# docs_fts_content

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From:
(USAFLS)"
To: Roy BLACK
Bcc:
(USAFLS)"
Subject: RE: Jeffrey Epstein
Date: Tue, 12 Aug 2008 13:07:57 +0000
Importance: Normal
Roy, thank you for your response and your assistance. I will forward your request to
who is representing the United States in
the civil suit.
Can you please ask Jack Goldberger to send me an exact copy of what was filed under seal in the state court? I want to insure that all of us
are presenting the same packet of documents as the final agreement.
Regards,
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phon
Fa
Original Message
From: Roy BLACK [mailto:
Sent: Monday, August 11, 2008 11:40 PM
To:
(USAFLS)
Subject: Jeffrey Epstein
I have conferred with the lawyers on the team. They all thank you for agreeing to oppose any disclosure of the 9/24/07 agreement.
We firmly believe this document is not discoverable in the civil cases. However if the court rules against you on this we request that you
further ask that any disclosure be subject to a strong protective order prohibiting dissemination to anyone except counsel to the petitioners.
We are particularly concerned because civil lawyers are more apt to publicize something like this than those of us who litigate on the
criminal side of the docket. You may recall one lawyer standing on the bridge to palm beach railing over his misconceptions of the case.
This is the typical vehicle they use to get more plaintiffs. You had also asked what documents were disclosed in the state court. As part of
counsels obligation to fully disclose any promises or inducements which led to the plea agreement, the 9/24/07 agreement was filed with
the court. It was filed under seal. Once again I want to re-assure you that Mr. Epstein and his counsel intend to stand by their agreements. If
you or anyone in the USAO have any concern about a possible breach please call or email me again so we can discuss any dispute or
misunderstanding and allay any concerns. Thanks again. Roy
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From:
(USAFLS)" /O=USA/OU=FLS/CN=RECIPIENTS/CN=
To:
Subject: FW: Epstein
Date: Thu, 29 Nov 2007 16:51:31 +0000
Importance: Normal
From: Jay Lefkowitz [mailto:
Sent: Wednesday, November 28, 2007 4:29 PM
To:
(USAFLS)
Cc
(USAFLS)
Subject: Re: Epstein
Dear
I received your email yesterday and was a little surprised at the tone of your letter, given the fact that we
spoke last week and had what I thought was a productive meeting. I was especially surprised given that your
letter arrived on only the second day back to work after the Thanksgiving Holiday, and yet your demands
regarding timing suggest that I have been sitting on my hands for days.
You should know that the first time I learned about Judge Davis's selection of Podhurst and Josephsberg,
and indeed the first time I ever heard their names, was in our meeting with you on Wednesday of last week.
Nevertheless, I have now been able to confer with my client, and we have determined that the selection of
Podhurst and Josephsberg are acceptable to us, reserving, of course, our previously stated objections to the
manner in which you have interpreted the section 2255 portions of the Agreement.
We do, however, strongly and emphatically object to your sending a letter to the alleged victims. Without a
fair opportunity to review and the ability to make objections to this letter, it is completely unacceptable that you
would send it without our consideration. Additionally, given that the US Attorney's office has made clear it
cannot vouch for the claims of the victims, it would be incendiary and inappropriate for your Office to send such
a letter. Indeed, because it is a certainty that any such letter would immediately be leaked to the press, your
actions will only have the effect of injuring Mr. Epstein and promoting spurious civil litigation directed at him.
We believe it is entirely unprecedented, and in any event, inappropriate for the Government to be the instigator
of such lawsuits.
Finally, we disagree with your view that you are required to notify the alleged victims pursuant to the
Justice for All Act of 2004. First, 18 USC section 2255, the relevant statute under the Non-Prosecution
Agreement for the settlement of civil remedies, does not have any connection to the Justice for All Act. Section
2255 was enacted as part of a different statute. Second, the Justice for All Act refers to restitution, and section
2255 is not a restitution statute. It is a civil remedy. As you know, we had offered to provide a restitution fund
for the alleged victims in this matter; however that option was rejected by your Office. Had that option been
chosen, we would not object to your notifying the alleged victims at this point. At this juncture, however, we do
not accept your contention that there is a requirement that the government notify the alleged victims of a
potential civil remedy in this case.
Accordingly, for all the reasons we have stated above, we respectfully -- and firmly -- object to your sending
any letter whatsoever to the alleged victims in this matter. Furthermore, if a letter is to be sent to these
individuals, we believe we should have a right to review and make objections to that submission prior to it being
sent to any alleged victims. We also request that if your Office believes that it must send a letter to go to the
alleged victims, who still have not been identified to us, it should happen only after Mr. Epstein has entered his
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plea. This letter should then come from the attorney representative, and not from the Government, to avoid any
bias.
As you know, Judge Starr has requested a meeting with Assistant Attorney General Fisher to address what
we believe is the unprecedented nature of the section 2255 component of the Agreement. We are hopeful that
this meeting will take place as early as next week. Accordingly, we respectfully request that we postpone our
discussion of sending a letter to the alleged victims until after that meeting. We strongly believe that rushing to
send any letter out this week is not the wisest manner in which to proceed. Given that Mr. Epstein will not even
enter his plea for another few weeks, time is clearly not of the essence regarding any notification to the identified
individuals.
Thanks very much,
Jay
(USAFLS)"
To "Jay Lefkowitz"
CC
USAFLS)*
11/27/2007 01:55 PM
Subject Epstein
Jay,
Please accept my apologies for not getting back to you sooner but I was a little under the weather yesterday. I
hope that you enjoyed your Thanksgiving.
Regarding the issue of due diligence concerning Judge Davis' selection, I'd like to make a few observations.
First, Guy Lewis has known for some time that Judge Davis was making reasonable efforts to secure Aaron
Podhurst and Bob Josephsberg for this assignment. In fact, when I told you of Judge Davis's selection during our
meeting last Wednesday, November 21st, you and Professor Dershowitz seemed very comfortable, and certainly
not surprised, with the selection. Podhurst and Josephsberg are no strangers to nearly the entire Epstein defense
team including Guy Lewis, Lili Ann Sanchez, Roy Black, and, apparently, Professor Dershowitz who said he
knew Mr. Josephsberg from law school. Second, Podhurst and Josephsberg have long-standing stellar reputations
for their legal acumen and ethics. It's hard for me to imagine how much more vetting needs to be done.
The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims of the anticipated
upcoming events and their rights associated with the agreement entered into by the United States and Mr. Epstein
in a timely fashion. Tomorrow will make one full week since you were formally notified of the selection. I must
insist that the vetting process come to an end. Therefore, unless you provide me with a good faith objection to
Judge Davis's selection by COB tomorrow, November 28, 2007, I will authorize the notification of the victims.
Should you give me the go-ahead on Podhurst and Josephsberg selection by COB tomorrow, I will
simultaneously send you a draft of the letter. I intend to notify the victims by letter after COB Thursday,
November 29th. Thanks,
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
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Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.:
08-80069
JANE DOE NO. 1, by and through
JANE DOE's FATHER as parent and natural
guardian, and JANE DOE's FATHER, and
JANE DOE's STEPMOTHER, individually,
CIV-MARRA
Plaintiffs,
MAGISTRATE JUDGB
VS.
JOHNSON
FILED INTAKE by
D.C.
JEFFREY EPSTEIN,
Defendant.
JAN 24 2008
/
CLARENCE MADDOX
CLERK U.S. DIST. CT.
S.D. OF FLA. . FT. LAUD.
COMPLAINT
Plaintiff, Jane Doe No. 1 ("Jane" or "Jane Doe"), by and through Jane Doe's Father as parent
and natural guardian, and Jane Doe's Father and Jane Doe's Stepmother, individually, bring this
Complaint against Jeffrey Epstein, as follows:
Parties, Jurisdiction and Venue
1.
Jane Doe is a citizen and resident of the State of Florida. She is a minor under the
age of 18 years.
2.
Jane Doe's Father brings this action individually and as parent and natural guardian of
Jane Doe. Jane Doe's Father is a citizen and resident of the State of Florida.
3.
Jane Doe's Stepmother brings this action individually. Jane Doe's Stepmother is a
citizen and resident of the State of Florida.
4.
This Complaint is brought under fictitious names to protect the identity of the Minor
Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
HERMAN & MERMELSTEIN, P. A.
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minor.
5.
Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
6.
This is an action for damages in excess of $50 million.
7.
This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
U.S.C. 1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
and (ii) is between citizens of different states.
8.
This Court has venue of this action pursuant to 28 U.S.C. 1391(a) as a substantial
part of the events or omissions giving rise to the claim occurred in this District.
Factual Allegations
9.
At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52
years old. Epstein is a financier and money manager with a secret clientele limited exclusively to
billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his
principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach,
FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
10.
Upon information and belief, Epstein has a sexual preference and obsession for
underage minor girls. He engaged in a plan and scheme in which he gained access to primarily
economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
them money. In or about 2005, Jane Doe, then 14 years old, fell into Epstein's trap and became one
of his victims.
11.
Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas.
12.
