of the government's conduct that
formed the basis for the court's findings that the USAO violated the CVRA in failing to afford
victims a reasonable right to confer with the government about the NPA before the agreement was
signed and that the government affirmatively misled victims about the status of the federal
investigation.
During the course of its investigation, OPR obtained and reviewed hundreds of thousands
of records from the USAO, the FBI, and other Department components, including the Office of
the Deputy Attorney General, the Criminal Division, and the Executive Office for U.S. Attorneys.
The records included emails, letters, memoranda, and investigative materials. OPR also collected
and reviewed materials relating to the state investigation and prosecution of Epstein. OPR also
examined extensive publicly available information, including depositions, pleadings, orders, and
other court records, and reviewed media reports and interviews, articles, podcasts, and books
relating to the Epstein case.
In addition to this extensive documentary review, OPR conducted more than 60 interviews
of witnesses, including the FBI case agents, their supervisors, and FBI administrative personnel;
current and former USAO staff and attorneys; current and former Department attorneys and senior
managers, including a former Deputy Attorney General and a former Assistant Attorney General
for the Criminal Division; and the former State Attorney and former Assistant State Attorney in
charge of the state investigation of Epstein. OPR also interviewed several victims and attorneys
representing victims, and reviewed written submissions from victims, concerning victim contacts
with the USAO and the FBI.
OPR identified former U.S. Attorney Acosta, three former USAO supervisors, and the
AUSA as subjects of its investigation based on preliminary information indicating that each of
them was involved in the decision to resolve the case through the NPA or in the negotiations
leading to the agreement. OPR deems a current or former Department attorney to be a subject of
its investigation when the individual's conduct is within the scope of OPR's review and may result
in a finding of professional misconduct. OPR reviewed prior public statements made by Acosta
and another subject. All five subjects cooperated fully with OPR's investigation. OPR requested
that all of the subjects provide written responses detailing their involvement in the federal
investigation of Epstein, the drafting and execution of the NPA, and decisions relating to victim
notification and consultation. OPR received and reviewed written responses from all of the
subjects, and subsequently conducted extensive interviews of each subject under oath and before
a court reporter. Each subject was represented by counsel and had access to relevant
contemporaneous documents before the subject's OPR interview. The subjects reviewed and
provided comments on their respective interview transcripts and on OPR's draft report. OPR
6
The federal government was closed from December 22, 2018, to January 25, 2019. After initiating its
investigation, OPR also subsequently received other letters from U.S. Senators and Representatives inquiring into the
status of the OPR investigation.
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=== Page 9 ===
carefully considered the comments and made changes, or noted comments, as OPR deemed
appropriate; OPR did not, however, alter its findings and conclusions.
Finally, OPR reviewed relevant case law, statutes, regulations, Department policy, and
attorney professional responsibility rules as necessary to resolve the issues presented in this case
and to determine whether the subjects committed professional misconduct.
As part of its investigation, OPR examined the interactions between state officials and the
federal investigators and prosecutors, but because OPR does not have jurisdiction over state
officials, OPR did not investigate, or reach conclusions about, their conduct regarding the state
investigation.⁷ Because OPR's mission is to ensure that Department attorneys adhere to the
standards of professional conduct, OPR's investigation focused on the actions of the subject
attorneys rather than on determining the full scope of Epstein's and his assistants' criminal
behavior. Accordingly, OPR considered the evidence and information regarding Epstein's and his
assistants' conduct as it was known to the subjects at the time they performed their duties as
Department attorneys. Additional evidence and information that came to light after June 30, 2008,
when Epstein entered his guilty plea under the NPA, did not affect the subjects' actions prior to
that date, and OPR did not evaluate the subjects' conduct on the basis of that subsequent
information.
OPR's investigation occurred approximately 12 years after most of the significant events
relating to the USAO's investigation of Epstein, the NPA, and Epstein's guilty plea. As a result,
many of the subjects and witnesses were unable to recall the details of events or their own or
others' actions occurring in 2006-2008, such as conversations, meetings, or documents they
reviewed at the time. 8 However, OPR's evaluation of the subjects' conduct was aided significantly
by extensive, contemporaneous emails among the prosecutors and communications between the
government and defense counsel. These records often referred to the interactions among the
participants and described important decisions and, in some instances, the bases for them.
III.
OVERVIEW OF OPR'S ANALYTICAL FRAMEWORK
OPR's primary mission is to ensure that Department attorneys perform their duties in
accordance with the highest professional standards, as would be expected of the nation's principal
law enforcement agency. Accordingly, OPR investigates allegations of professional misconduct
against current or former Department attorneys related to the exercise of their authority to
7
In August 2019, Florida Governor Ron DeSantis announced that he had directed the Florida Department of
Law Enforcement to open an investigation into the conduct of state authorities relating to Epstein. As reported, the
investigation focuses on Epstein's state plea agreement and the Palm Beach County work release program.