An integral player in Epstein's Florida scheme was
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She recruited girls ostensibly to give a
wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's
plan, Ms.
would be contacted when Epstein was planning to be at his Palm Beach residence
or soon after he had arrived there. Epstein or someone on his behalf directed Ms.
1 to bring
one or more underage girls to the residence. Ms.
1, upon information and belief, generally
sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas who
would be enticed by the money being offered - generally $200 to $300 per "massage" session - and
who were perceived as less likely to complain to authorities or have credibility if allegations of
improper conduct were made. This was an important element of Epstein's plan.
13.
Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at
Epstein's mansion, Mr.
would introduce each victim to
,
,
who gathered the girl's personal information, including her name and telephone number. Ms.
would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition
to other furnishings. There were photographs of nude women lining the stairway hall and in the
bedroom. Ms.
would then leave the girl alone in this room, whereupon Epstein would enter
wearing only a towel. He would then remove his towel, lay down naked on the massage table, and
direct the girl to remove her clothes. He then would perform one or more lewd, lascivious and
sexual acts, including masturbation and touching the girl's vagina with a vibrator.
14.
Consistent with the foregoing plan and scheme, Ms.
recruited Jane Doe to
give Epstein a massage for monetary compensation. Ms.
brought Jane to Epstein's mansion
in Palm Beach. Jane was introduced to
, who led her up the flight of stairs to the room
with the massage table.
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15.
After Epstein had completed the assault, he left the room. Jane was then able to get
dressed, leave the room and go back down the stairs. She then met Ms.
again who brought
Jane home. Jane was paid $300 by Epstein. Ms.
was paid $200 by Epstein for bringing Jane
to him.
16.
As a result of this encounter with Epstein, the 14-year old Jane experienced
confusion, shame, humiliation, embarrassment and the assault sent her life into a downward spiral.
COUNT I
Sexual Assault
17.
Plaintiff Jane Doe by and through her Father, as parent and natural guardian, repeats
and realleges paragraphs 1 through 16 above.
18.
Epstein tortiously assaulted Jane Doe sexually in or about 2005.
19.
This sexual assault was in violation of Chapter 800 of the Florida Statutes, which
recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane.
20.
As a direct and proximate result of Epstein's assault on Jane, she has suffered and will
continue to suffer severe and permanent traumatic injuries, including mental, psychological and
emotional damages.
WHEREFORE, Plaintiff Jane Doe, by and through her Father, as parent and natural guardian,
demands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages,
costs, and such other and further relief as this Court deems just and proper.
HERMAN & MERMELSTEIN, P. A.
www.hermanlaw.com
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COUNT II
Intentional Infliction of Emotional Distress
21.
Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane
Doe's Father and Jane Doe's Stepmother, individually, repeat and reallege paragraphs 1 through 16
above.
22.
Epstein's conduct was intentional or reckless.
23.
Epstein's conduct was outrageous, going beyond all bounds of decency.
24.
Epstein's conduct caused severe emotional distress not only to Jane Doe, but also to
her parents, Jane Doe's Father and Jane Doe's Stepmother. Epstein knew or had reason to know that
his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe's
parents.
25.
As a direct and proximate result of Epstein's intentional or reckless conduct, Jane
Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe
mental anguish and pain.
WHEREFORE, Plaintiffs Jane Doe by and through her Father, as parent and natural
guardian, Jane Doe's Father and Jane Doe's Stepmother demand judgment against Defendant Jeffrey
Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
Court deems just and proper.
COUNT III
Loss of Parental Consortium
26.
Plaintiff Jane Doe's Father repeats and realleges paragraphs 1 through 16 above.
27.
Epstein's tortious conduct is the direct and proximate cause of damages to Jane Doe's
Father, consisting of parental loss of comfort, companionship and society and healthcare costs
HERMAN & MERMELSTEIN, P. A.
www.hermanlaw.com
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associated with the treatment of Jane.
28.
Jane Doe's Father experienced and will continue to experience great mental anguish,
pain and suffering from the time that Defendant's tortious conduct occurred.
WHEREFORE, Plaintiff Jane Doe's Father demands judgment for loss of consortium
damages, costs and such other and further relief as this Court deems proper.
JURY TRIAL DEMAND
Plaintiffs demand a jury trial in this action.
Dated: January 24, 2008
Respectfully submitted,
HERMAN & MERMELSTEIN, P.A.
Attorneys for Plaintiffs
18205 Biscayne Blvd.
Suite 2218
Miami, Florida 33160
Tel: 305-931-2200
Fax: 305-931-0877
By: Jeffrey Jan M. Herman
jlherman@hermanlaw.com
Florida Bar No. 521647
Stuart S. Mermelstein
smermelstein@hermanlaw.com
Florida Bar No. 947245
Adam D. Horowitz
Florida Bar No. 376980
ahorowitz@hermanlaw.com
HERMAN & MERMELSTEIN, P. A.
www.hermanlaw.com
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=== Page 1 ===
From:
)"
To:
Subject: RE: FirstBank Puerto Rico
Date: Sat, 04 Apr 2020 17:34:07 +0000
Attachments: 2019-12-31.
Puerto_Rico.pdf
Subpoena attached.
From:
Sent: Saturday, April 04, 2020 08:20
To:
Subject: FW: FirstBank Puerto Rico
Hey
Sorry I missed your call back. I tried you again later yesterday but we couldn't connect. No huge rush - can we
speak Monday morning? If so, what's a good time?
In the meantime, it would help if you could email me a copy of the
I think all I have is a hard copy which I
believe I left back at the office before we were ordered to work at home.
Thank you and enjoy the weekend.
From:
Sent: Friday, April 03, 2020 9:59 AM
To:
Subject: FirstBank Puerto Rico
Good morning
I just left you a voice mail. When you have a couple of minutes, please call me on
Thanks.
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From: "
)
To: "
USANYS)
Cc: "
(USANYS
Subject: Re:
Date: Mon, 08 Apr 2019 16:42:31 +0000
Importance: Normal
On my way back now.
Sent from my iPhone
> On Apr 8, 2019, at 12:41 PM,
(USANYS)
wrote:
>
> Let me know when you have a minute just to put a forfeiture case on your radar involving Epstein.
V
> Sent from my iPhone
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=== Page 1 ===
KIRKLAND & ELLIS LLP
SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL
IN THE MATTER OF JEFFREY E. EPSTEIN
Jeffrey Epstein, a successful businessman and noted philanthropist with no prior criminal
record, has been investigated for potential violations of 18 U.S.C. §§ 1591, 2422(b) and 2423(b).
Since the limited review conducted by CEOS, two Supreme Court decisions-one authored by
Justice Scalia and the other by Justice Thomas-have revitalized the bedrock principles that
federal criminal statutes must be narrowly construed, that they may not be stretched to federalize
conduct not clearly covered by their prohibitions, and that whenever there are two plausible
constructions of a criminal statute, the narrower construction (hich safeguards liberty) rather than
the broader construction (which expands the federal prosecutor's arsenal) controls under the
venerable rule of lenity.
Mr. Epstein's conduct-including his misconduct-falls within the heartland of historic
state police and prosecutorial powers. Absent a significant federal nexus, matters involving
prostitution have always been treated as state-law crimes even when they involve minors. Mr.
Epstein's conduct lacks any of the hallmarks that would convert this quintessential state crime
into a federal one under any of the statutes prosecutors are considering.
Mr. Epstein lived in Palm Beach, and his interstate travel was merely to go home. Any
sexual conduct that occurred after he arrived was incidental to the purposes for his travel. Even
CEOS admitted that applying § 2423(b) to a citizen traveling home would be "novel." In fact, it
would be both unprecedented and in conflict with Supreme Court cases that have withstood the
test of time for over 60 years.
Moreover, Mr. Epstein did not use the internet (either via email or chatrooms) to
communicate with any of the witnesses in this investigation. Indeed, he did not use any other
facility of interstate commerce, including the phone, to knowingly persuade, entice, or induce
anyone to visit his home-the "local" locus of all the incidents under investigation-much less
to persuade, entice, or induce a known minor to engage in prohibited sex acts, as $ 2422(b)
requires. Nor did anyone on his behalf "persuade" or "induce" or "entice" or "coerce" anyone as
these words are ordinarily understood and as the new Supreme Court decisions mandate they be
applied: narrowly, without stretching ordinary usage to conform to a prosecutor's case-specific
need for a broad (and in this case unprecedented) application. In addition, as will be shown
below, $ 2422(b) requires that the object of the communication be a state law offense that "can
be charged." Yet because the state of Florida's statute of limitations is one year for the first
prostitution offense and three years for other targeted offenses, and because all or virtually all of
the offense conduct at issue in the federal investigation occurred prior to June 20, 2005, those
acts can not be charged by the State, and thus cannot meet this essential element of federal law.
Finally, Mr. Epstein neither coerced, nor enslaved, nor trafficked, nor derived any profit
from his sexual conduct. He was an ordinary "John," not a pimp. But § 1591 is directed only
against those who engage in force or fraud or coercion or who are in the business of commercial
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KIRKLAND & ELLIS LLP
sexual trafficking. The statute has never been applied to a "John," and only a highly and
impermissibly selective prosecution could stretch § 1591 to reach conduct like that at issue in
this case.
In short, without "novel" interpretive expansions-a description used by CEOS itself-it
cannot be shown that Mr. Epstein violated any of the three federal statutes identified by
prosecutors. As the Supreme Court's recent decisions in Santos and Cuellar make clear, federal
law may not be stretched in that manner, and the current federal investigation relies, as its
foundation, on impermissibly elastic stretches of each statute beyond any reported precedent;
beyond the essential elements of each statute; well outside the ordinary construction of each
statute's limitations; and on a selective, extraordinary, and unwarranted expansion of federal law
to cover conduct that has always been exclusively within the core of state powers.
At this point in time, the need for Departmental oversight is critical. We appreciate this
opportunity to submit our assessment of the key facts in this case and review of the pertinent
federal statutes, and respectfully request that the Office of the Deputy Attorney General end
federal involvement in this matter so that the State of Florida may resolve this case appropriately.
Summary of the Facts
Mr. Epstein has maintained a home in Palm Beach, Florida for the past 20 years. While
there, he routinely conducted business, received medical attention, socialized with friends, and
helped care for his elderly mother. Mr. Epstein also had various women visit his home to
perform massages. He did not personally schedule the massage appointments or communicate
with the women over the phone or the Internet. Rather, Mr. Epstein's personal assistants
scheduled many types of appointments, personal trainers, chiropractors, business meetings and
massages. The phone message pad taken from his house and in the possession of the
government confirmed that in many cases, the women themselves contacted Mr. Epstein's
assistants to inquire about his availability-rather than vice versa.
The majority of the massages were just that and nothing else. Mr. Epstein often would be
on the telephone conducting business while he received his massage. At times, the masseuses
would be topless, and some sexual activity might occur-primarily self-masturbation on the part
of Mr. Epstein. On other occasions, no sexual activity would occur at all. There was no pattern
or practice regarding which masseuse would be scheduled on a particular day-if one would be
scheduled at all-or whether any sexual activity might occur. Indeed, Mr. Epstein almost never
knew which masseuse his assistants had scheduled until she arrived. See Tab 3,
Toll
Records.
Mr. Epstein specifically requested that each masseuse be at least 18 years old. The vast
majority of the masseuses were in fact in their twenties, many accompanied to Mr. Epstein's
home by friends or even other family members. Furthermore, most of the women who have
testified that they were actually under 18 have specifically admitted to systematically lying to
Mr. Epstein about their age. See Tab 4
Tr. at 38-39; Tab 5,
Tr. at 16; Tab 6,
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Tr. at 6, 8, 22, 45; Tab 7,
Tr. 13; Tab 8
Tr. at 8; Tab 9,
Tr. at 5; and
Tab 10,
Tr. at 14-15 (excerpts from these transcripts are included below). Furthermore,
the women who visited Mr. Epstein's home all visited voluntarily and many willingly returned
several times.
The State Attorney's Office (the "SAO") has vast experience prosecuting sex crimes and
conducted an exhaustive, 15-month investigation of Mr. Epstein. A Grand Jury has concluded
that Mr. Epstein was merely a local "John," guilty of soliciting prostitution in violation of state
law. Notably, Florida law distinguishes soliciting from procuring and compelling prostitution if
minors are involved. Indeed, soliciting is a misdemeanor except for the commission of a third
subsequent offense, turning it into a felony. The SAO, therefore, sought and obtained an
indictment charging Mr. Epstein with felony solicitation of prostitution. Mr. Epstein is prepared
to plead guilty and accept a sentence for that offense-a sentence that, notably, is far more
severe than that meted out to other "Johns" convicted of violating Florida's solicitation laws for
cases in which sexual activity was alleged.
Though CEOS points out its admirable goal of "protecting children," a moniker that
engenders high emotions, the conduct alleged here involves women over 16, which is the age of
consent in 38 states and supplies the effective federal age of consent. The young women were by
no means the target of high-school trolling; they were individuals who, with friends, visited Mr.
Epstein's house-a home full of friends and staff. The civil complaints filed against Mr. Epstein
reiterate the fact that the individuals who visited Mr. Epstein would visit with their friends. And
Mr. Epstein never spoke to or had any contact with these women before they arrived at his
house. And again, the State is handling this matter appropriately.
We respectfully submit that that should be the beginning and the end of this matter. As
you know, the Department's Petite Policy precludes successive federal prosecutions after a State
has acted: "[A] state judgment of conviction, plea agreement [here held in abeyance solely as a
result of the federal investigation], or acquittal on the merits shall be a bar to any subsequent
federal prosecution for the same act or acts." U.S.A.M. § 9-2.031A (emphasis added).
Consistent with that principle, and of particular relevance to this case, the Department itself just
recently observed the following:
[P]rostitution-related offenses have historically been prosecuted at the state or
local level. This allocation between state and Federal enforcement authority does
not imply that these crimes are less serious, but rather reflects important structural
allocations of responsibility between state and Federal governments. [T]he
Department is not aware of any reasons why state and local authorities are not
currently able to pursue prostitution-related crimes such that Federal jurisdiction
is necessary.
See Tab 11, November 9, 2007 Letter from Justice Department Principal Deputy Assistant
Attorney General Brian Benczkowski to the House Committee on the Judiciary, p. 8-9.
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Summary of the Law
We have reviewed every reported case under 18 U.S.C. §§ 1591, 2422(b), and 2423(b),
and cannot find a single one that resulted in a conviction on facts akin to the ones here. In some
respects, it is not surprising that no precedent supports federal prosecution of a man who engaged
in consensual conduct, in his home, that amounts to solicitation under State law. After all,
prostitution, even when the allegations involve minors, is fundamentally a State concern, United
States V. Evans, 476 F.3d 1176, n.1 (11th Cir. 2007) (noting that federal law "does not
criminalize all acts of prostitution (a vice traditionally governed by state regulation)"), and there
is no evidence that Palm Beach County authorities and Florida prosecutors cannot effectively
prosecute and punish the conduct. See also Batchelder V. Gonzalez, No. 4:07-cv-00330-SPM-
AK, 2007 WL 5022105 (N.D. Fla. Oct. 19, 2007). In fact, the opposite is true-the state-elected
officials, cognizant of the local mores of the community, have a lauded history of just such
prosecutions.
In any event, and as set forth below, none of the federal statutes in this case remotely
supports a prosecution on the facts of this case without each and every element being stretched in
a novel way to encompass the behavior at issue. We begin with first principles. Courts in this
country have "traditionally exercised restraint in assessing the reach of federal criminal statutes,
both out of deference to the prerogatives of Congress, Dowling V. United States, 473 U.S. 207
(1985), and out of concern that 'a fair warning should be given to the world in language that the
common world will understand, of what the law intends to do if a certain line is passed." Arthur
Andersen LLP V. United States, 544 U.S. 696, 703 (2005) (quoting McBoyle V. United States, 283
U.S. 25, 27 (1931)) (citation omitted).
Two recent Supreme Court decisions dramatically underscore these principles and help to
highlight why federal prosecution in this case would be improper as a matter of both law and
policy. See United States V. Santos, No. 06-1005 (June 2, 2008); Cuellar V. United States, No.
06-1456 (June 2, 2008). Though they both address the interpretation and application of the
federal money laundering statute, 18 U.S.C. § 1956, the principles they set forth are equally
applicable here. In Santos, the Court held that the statutory term "proceeds" means "profits"
rather than "receipts," and thus gave the statute a significantly narrower interpretation than what
the government had urged. In his plurality opinion, Justice Scalia emphasized that where a
statutory term in a criminal statute could support either a narrow or broad application, the narrow
interpretation must be adopted because "[w]e interpret ambiguous criminal statutes in favor of
defendants, not prosecutors." Slip op. at 12. As his opinion explained, the rule of lenity "not
only vindicates the fundamental principle that no citizen should be held accountable for a
violation of a statute whose commands are uncertain, or subjected to punishment that is not
clearly proscribed. It also places the weight of inertia upon the party that can best induce
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Congress to speak more clearly and keeps courts from making criminal law in Congress's stead."
Slip op. at 6.¹
In Cuellar, the Court examined the link between the money-laundering statute's mens rea
requirement and the underlying elements of the offense. After a careful textual analysis of the
statute and its structure, the Court ruled that the defendant's conviction could be sustained only if
he knew that the transportation of funds to Mexico was designed to conceal their nature,
location, source, ownership or control-not merely that the defendant knew that the funds had
been hidden during their transportation to Mexico. Slip op. at 10-17.
Both decisions relied on the ordinary meaning of the statutory terms Congress chose.