8
OPR was cognizant that Acosta and the three managers all left the USAO during, or not long after resolution
of, the Epstein case, while the AUSA remained with the USAO until mid-2019. Moreover, as the line prosecutor in
the Epstein investigation and also as co-counsel in the CVRA litigation until the USAO was recused from that
litigation in early 2019, the AUSA had continuous access to the USAO documentary record and numerous occasions
to review these materials in the course of her official duties. Additionally, in responding to OPR's request for a written
response, and in preparing to be interviewed by OPR, the AUSA was able to refresh her recollection with these
materials to an extent not possible for the other subjects, who were provided with relevant documents by OPR in
preparation for their interviews.
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=== Page 10 ===
investigate, litigate, or provide legal advice.9 OPR also has jurisdiction to investigate allegations
of misconduct against Department law enforcement agents when they relate to a Department
attorney's alleged professional misconduct.
In its investigations, OPR determines whether a clear and unambiguous standard governs
the challenged conduct and whether a subject attorney violated that standard. Department
attorneys are subject to various legal obligations and professional standards in the performance of
their duties, including the Constitution, statutes, standards of conduct imposed by attorney
licensing authorities, and Department regulations and policies. OPR finds misconduct when it
concludes by a preponderance of the evidence that a subject attorney violated such a standard
intentionally or recklessly. Pursuant to OPR's analytical framework, when OPR concludes that
(1) no clear and unambiguous standard governs the conduct in question or (2) the subject did not
intentionally or recklessly violate the standard that governs the conduct, then it concludes that the
subject's conduct does not constitute professional misconduct. In some cases, OPR may conclude
that a subject attorney's conduct does not satisfy the elements necessary for a professional
misconduct finding, but that the circumstances warrant another finding. In such cases, OPR may
conclude that a subject attorney exercised poor judgment, made a mistake, or otherwise acted
inappropriately under the circumstances. OPR may also determine that the subject attorney's
conduct was appropriate under the circumstances. 10
IV.
ISSUES CONSIDERED
In this investigation, OPR considered two distinct sets of allegations. The first relates to
the negotiation, execution, and implementation of the NPA. The second relates to the USAO's
interactions with Epstein's victims and adherence to the requirements of the CVRA. The two sets
of issues are described below and are analyzed separately in this Report.
A.
The Negotiation, Execution, and Implementation of the NPA
In evaluating whether any of the subjects committed professional misconduct, OPR
considered whether any of the NPA's provisions violated a clear or unambiguous statute,
professional responsibility rule or standard, or Department regulation or policy. In particular, OPR
considered whether the NPA violated standards relating to (1) charging decisions, (2) declination
of criminal charges, (3) deferred or non-prosecution agreements, (4) plea agreements, (5) grants
9
28 C.F.R. § 0.39a(a)(1). OPR has authority to investigate the professional conduct of attorneys occurring
during their employment by the Department, regardless of whether the attorney left the Department before or during
OPR's investigation. Over its 45-year history, OPR has routinely investigated the conduct of former Department
attorneys. Although former Department attorneys cannot be disciplined by the Department, OPR's determination that
a former Department attorney violated state rules of professional conduct for attorneys could result in a referral to an
appropriate state attorney disciplinary authority. Furthermore, findings resulting from investigations of the conduct
of Department attorneys, even former employees, may assist Department managers in supervising future cases.
10
In some instances, OPR declines to open an investigation based upon a review of the initial complaint or after
a preliminary inquiry into the matter. In December 2010, one of the attorneys representing victims in the CVRA
litigation raised allegations that Epstein may have exerted improper influence over the federal criminal investigation
and that the USAO had deceived the victims of Epstein's crimes about the existence of the NPA. Pursuant to its
standard policy, OPR declined to open an investigation into those allegations at that time in deference to the
then-pending CVRA litigation.
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=== Page 11 ===
of immunity, or (6) the deportation of criminal aliens. The potentially applicable standards that
OPR considered as to each of these issues are identified and discussed later in this Report. OPR
also examined whether the evidence establishes that any of the subjects were influenced to enter
into the NPA, or to include in the NPA terms favorable to Epstein, because of an improper motive,
such as a bribe, political consideration, personal interest, or favoritism. OPR also examined and
discusses in this Report significant events that occurred after the NPA was negotiated and signed
that shed additional light on the USAO's handling of the Epstein investigation.
B.
The District Court's Conclusion That the USAO Violated the CVRA
To address the district court's adverse judicial findings, OPR assessed the manner, content,
and timing of the government's interactions with victims both before and after the NPA was
signed, including victim notification letters issued by the USAO and the FBI and interviews
conducted by the USAO. OPR considered whether any of the subject attorneys violated any clear
and unambiguous standard governing victim consultation or notification. OPR examined the
government's lack of consultation with the victims before the NPA was signed, as well as the
circumstances relating to the district court's finding that the USAO affirmatively misled Epstein's
victims about the status of the federal investigation after the NPA was signed.