And both rejected attempts to broaden those words to cover conduct not clearly targeted by
Congress. Taken together, these decisions reject the notion that prosecutors can take language
from a narrowly drawn federal statute-especially one that itself federalizes the prosecution of
conduct traditionally within the heartland of State police powers-and convert it into a license to
reach additional conduct by ignoring, rewriting or expansively interpreting the law. Both cases
additionally rejected the notion that statutes should be broadly construed in order to facilitate
prosecutions or to in anyway diminish the burden on prosecutors to prove each essential element
of a federal charge in conformity with Congress's determinations as to what is within the federal
criminal law and what is not. The conflict between the Santos and Cuellar decisions and
CEOS's grant of effectively unlimited discretionary authority to the USAO to take federal law to
"novel" places where they have never reached before could not be starker.
These lessons have no less force in the context of Executive Branch decision-making
than they do in the context of Judicial interpretation. As you are aware, when federal prosecutors
exercise their discretion, they bear an independent constitutional obligation to faithfully interpret
the law as written-not to broaden its scope beyond the limits endorsed by both Congress and
the President. There is no support for CEOS's view that the courts or a jury should ultimately
decide whether a "novel" construction of the law is correct. Instead, the Executive Branch itself
has a non-delegable obligation not to exceed its authority; the power of other branches to check
or remedy such usurpation does not legitimize executive action that exceeds its bounds. See Tab
12, November 2, 1994 Memorandum from Assistant Attorney General Walter Dellinger to the
Hon. Abner J. Mikva, Counsel To The President, on Presidential Authority To Decline To
Execute Unconstitutional Statutes, available at http://www.usdoj.gov/olc/nonexcut.htm.
In this case, the text, structure, and history of the relevant federal statutes unambiguously
indicate that these statutes were designed to address problems of a national and international
1
Justice Stevens, in his concurring opinion, also acknowledged the rule of lenity, calling the plurality opinion's
discussion of that rule "surely persuasive." United States V. Santos, No. 06-1005, slip op. at 5 (June 2, 2008)
(Stevens, J., concurring).
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scope-not the local conduct that is alleged here-and each of these statutes requires proof of
the defendant's actual knowledge that simply is not present in this case. Any attempt to stretch
the language of these statutes to cover this case would be a misuse of the law and contrary to
express legislative intent. In short, the elements under each federal statute-18 U.S.C. §§ 1591,
2422(b) and 2423(b)-are not satisfied here.
1.
18 U.S.C. § 2422(b)
18 U.S.C. § 2422(b) requires the government to prove beyond a reasonable doubt that the
defendant engaged in communications over an interstate facility (e.g., the Internet or phone) with
four concurrent intentions: (1) to knowingly (2) persuade, induce, entice or coerce, or attempt to
persuade, induce, entice, or coerce (3) a minor (4) to engage in prostitution or criminal sexual
activity for which the person can be charged. Mr. Epstein's conduct does not satisfy the
elements of § 2422(b). Each element must be individually stretched, and then conflated in a
tenuous chain to encompass the alleged conduct with any individual woman.
As the statute makes clear, the essence of this crime is the communication itself-not the
resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point:
The defendant in Bailey contended that attempt under $ 2422(b) "requires the
specific intent to commit illegal sexual acts rather than just the intent to persuade
or solicit the minor victim to commit sexual acts.' Id. at 638. In response, the
court held '[w]hile it may be rare for there to be a separation between the intent to
persuade and the follow-up intent to perform the act after persuasion, they are two
clearly separate and different intents and the Congress has made a clear choice to
criminalize persuasion and the attempt to persuade, not the performance of the
sexual acts themselves. Hence, a conviction under the statute only requires a
finding that the defendant had an intent to persuade or to attempt to persuade.'
United States V. Murrell 368 F.3d 1283, 1287 (11th Cir. 2004) (citing United States V. Bailey,
228 F.3d 637, 638-39 (6th Cir.2000)). Thus, the targeted criminal conduct must occur through
the interstate facility, not thereafter, and the scienter element must be present at the time of the
call or Internet contact.
In this case, however, Mr. Epstein did not use an interstate facility to communicate any
illegal intention in this case; the phone calls were made by his assistants in the course of setting
up many other appointments. Neither a conspiracy charge nor a charge of aiding and abetting
can fulfill the mens rea requirement here. Indeed, neither Mr. Epstein nor his assistants knew
whether sexual activity would necessarily result from a scheduled massage. And certainly, no
such activity was ever discussed on the phone by either Mr. Epstein or his assistants. Instead, as
the record in this case makes clear, many appointments resulted in no illegal sexual activity, and
often, as confirmed by the masseuses' own testimony, several individuals who were contacted by
phone visited Mr. Epstein's house and did not perform a massage at all. Where sexual activity
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did result, it was mainly self-pleasuring masturbation and not necessarily illegal, but spontaneous
and resulted from face-to-face conversations during the massage. Thus, the fact that Mr. Epstein
later may have persuaded any particular masseuse to engage in unlawful activity during the
massage does not work retroactively to render the earlier scheduling phone call an offense under
$ 2422(b). Nor is there any evidence that women who returned to Mr. Epstein's home time and
again were somehow coerced or induced over a facility of interstate commerce to do so.
The first essential element of $ 2422(b) that "[w]hoever, using the mail or any facility or
means of interstate or foreign commerce," by its plain language, requires that the
communication, which is the essence of the crime and its actus reus, take place during the use of
the facility of interstate commerce (in this case, unlike the vast majority of Internet chat room
sting operations, a telephone). The statute is not ambiguous. It requires that the criminal
conduct occur while the defendant is "using" (i.e. engaged in the communication), not thereafter.
Given the utter lack of direct evidence against Mr. Epstein, prosecutors have signaled that
they intend to offer a purely circumstantial case if this matter proceeds to trial-essentially
arguing that "routine and habit" evidence could substitute for actual proof that an interstate
facility was used to solicit sex from minors. Thus, despite the fact that the calls themselves were
not made by Mr. Epstein and did not contain the necessary explicit communication to knowingly
induce minors to provide sexual favors for money, prosecutors are seeking to turn the phrase "are
you available"-the same phrase used with friends, chiropractors, and trainers-into a ten-year
mandatory prison sentence. In any case, the prosecution's attenuated argument regarding
"routine and habit" will also not fit the facts of this case. The witness testimony at issue makes
clear that there was no clear "routine or habit" with respect to the interactions at issue. And in
those unpredictable instances where sexual contact resulted, it was a product of what occurred
after the benign phone communication, not during the call itself.
The prosecution's theory of liability-that a call to a person merely to schedule a visit to
the defendant's residence followed by a decision made at the residence to engage in prohibited
sexual activity is sufficient-cannot survive either a "plain language" test or the rule of lenity as
they have been authoritatively construed in the recent Santos and Cuellar cases. The statute
cannot be read otherwise. As the Cuellar decision makes clear, a proper interpretation of a
federal criminal statute is guided "by the words of the operative statutory provision," not by
outside objectives, such as those facilitating successful prosecution. See Cuellar, supra, Slip op.
at 7. As Justice Alito stated in his concurring opinion, the government must prove not just the
"effect" of the secretive transportation, but also that "petitioner knew that achieving one of these
effects was a design (i.e. purpose) of the transportation" of currency. Cuellar V. United States,
supra, 553 U.S., Slip op. At 1 (Alito, J. concurring). Similarly, it is not enough that one effect of
a communication scheduling a visit between Mr. Epstein and a minor was that there might be
subsequent face-to-face inducement. Instead, the statute, as drafted, defines the crime as the
communication and demands that far more be proven than that the use of an interstate facility
resulted in a later meeting where even an inducement (as opposed to a solicitation) was made.
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The prosecution has never represented to counsel that they have evidence that would
prove that the inducement or enticement to engage in illegal sexual acts occurred over the phone
(or Internet). The prosecution's references to "routine and habit" evidence that would substitute
for the explicit communications usually found in the transcripts from chat rooms or sting
operations is tenuous at best. In essence, the prosecution would be alleging communications
understood, but not spoken, by two people, one of whom was usually a secretary or assistant.
Separating the actus reus and the mens rea, however, and premising criminal liability on
persuasion that might occur after the communication, or on the existence of a specific intent to
engage in illegal sex with a minor that arises after the communication would violate the bedrock
principle of criminal law that predicates liability on the concurrence of the act and the criminal
state of mind. Even if, arguendo, the communication and mens rea could be separated (a
premise which is at odds with the requirement of concurrence), Mr. Epstein denies that the
factual proof demonstrates such a pattern or practice. Instead, the evidence compellingly proves
that there was no regularity or predictability to the content of the communication or in what
occurred at meetings that were telephonically scheduled (including those that are the subject of
this investigation).
A second essential element of 2422(b) requires that the defendant "knowingly" induce,
persuade, entice or coerce a person believed to be a minor. " [K]knowingly induces
requires the Court to define inducement so it is consistent with its ordinary usage and so the term
is not so broad that it subsumes the separate statutory terms of "entices" and "persuades."
Inducement has a common legal meaning that has been endorsed by the government when it
operates to narrow the affirmative defense of entrapment. Inducement must be more than "mere
solicitation;" it must be more than an offer or the providing of an opportunity to engage in
prohibited conduct. See, e.g,. United States V. Sanchez-Berrios, 424 F.3d 65, 76-77 (1st Cir.
2005); United States V. Brown, 43 F.3d 618, 625 (11th Cir. 1995). The government cannot fairly,
or consistent with the rule of lenity, advocate a broader definition of the same term when it
expands a citizen's exposure to criminal liability than when it limits the ambit of an affirmative
defense to criminal conduct. If the term is ambiguous, absent clear Congressional intent on the
issue, the Court's decision in Santos requires that the narrower rather than the broader definition
be used.
The facts simply do not prove Mr. Epstein's culpability for knowingly inducing or
persuading minors. First, in the case of masseuses who agreed or even sought to return to see
Mr. Epstein on successive occasions, there is no evidence that there was any inducement,
persuasion, enticement or coercion over the phone. And, for masseuses seeing Mr. Epstein for
the first time, there was generally no telephone contact with Mr. Epstein and there was no
knowledge that any third party at Mr. Epstein's specific direction was inviting them to Mr.
Epstein's home over the phone rather than in face-to-face meetings. The women who visited Mr.
Epstein's home were all friends of friends. Contrary to the facts in this case, § 2422(b)'s
knowing inducement element is essential to federal liability and, given its hefty minimum
mandatory punishment, it should not be interpreted as a strict liability statute.
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There is insufficient evidence that Mr. Epstein targeted minors, as required. The
evidentiary pattern does not even establish willful blindness since Mr. Epstein took steps to
ensure his visitors were over 18-and certainly took none to avoid knowing. But, even if the
government contends that it possesses evidence that could demonstrate that Mr. Epstein knew or
should have known or suspected that a small number of the masseuses were underage, that would
still not make this an appropriate case for federal, rather than state prosecution. The federal
statutes were not intended to supersede state prosecutions involving isolated instances of
underage sex. Instead, the federal statutes were intended for large-scale rings or for an
individual who was engaged, while using interstate facilities such as the Internet, with the willful
targeting of minors.
The government's evidence, even when stretched to the limit, will not show a pattern of
targeting underage persons for illegal sexual activity. A federal prosecution should not become a
contest between the prosecution and defense over whether the defendant knew, suspected or
should have known whether a particular person was or was not over age. The history of cases
brought under this statute make crystal clear that knowledge of the defendant regarding the age
of the women is required-either by admission or by incontrovertible transcripts of
conversations (i.e. stings operations which require repeated acknowledgment of the defendant's
awareness of the victims' age). Even states with absolute liability about mistake regarding age
rarely prosecute cases where definitive proof is lacking (Palm Beach County rarely does and
when it does, it imposes house arrest sentences). This is a matter for the exercise of state
prosecutorial discretion and not federal mandatory minimum statutes that were not intended to
cover such conduct.
A third essential element of $ 2422(b) is the requirement that the government prove that
the defendant actually believed that the person being persuaded (coerced, etc.) was a minor at the
time of the communication. See e.g., Offense Instruction 80, Eleventh Circuit Pattern Jury
Instructions-Criminal (2003) ("The defendant can be found guilty of that offense only if. the
defendant believed that such individual was less than (18) years of age..."); United States V.
Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) (§ 2422(b) requires that the defendant knowingly
target a minor). Importantly, then, all the elements must be proven with respect to a specific
person. However, we are told that the majority of proof is no more than toll records, not
recorded conversations or Internet chat transcripts, but toll records and perhaps a memory of
what was said years ago on a particular call for a particular request from a particular person
acting at Mr. Epstein's direction.
Two final points bear special emphasis here. The statute, which according to Santos and
Cuellar must be narrowly construed, also requires that the inducement be to engage in
prostitution or sexual activity "for which [the defendant] can be charged." 18 U.S.C. § 2422(b).
However, simple prostitution is not defined (or made punishable) in the U.S. Code, and state law
thus supplies the appropriate reference point. Under Florida law, "prostitution" entails the
"giving or receiving of the body for sexual activity for hire," Fla. Stat. § 796.07(1)(a), and the
term "sexual activity" is limited to "oral, anal, or vaginal penetration by, or union with, the
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sexual organ of another; anal or vaginal penetration of another by any other object; or the
handling or fondling of the sexual organ of another for the purpose of masturbation." Fla. Stat. §
796.01(1)(d). Also, the Florida Supreme Court jury instructions define prostitution as involving
"sexual intercourse." As a result, topless massages-even ones for hire that include self-
masturbation-fall outside the ambit of the state-law definition of prostitution. Absent proof
beyond a reasonable doubt that, at the critical time of the communication, Mr. Epstein had a
specific intent to persuade another to engage in prostitution or "sexual activity," as defined by
Florida law, he cannot be guilty of an offense under $ 2422(b).
As important, the plain language of the phrase "for which any person can be charged"
necessarily excludes acts as to which the state's statute of limitations has run. Under Florida
law, prostitution and prostitution-related offenses are misdemeanors in the second degree for a
first violation. 2 See Fla. Stat.. $ 796.07(4)(a). The limitations period for a misdemeanor in the
second degree is one year, and there is no tolling provision based upon the victim's age. See Fla.
Stat. $ 775.15(b). Even as to allegations of third degree felonies, the statute of limitations is
three years. Thus, any conduct alleged to have occurred before mid-June 2005 cannot be
charged as a matter of state law and thus cannot be a predicate for a § 2422(b) offense-even if
the federal statute of limitations has not run on any given $ 2422(b) offense because of the
lengthier statute codified in 18 U.S.C. § 3282. Thus, no prosecution under § 2422(b) can be
brought based upon inducement of prostitution or sexual activity for which Florida's statute of
limitation has run. Furthermore, in Florida, the statute of limitations does not simply give rise to
an affirmative defense. On the contrary, statute of limitations "creates a substantive right which
prevents prosecution and conviction of an individual after the statute has run." See State V. King,
282 So. 2d 162 (Fla. 1973); Tucker V. State, 417 So. 2d 1006 (Fla. 3d D.C.A. 1982) (citing
cases).
Given the one-year statute of limitations, any conduct that might amount to prostitution
or other chargeable sexual activity that occurred before one year from today is not conduct for
which any person can be charged with a criminal offense. Also, given the three year statute of
limitations for third degree felonies, any allegations of illegal state criminal conduct that is
classified as a third degree felony cannot be charged in the state and, concomitantly, cannot be
the basis for a federal charge under § 2422(b), to the extent that it occurred-as did almost all of
the pivotal allegations (e.g., the
allegation which was made in March of 2005)
prior to mid-June of 2005.
2.
18 U.S.C. $ 1591
2
The offense is a felony of the third degree only for a third or subsequent violation. Fla. Stat. $ 796.07(4)( c).
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18 U.S.C. § 1591, a sex trafficking statute, provides up to 40 years' imprisonment for
anyone (1) who recruits or obtains by any means a person in interstate commerce (ii) knowing
that the person is under 18 and (iii) knowing that the person will be caused to engage in a
commercial sex act. The most heinous of crimes, described on the CEOS website, fall within
this statute and include the buying and selling of children and the forced servitude of third-world
immigrants brought to this country to be enslaved. Mr. Epstein's behavior is nowhere near the
heartland of this statute. This statute has also been previously reserved for prostitution rings
involving violence, drugs and force. In stark contrast, there is no jurisdictional hook that brings
Mr. Epstein's conduct within the ambit of the statute, and securing a prosecution on these facts
would require a court to set aside both reason and precedent to convict a local 'John' with a sex-
slavery crime. It can not be said that Mr. Epstein engaged in trafficking and slavery nor did he
knowingly recruit or obtain underage women with knowledge that they would be caused to
engage in a commercial sex act. Thus, prosecuting him under this statute would expand the law
far beyond its scope.
To the extent there are cases where prosecutors think that Mr. Epstein should have known
that certain women were underage, there is no evidence that Mr. Epstein "caused [them] to
engage in a commercial sex act." The term "cause" naturally implies the application of some
sort of force, coercion, or undue pressure, but there is no evidence that Mr. Epstein's interactions
with the women were anything but consensual. Again, many of the women phoned Mr.
Epstein's assistant themselves in order to determine whether he wanted a massage. Nor can the
cause requirement be proved simply by the fact that Mr. Epstein compensated the women. After
all, the statute elsewhere requires that the women "engage in a commercial sex act," which by
definition means that they would have received something of value in exchange for sexual
services. Interpreting the statute to authorize prosecution whenever a commercial sex act results
from solicitation thus would render the term "caused" superfluous, and would make every 'John'
who interacts with an underage prostitute guilty of a federal crime-even where the transaction
is entirely local. Read in context, then, there is no doubt that the statute targets pimps and sex-
traffickers who knowingly obtain underage girls and direct them to engage in prostitution. There
is not a shred of evidence that Mr. Epstein (or his assistants) did any such thing, and he cannot be
prosecuted under this statute.
The Cuellar and Santos decisions also foreclose a prosecution under $ 1591. Just as the
federal money laundering statute did not come down to a proscription against transportation of
criminal proceeds that are hidden, the sex trafficking of children statute cannot be boiled down
and expanded to a federal proscription of commercial sexual activity with persons who turn out
to be below the age of 18.