V.
OPR'S FINDINGS AND CONCLUSIONS
OPR evaluated the conduct of each subject and considered his or her individual role in
various decisions and events. Acosta, however, made the pivotal decision to resolve the federal
investigation of Epstein through a state-based plea and either developed or approved the terms of
the initial offer to the defense that set the beginning point for the subsequent negotiations that led
to the NPA. Although Acosta did not sign the NPA, he participated in its drafting and approved
it, with knowledge of its terms. During his OPR interview, Acosta acknowledged that he approved
the NPA and accepted responsibility for it. Therefore, OPR considers Acosta to be responsible for
the NPA and for the actions of the other subjects who implemented his decisions. Acosta's overall
responsibility for the government's interactions or lack of communication with the victims is less
clear, but Acosta affirmatively made certain decisions regarding victim notification, and OPR
evaluates his conduct with respect to those decisions.
A.
Findings and Conclusions Relating to the NPA
With respect to all five subjects of OPR's investigation, OPR concludes that the subjects
did not commit professional misconduct with respect to the development, negotiation, and
approval of the NPA. Under OPR's framework, professional misconduct requires a finding that a
subject attorney intentionally or recklessly violated a clear and unambiguous standard governing
the conduct at issue. OPR found no clear and unambiguous standard that required Acosta to indict
Epstein on federal charges or that prohibited his decision to defer prosecution to the state.
Furthermore, none of the individual terms of the NPA violated Department or other applicable
standards.
As the U.S. Attorney, Acosta had the "plenary authority" under established federal law and
Department policy to resolve the case as he deemed necessary and appropriate, as long as his
decision was not motivated or influenced by improper factors. Acosta's decision to decline to
initiate a federal prosecution of Epstein was within the scope of his authority, and OPR did not
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=== Page 12 ===
find evidence that his decision was based on corruption or other impermissible considerations,
such as Epstein's wealth, status, or associations. Evidence shows that Acosta resisted defense
efforts to have the matter returned to the state for whatever result state authorities deemed
appropriate, and he refused to eliminate the incarceration and sexual offender registration
requirements. OPR did not find evidence establishing that Acosta's "breakfast meeting" with one
of Epstein's defense counsel in October 2007 led to the NPA, which had been signed weeks earlier,
or to any other significant decision that benefited Epstein. The contemporaneous records show
that USAO managers' concerns about legal issues, witness credibility, and the impact of a trial on
the victims led them to prefer a pre-charge resolution and that Acosta's concerns about the proper
role of the federal government in prosecuting solicitation crimes resulted in his preference for a
state-based resolution. Accordingly, OPR does not find that Acosta engaged in professional
misconduct by resolving the federal investigation of Epstein in the way he did or that the other
subjects committed professional misconduct through their implementation of Acosta's decisions.
Nevertheless, OPR concludes that Acosta's decision to resolve the federal investigation
through the NPA constitutes poor judgment. Although this decision was within the scope of
Acosta's broad discretion and OPR does not find that it resulted from improper factors, the NPA
was a flawed mechanism for satisfying the federal interest that caused the government to open its
investigation of Epstein. In Acosta's view, the federal government's role in prosecuting Epstein
was limited by principles of federalism, under which the independent authority of the state should
be recognized, and the federal responsibility in this situation was to serve as a "backstop" to state
authorities by encouraging them to do more. However, Acosta failed to consider the difficulties
inherent in a resolution that relied heavily on action by numerous state officials over whom he had
no authority; he resolved the federal investigation before significant investigative steps were
completed; and he agreed to several unusual and problematic terms in the NPA without the
consideration required under the circumstances. In sum, Acosta's application of federalism
principles was too expansive, his view of the federal interest in prosecuting Epstein was too
narrow, and his understanding of the state system was too imperfect to justify the decision to use
the NPA. Furthermore, because Acosta assumed a significant role in reviewing and drafting the
NPA and the other three subjects who were supervisors left the USAO, were transitioning to other
jobs, or were absent at critical junctures, Acosta should have ensured more effective coordination
and communication during the negotiations and before approving the final NPA. The NPA was a
unique resolution, and one that required greater oversight and supervision than Acosta provided.
B.