3.
18 U.S.C. § 2423
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18 U.S.C. $ 2423(b), a statute enacted to prevent sex tourism, provides up to 30 years of
imprisonment for anyone who travels across state lines (i) for the purpose of engaging in (ii)
illicit sexual conduct with a minor. Neither of those elements is satisfied here.
Mr. Epstein did not travel to Palm Beach for the purpose of engaging in sexual activity
with a minor, within the meaning of the statute. The evidence is indisputable that Palm Beach
was where Mr. Epstein spent most of his discretionary time, and that his travels to Palm Beach
were merely trips returning often to his home of twenty years-not the escapades of a sex tourist
off to some destination inextricably intertwined with the required significant or dominant
purpose of that trip to be to have "illicit sexual conduct." Epstein's trips to Palm Beach were
simply those of a businessperson traveling home for weekends or stopping over on his way to or
from New York and St. Thomas or to visit his sick and dying mother in the hospital for months
on end. He certainly did not travel to his home in Florida for the dominant purpose of engaging
in sexual conduct with a person who he knew was under 18 when he did not know, at the time he
decided to travel, from whom he was to receive a massage, if he were to receive one at all.
In Cuellar, the unanimous Supreme Court linked the term "design" in the money-
laundering statute to the terms "purpose" and "plan," and stressed that those terms all required
the defendant to "formulate a plan for; devise"; "[t]o create or contrive for a particular purpose or
effect"; [carry out] "[a] plan or scheme"; or "to conceive and plan out in the mind." Slip. op. at
12 (citing dictionary definitions). The same link is present here, and it simply cannot be said that
Mr. Epstein's design, plan, or purpose in traveling to Palm Beach was to engage in illicit sexual
conduct with minors; his design or plan or purpose was simply to return to his home.
Any construction of $ 2423(b)'s "for the purpose of" language to include purposes
beyond the dominant purpose of the travel would run afoul of the rule of lenity and due process
principles discussed earlier. Any attempted prosecution of Mr. Epstein under a more expansive
construction of the "for the purpose of" language would also violate the separation of powers
doctrine. Congress, which selected the "for the purpose of" language signaled no clear intention
to make it a federal crime whenever an actor has engaged in illicit sexual conduct following his
crossing of state lines as long as it might be said that sexual activity at his destination was among
the activities he pursued there. Congress well knows how to write a statute in this field which
eliminates a purpose requirement. See 18 U.S.C. § 2423(c)("Any United States citizen or alien
admitted for permanent residence who travels in foreign commerce, and engages in any illicit
sexual conduct with another person "). $ 2423(b) is not such a statute.
Federal court decisions watering down the "for the purpose of requirement fly in the
face of the two Supreme Court decisions addressing that element. See Hansen V. Huff, 291 U.S.
559 (1934); Mortensen V. United States, 322 U.S. 369 (1944). Santos and Cuellar speak loudly
and clearly against prosecutors seeing such elasticity in federal criminal statutes, including those
enacted to protect important federal interests. In cases involving the federalization of activity
that is within the States' historic police power, Congress must speak with particular clarity. See,
e.g., Will V. Michigan Dep't of State Police, 491 U.S. 58, 65 (1989).
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Relevant Past Cases
We have not been able to find a single federal prosecution based on facts like these-but
have voluminous evidence of federal prosecutors routinely declining to bring charges in cases far
more egregious than this one. To take just one obvious example, federal prosecutors have self-
consciously refrained from involvement in the literally dozens of sexual cases of former priests,
opting instead to allow seasoned state prosecutors (like the ones in this case) to pursue the
accused former clergymen. That is so despite (1) the large number of victims, (2) the vast
geographic diversity of the cases, and (3) the fact that some of these cases involve allegations
that the defendant forcibly molested, abused, or raped literally dozens of children-including
some as young as five years old-over a period of years. Nonetheless, federal prosecutors have
not hesitated to let their state counterparts pursue these cases free from federal interference-
even though the sentences meted out vary greatly on account of the fact that "[c]riminal penalties
are specific to localities or jurisdictions."³ The facts of this case, which involve the solicitation
of consensual topless massages and some sexual contact, entirely in the privacy of his home and
almost entirely by women over the age of 18, pale in comparison to the outright sexual abuse and
degradation of preteen minors in many of the priest cases.
Nor does this case bear any of the hallmarks that typify the cases that federal prosecutors
have pursued under the federal statutes at issue here. When asked, the closest case suggested by
the prosecutors was United States V. Boehm-and it hardly could differ more from Mr. Epstein's
case. In Boehm, the defendant was charged with conspiracy to distribute cocaine and cocaine
base to minors, in violation of 21 U.S.C. §§ 846, 841(a)(1), and 859(a); being a felon in
possession of a firearm, in violation of 18 U.S.C. $ 922(g)(1); and sex trafficking of children in
violation of 18 U.S.C. §§ 371 and 1591. United States V. Boehm, Case No. 3:04CR00003 (D.
Alaska 2004). Boehm's actions, unlike Mr. Epstein's, also had a strong interstate nexus: Boehm
purchased and distributed large quantities of crack cocaine and cocaine that traveled in interstate
commerce, and he used his home and hotels (which were used by interstate travelers) to purchase
drugs and distribute them to minors while also arranging for these minors to have sex with him
and others. Indeed, Boehm not only (1) purchased cocaine in large quantities; (2) distributed the
drugs to minors; (3) possessed illegal firearms; (4) and arranged for the minors to have sex with
other members of the conspiracy in exchange for drugs; but (5) admitted to knowing the ages of
the individuals involved.4 Here, by contrast, as previous stated, all of the conduct took place in
Mr. Epstein's private home in Palm Beach; there was no for-profit enterprise; no interstate
component; no use by Mr. Epstein of an instrumentality of interstate commerce; no violence; no
force; no alcohol; no drugs; no guns; and no child pornography.
3
Se http://www.bishop-accountability.org/reports/2004_02_27_JohnJay/2004_02_27_Terry_Johnlay_3.htm
#cleric7.
4
In fact, Boehm and his co-defendants distributed drugs to approximately 12 persons between the ages of 13 and
21. Boehm also had a prior criminal history-and one that clearly showed he was a danger to society: he
previously had been convicted of raping both a thirteen year-old girl and a fifteen year-old girl. (Day 7 of
Sentencing hearing p. 32).
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To the extent there is a similar, but more egregious, local Florida case on the books, it is
that of Barry Kutun, a former North Miami city attorney accused of having sex with underage
prostitutes and videotaping the sessions. Mr. Kutun pleaded guilty on May 18, 2007 in a Miami-
Dade County courtroom as part of an agreement with State prosecutors and he received five
years probation and a withholding of adjudication with no requirement to register as a sex
offender-all without a shred of involvement by federal prosecutors, who declined to prosecute
him. Indeed, given the wide use of the telephone in today's society, it gives a rogue prosecutor
carte blanche to turn any local crime into a federal offense. Given the federal government's
decision to abstain from prosecuting that case, it is hard to understand how the federal
prosecutors responsible for this case think that the State's treatment of Mr. Epstein somehow
leaves federal interests substantially unvindicated. There is simply no basis for the federal
prosecutors' disparate treatment of Mr. Epstein.
Summary of the Evidence
Finally, we wish to share new evidence-obtained through discovery in connection with
the civil lawsuits filed in this matter-which confirms that further federal involvement in this
matter would be inappropriate. This testimony taken to date categorically confirms that (i) Mr.
Epstein did not target minors; (ii) women under 18 often lied to Mr. Epstein about their ages; (iii)
Mr. Epstein did not travel in interstate commerce for the purpose of engaging in illegal sexual
activity; (iv) Mr. Epstein did not use the Internet, telephone or any other means of interstate
communication to coerce or entice alleged victims; (v) Mr. Epstein did not apply force or
coercion to obtain sexual favors; and (vi) all sexual activity that occurred was unplanned and
purely consensual. The women's own statements-made under oath-demonstrate the absence
of a legitimate federal concern in this matter, and highlight the serious practical difficulties an
attempted federal prosecution would face.
Mr. Epstein did not recruit or obtain these women in interstate commerce (necessary
for a conviction under $ 1591).
confirmed that she did not know Mr. Epstein and had
absolutely no contact with him-be it through Internet, chat rooms, email,
or phone-prior to their arrival at his home. See Tab 13,
Tr.
(deposition), p. 30.
has stated that (like many other women) she first met Mr.
Epstein when her friend,
introduced her to him. See Tab
14,
Tr. A, p. 4-5.
Mr. Epstein was told the girls were over 18.
Ms.
expressly admitted to lying to Mr. Epstein about her age.
See Tab 13,
Tr. (deposition), p. 37 ("Q. So you told Jeff that you
were 18 years old, correct? A. Yes.").
stated that she not only always made sure she had a fake ID
with her and lied to Mr. Epstein by telling him she was 18, but that she
14
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KIRKLAND & ELLIS LLP
also had conversations with other women in which these women hoped
that "Jeffrey didn't find out [their] age[s]." See Tab 6,
Tr., p. 45.
Ms.
also stated that she: "would tell my girlfriends just like
approached me. Make sure you tell him you're 18. Well, these girls that I
brought, I know that they were 18 or 19 or 20. And the girls that I didn't
know and I don't know if they were lying or not, I would say make sure
that you tell him you're 18." See Tab 6,
Tr., p. 22.
Ms.
stated that Ms.
told her say that she was 18 if asked. See
Tab 14,
Tr. A, p. 8.
stated that she "told him I was 19." See Tab 5,
Tr., p. 16.
Mr. Epstein did not know these women would be caused to engage in a sex act
(necessary for a conviction under $ 1591) and any sexual activity that took place was
unplanned.
Ms.
stated "sometimes [Mr. Epstein] likes topless massages, but
you don't have to do anything you don't want to do. He just likes
massages." See Tab 6,
Tr., p. 7.
Ms.
also stated "[s]ometimes [Mr. Epstein] just wanted his feet
massaged. Sometimes he just wanted a back massage." See Tab 6,
Tr., p. 19.
Mr. Epstein did not use an interstate facility to communicate an illegal objective to
the alleged victims (necessary for a conviction under $ 2422(b)).
Ms.
confirmed that Mr. Epstein never emailed, texted, or chatted
in an Internet chat room with her. See Tab 13,
Tr. (deposition),
p. 30.
Mr. Epstein did not target minors (necessary for a conviction under $ 2422(b))
Ms.
stated, "I always made sure -- I had a fake ID, anyways, saying
that I was 18. And
(who is
friend who brought her to
Mr. Epstein's home)] just said make sure you're 18 because Jeffrey
doesn't want any underage girls." See Tab 6,
Tr., p. 8.
Mr. Epstein did not use the phone or the Internet to induce proscribed sexual activity
(necessary for a conviction under § 2422(b)).
Ms.
stated that there was never any discussion over the phone about
her coming over to Mr. Epstein's home to engage in sexual activity: "The
only thing that ever occurred on any of these phone calls [with
or another assistant] was, 'Are you willing to come over,' or,
15
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=== Page 16 ===
KIRKLAND & ELLIS LLP
'Would you like to come over and give a massage." See Tab 14,
Tr.
A, p. 15
Ms.
confirmed that she was informed that she was going to Mr.
Epstein's house to give him a massage and nothing else, and that no one
"said anything to [her] on the telephone [or over the Internet] about sexual
activity with Mr. Epstein." See Tab 13,
Tr. (deposition), p. 24-
25.
Ms.
also confirmed that no one associated with Mr. Epstein ever
tried to call her or contact her through the Internet to try to persuade,
induce, entice or coerce her to engage in any sexual activity. See Tab 13,
Tr. (deposition), p. 31.
Mr. Epstein did not travel to Palm Beach for the purpose of engaging in sexual
activity with a minor (necessary for a conviction under $ 2423(b)).
Mr. Epstein spent at least 100 days a year in Palm Beach for family
purposes, business purposes, and social purposes, and to maintain a home.
While in Palm Beach, Mr. Epstein routinely visits family members and
close friends, has seen his primary care physician for checkups and
prescribed tests in the Palm Beach area, and until her death in April of
2004, regularly saw his mother who was hospitalized and then
convalesced in south Florida.
From 2003 through 2005 there was no month when Mr. Epstein did not
spend at least one weekend in Palm Beach.
The Palm Beach area is the home base for his flight operations, for
maintenance of his aircraft, and for periodic FAA inspections.
Additionally, Mr. Epstein's pilots and engineers all resided in Florida.
Mr. Epstein's conduct did not involve force, coercion or violence and any sexual
activity that took place was consensual. The witness transcripts are replete with
statements such as the following:
Ms.
stated that she was not persuaded, induced, enticed or
coerced by anyone to engage in any sexual activity. See Tab 13,
Tr. (deposition), p. 31.
Ms.
stated: "[Mr. Epstein] never tried to force me to do anything."
See Tab 14,
Tr. A, p. 12.
Ms.
stated, "I said, I told Jeffrey, I heard you like massages topless.
And he's like, yeah, he said, but you don't have to do anything that you
16
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=== Page 17 ===
KIRKLAND & ELLIS LLP
don't feel comfortable with. And I said okay, but I willingly took it off."
See Tab 6,
Tr., p. 10.
Ms.
also stated "[s]ome girls didn't want to go topless and Jeffrey
didn't mind." See Tab 6,
Tr., p. 23.
Mr. Epstein did not engage in luring.
Mr. Epstein's message books show that several masseuses would regularly
call Mr. Epstein's assistants, without any prompting by Mr. Epstein or his
assistants, asking to visit Mr. Epstein at his home.
Ms.
stated "a lot of girls begged me to bring them back [to Mr.
Epstein's house]."
There was no alcohol or drugs involved, a fact that is not in dispute.
Mr. Epstein has no prior criminal history, a fact that is not in dispute.
These women do not see themselves as victims.
Ms.
indicated under oath that the FBI attempted to persuade her that
she was in fact a "victim" of federal crimes when she herself repeatedly
confirmed that she was not. See Tab 14,
Tr. A, p. 9-12 and Tab 15,
Tr. B, p. 7.
Conclusion
Jeffrey Epstein, a self-made businessman with no prior criminal history, should not be
prosecuted federally for conduct that amounts to, the solicitation of prostitution. A federal
prosecution based on these facts would be an unprecedented exercise of federal power, a misuse
of federal resources, and a prosecution that would carry with it the appearance, if not the reality,
of unwarranted selectivity given the incongruity between the facts as developed in this matter
and the factual paradigms for all other reported federal prosecutions under each of the three
statutes being considered. It would require the pursuit of a novel legal theory never before
sanctioned by federal law-and that indeed is inconsistent with each of the statutes prosecutors
have identified. Accordingly, we respectfully request that you direct the U.S. Attorney's Office
for the Southern District of Florida to discontinue its involvement in this matter, and return
responsibility for this case to the State of Florida.
17
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=== Page 1 ===
Event: Accepted: Epstein Op Meeting with FBI
Start Date: 2019-07-01 19:30:00 +0000
End Date: 2019-07-01 20:30:00 +0000
Organizer:
Class: X-PERSONAL
Comment:
Date Created: 2019-06-27 18:06:46 +0000
Date Modified: 2019-06-27 18:06:46 +0000
Priority: 5
DTSTAMP: 2019-06-27 17:42:50 +0000
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=== Page 1 ===
From:
To:
(USAFLS)"
Subject: Re: FW: Request for Written Staff Opinion ATTN Elizabeth Clark Tarbert; Logbook # 28386
Date: Tue, 04 Nov 2008 17:22:11 +0000
Importance: Normal
Attachments: 28386gef_denial.doc; Florida_Bar_Ltr_re_Ethics_Opinion.pdf_Final_Victim_Notification_
- -Sample.pdf; Final_Victim_Notification_Represented_Sample.pdf
Inline-Images: graycol.gif
Dear Ms.
:
My letter in response to your inquiry is attached below. This letter will be faxed and mailed to you later today.
If you have questions, please do not hesitate to call me at
or on the hotline at
Sincerely,
Gail E. Ferguson
Assistant Ethics Counsel
(See attached file: 28386gef denial.doc)
(USAFLS)"
on 09/29/2008 12:05:05 PM
To: "Ethics Opinions"
cc:
Subject: FW: Request for Written Staff Opinion ATTN Elizabeth Clark Tarbert; Logbook # 28386
Staff: Gail Ferguson/The Florida Bar
Dear Ms. Tarbert - Here is my earlier e-mail.
Thank you.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
EFTA00014009

=== Page 2 ===
From:
. (USAFLS)
Sent: Thursday, September 18, 2008 7:21 PM
To:
Cc:
(USAFLS);
(USAFLS)
Subject: Request for Written Staff Opinion
Dear Sir or Madam: Please see the attached correspondence. Thank you for your assistance.
<<Florida Bar Ltr re Ethics Opinion.pdf>>
<<Final Victim Notification -- Sample.pdf>>
<<Final Victim Notification Represented Sample.pdf>>
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
(See attached file: Florida Bar Ltr re Ethics Opinion.pdf)(See attached file: Final Victim
Notification -- Sample.pdf)(See attached file: Final Victim Notification Represented Sample.pdf)
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=== Page 1 ===
From:
To: Sigrid McCawley
Cc:
Subject: US V. Maxwell, 20 Cr. 330 (AJN)
Date: Fri, 19 Nov 2021 04:09:08 +0000
Attachments: 2021.11.18_Mot_to_quash_[final].pdf
Sigrid,
Attached is a copy of our motion to quash, which we just filed by email temporarily under seal. If it would be useful to
talk tomorrow, please let us know.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
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=== Page 1 ===
From:
=
(USAFLS)"
To:
(USAFLS)"
"Acosta, Alex (USAFLS)"
Subject: Epstein
Date: Fri, 01 Feb 2008 00:33:12 +0000
Importance: Normal
Hi
and Alex - We just finished interviewing three of the girls. I wish you could have been there to see how
much this has affected them.