Findings and Conclusions Relating to the Government's Interactions with
Victims
OPR further concludes that none of the subject attorneys committed professional
misconduct with respect to the government's interactions with victims. The subjects did not have
a clear and unambiguous duty under the CVRA to consult with victims before entering into the
NPA because the USAO resolved the Epstein investigation without a federal criminal
charge. Significantly, at the time the NPA was signed, the Department did not interpret CVRA
rights to attach unless and until federal charges had been filed, and the federal courts had not
established a clear and unambiguous standard applying the CVRA before criminal charges were
brought. In addition, OPR did not find evidence that the lack of consultation was for the purpose
of silencing victims. Nonetheless, the lack of consultation was part of a series of government
interactions with victims that ultimately led to public and court condemnation of the government's
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treatment of the victims, reflected poorly on the Department as a whole, and is contradictory to the
Department's mission to minimize the frustration and confusion that victims of a crime endure.
OPR determined that none of the subjects was responsible for communications sent to
certain victims after the NPA was signed that described the case as "under investigation" and that
failed to inform them of the NPA. The letters were sent by an FBI administrative employee who
was not directly involved in the investigation, incorporated standard form language used by the
FBI when communicating with victims, and were not drafted or reviewed by the subjects.
Moreover, the statement that the matter was "under investigation" was not false because the
government in fact continued to investigate the case in anticipation that Epstein would not fulfill
the terms of the NPA. However, the letters risked misleading the victims and contributed to victim
frustration and confusion by failing to provide important information about the status of the
investigation. The letters also demonstrated a lack of coordination between the federal agencies
responsible for communicating with Epstein's victims and showed a lack of attention to and
oversight regarding communication with victims.
After the NPA was signed, Acosta elected to defer to the State Attorney the decision
whether to notify victims about the state's plea hearing pursuant to the state's own victim's rights
requirements. Although Acosta's decision was within his authority and did not constitute
professional misconduct, OPR concludes that Acosta exercised poor judgment when he failed to
make certain that the state intended to and would notify victims identified through the federal
investigation about the state plea hearing. His decision left victims uninformed about an important
proceeding that resolved the federal investigation, an investigation about which the USAO had
communicated with victims for months. It also ultimately created the misimpression that the
Department intentionally sought to silence the victims. Acosta failed to ensure that victims were
made aware of a court proceeding that was related to their own cases, and thus he failed to ensure
that victims were treated with forthrightness and dignity.
OPR concludes that the decision to postpone notifying victims about the terms of the NPA
after it was signed and the omission of information about the NPA during victim interviews and
conversations with victims' attorneys in 2008 do not constitute professional misconduct.
Contemporaneous records show that these actions were based on strategic concerns about creating
impeachment evidence that Epstein's victims had financial motives to make claims against him,
evidence that could be used against victims at a trial, and were not for the purpose of silencing
victims. Nonetheless, the failure to reevaluate the strategy prior to interviews of victims and
discussions with victims' attorneys occurring in 2008 led to interactions that contributed to
victims' feelings that the government was intentionally concealing information from them.
After examining the full scope and context of the government's interactions with victims,
OPR concludes that the government's lack of transparency and its inconsistent messages led to
victims feeling confused and ill-treated by the government; gave victims and the public the
misimpression that the government had colluded with Epstein's counsel to keep the NPA secret
from the victims; and undercut public confidence in the legitimacy of the resulting agreement. The
overall result of the subjects' anomalous handling of this case understandably left many victims
feeling ignored and frustrated and resulted in extensive public criticism. In sum, OPR concludes
that the victims were not treated with the forthrightness and sensitivity expected by the
Department.
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VI.
ORGANIZATION OF THE REPORT
The Report is divided into three chapters. In Chapter One, OPR describes the relevant
federal, state, and local law enforcement entities involved in investigating Epstein's criminal
conduct, as well as the backgrounds of the five subjects and their roles in the events in question.
OPR provides a brief profile of Epstein and identifies the defense attorneys who interacted with
the subjects.
In Chapter Two, OPR sets forth an extensive account of events relating to the federal
investigation of Epstein. The account begins with the initial complaint in March 2005 by a young
victim and her parents to the local police-a complaint that launched an investigation by local law
enforcement authorities-and continues through the mid-2006 opening of the federal
investigation; the September 2007 negotiation and signing of the NPA; Epstein's subsequent
efforts to invalidate the NPA through appeals to senior Department officials; Epstein's June 2008
guilty plea in state court; and, finally, efforts by the AUSA to ensure Epstein's compliance with
the terms of the NPA during his incarceration and until his term of home detention ended in July
2010. After describing the relevant events, OPR analyzes the professional misconduct allegations
relating to the decisions made regarding the development and execution of the NPA. OPR
describes the relevant standards and sets forth its findings and conclusions regarding the subjects'
conduct.
Chapter Three concerns the government's interactions with victims and the district court's
findings regarding the CVRA. OPR describes the relevant events and analyzes the subjects'
conduct in light of the pertinent standards.
OPR sets forth the extensive factual detail provided in Chapters Two and Three, including
internal USAO and Department communications, because doing so is necessary for a full
understanding of the subjects' actions and of the bases for OPR's conclusions.
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