One girl broke down sobbing so that we had to stop the interview twice within a 20 minute span. She regained
her composure enough to continue a short time, but she said that she was having nightmares about Epstein
coming after her and she started to break down again, so we stopped the interview.
The second girl, who has a baby girl of her own, told us that she was very upset about the 18 month deal she had
read about in the paper. She said that 18 months was nothing and that she had heard that the girls could get
restitution, but she would rather not get any money and have Epstein spend a significant time in jail.
The FBI's victim-witness coordinator attended and she has arranged for counseling for several of the girls.
Please reach out to
to make her decision. These girls deserve so much better than they have received so
far, and I hate feeling that there is nothing I can do to help them.
We have four more girls coming in tomorrow. Can I persuade you to attend?
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
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=== Page 1 ===
From:
"The Invisible Man" <abx17@dial.pipex.com>
To:
"G. Maxwell" <gmax1@mindspring.com>
Subject:
RE:
Sent:
Sat, 18 Aug 2001 22:42:18 +0100
Distraught!
You probably wouldn't know but I lost my valet on Thursday. He died in his
sleep. He had been with me since I was 2. I am a little off balance as
not only has my office been restructured, I have left the RN and now my
whole life is in turmoil as I have no one to look after me. He was a real
rock and almost a part of the family.
If you have any good ideas as to how to get my mind back on track I'd be
grateful for advice.
See you real soon.. I hope if you are coming over.
A XXX
Original Message
From: G. Maxwell [mailto:gmax1@mindspring.com]
Sent: 16 August 2001 16:32
To: abx17@dial.pipex.com
Subject:
So sorry to dissapoint you, however the truth must be told. I have only
been able to find appropriate friends. Will let you know about some church
meetings on those dates
Kisses
Gx
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=== Page 1 ===
From:
)"
To:
Cc:
)"
Subject: RE: New drive for Maxwell
Date: Fri, 04 Dec 2020 14:39:49 +0000
Thank you very much.
Original Message
From:
Sent: Friday, December 4, 2020 7:41 AM
To:
Cc:
)
Subject: Re: New drive for Maxwell
Not a problem.
Best,
"
)"
12/3/2020 5:24
PM
Hi all,
Today our office is sending via FedEx a replacement drive for Ghislaine Maxwell, which should arrive at the
MDC tomorrow. This drive will replace the drive that Maxwell recently dropped and broke, and the
accompanying cover letters are attached. Would you please make sure Maxwell is given access to this drive?
Would you please mail the broken drive back to our office? It can be mailed to the below address:
Paralegal Specialist
U.S. Attorney's Office, SDNY
New York, NY 10007
Thanks very much, as always, for your help.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00010200

=== Page 2 ===
New York, NY 10007
<mailto:
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=== Page 1 ===
From:
To: BOBBI C STERNHEIM
Cc:
Subject: RE: Ghislaine Maxwell 02879-509
Date: Mon, 16 Nov 2020 18:06:58 +0000
Bobbi,
Thank you for including me on this email. I understand from my conversation with MDC legal counsel today that MDC
staff is continuing to monitor temperatures throughout the facility, including in the area where Ms. Maxwell is housed. My
understanding is that the temperature where Ms. Maxwell is housed remains within the limits prescribed by BOP policy
and that the MDC does not expect this week's activities to affect the temperature in Ms. Maxwell's cell. That said, they will
continue to monitor the temperature and take appropriate action if it falls below prescribed limits.
As has previously been conveyed via letter from the Government to defense counsel dated October 8, 2020, the MDC's
assessment continues to be that Ms. Maxwell's current cell is the most appropriate placement for Ms. Maxwell both for her
safety and the security of the institution.
Finally, you have referenced a court order directing that certain steps be taken by the BOP. The only order of which I am
aware is Judge Nathan's order dated August 25, 2020, which denied Ms. Maxwell's request for an order concerning the
conditions of confinement at the MDC (See Dkt. No. 49 at 2-3). Please let me know if there is a different order to which
you are referring.
Best,
Assistant United States Attorney
Southern District of New York
From: BOBBI C STERNHEIM
Sent: Monday, November 16, 2020 9:50 AM
To:
Cc:
Subject: Ghislaine Maxwell 02879-509
Good afternoon-
I am informed that the NYC Dept. of Design & Construction will shut off
water and heat to the MDC from 9:00 pm to 5:00 am beginning tonight until 11/21.
I am further informed that the MDC will give inmates one bottle of water
and an extra blanket due to this disruption of services.
I am requesting that my client - Ghislaine Maxwell (02879-509)
be moved from her present isolation cell with two exterior walls to an interior cell.
Please explain why she cannot be moved to the cell in the
dayroom area where, by Court order, she is permitted to review discovery
from 7:00 am to 8:00 pm.
Thank you-
Bobbi C. Sternheim
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
EFTA00009920

=== Page 2 ===
Main:
Cell:
Fax:
**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.
On Nov 10, 2020, at 1:45 PM,
wrote:
The City contacted us and they said the water and heat will not be shut off. The information has been posted on the inmate Bulletin.
BOBBI C STERNHEIM
11/9/2020 3:47 PM
Good afternoon-
I am informed that the NYC Dept. of Design & Construction will shut off
water and heat to the MDC from 8:30 pm to 4:00 am beginning tonight until 11/17.
I am further informed that the MDC will give inmates a bottle of water and an extra blanket
due to this disruption of services.
I am requesting that my client - Ghislaine Maxwell (02879-509)
be moved from her present isolation cell with two exterior walls to an interior cell.
Please explain why she cannot be moved to the cell in the
dayroom area where, by Court order, she is permitted to review discovery
from 7:00 am to 8:00 pm.
Thank you-
Bobbi C. Sternheim
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
**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.
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=== Page 3 ===
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=== Page 1 ===
From: Christian Everdell
To: "NathanNYSDChambers@nysd.uscourts.gov"
Cc:
"Mark S. Cohen"
"BOBBI
C STERNHEIM"
'Jeff Pagliuca'
,
'Laura Menninger'
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Renewed Bail Motion and Exhibits (to be
Filed Under Seal)
Date: Tue, 08 Dec 2020 22:23:57 +0000
Attachments: Exhibit_O.pdf; Exhibit_P.PDF; Exhibit_Q.pdf; Exhibit_R.pdf; Exhibit_S.PDF;
Exhibit_T.pdf; Exhibit_U.pdf; Exhibit_V.pdf; Exhibit_W.pdf; Exhibit_X.pdf
Inline-Images: image001.gif; image002.jpg
Dear Judge Nathan -
Attached please find the following documents submitted to the Court and all counsel under seal pursuant to the Court's
order (Dkt. 89):
1. Accompanying exhibits O-X (unredacted)
Regards,
Christian R Everdell
COHEN & GRESSER LLP
New York, NY 10022
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
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=== Page 1 ===
From:
To:
Cc:
Bec:
Subject: Draft Indictment
Date: Tue, 03 Jun 2008 14:43:19 +0000
Importance: Normal
Attachments:080429_revised_indictment_without_Watermark.wpd;
080429_revised_indictment_with_Watermark.wpd
Hi
called and said that
needed a copy of this. The first copy has a "draft" watermark on it,
and the second is exactly the same except that the watermark is removed.
<<080429 revised indictment without Watermark.wpd>> Thanks!
<<080429 revised indictment with Watermark.wpd>>
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=== Page 1 ===
From:
To: Nathan NYSD Chambers
Cc:
Christian Everdell
"Mark S. Cohen"
>, Bobbi Sternheim
>, 'Laura
Menninger'
>, , "Jeff Pagliuca"
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Government Opposition to Defense Motions
Date: Sat, 27 Feb 2021 04:20:19 +0000
Attachments: Brief_Exhibits.zip; 2021-02-26_GM_Government_pre-
trial_opposition_cover_letter_(final).pdf,PROPOSED_REDACTIONS_ -
2021.02.26_Government_Omnibus_Opposition_to_Maxwell_Defense_Motions_FINAL.pd
f;
2021.02.26_Government_Omnmibus_Opposition_to_Maxwell_Defense_Motions_FINAL_U
NREDACTED.pdf
Good evening,
Attached please find the Government's omnibus memorandum of law in opposition to the defense's pretrial motions in
the above-referenced case. Also attached is a zip file containing the exhibits to the memorandum, as well as a cover
letter. The cover letter has been filed on ECF, and the Government requests that the remaining filings be accepted
temporarily under seal.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
From:
To:
Subject: RE: Ghislaine Maxwell custody
Date: Thu, 02 Jul 2020 21:04:06 +0000
Thanks very much.
From:
Se
Subject: Fwd: Ghislaine Maxwell custody
FYI
Sent from my iPhone
Begin forwarded message:
From:
Date: July 2, 2020 at 3:43:43 PM EDT
To: "NHD-SUPERVISORS (USMS)" <USMS-NHD-SUPERVISORS@usms.doj.gov>
Cc:
Subject: Ghislaine Maxwell custody
To all:
Below are the restrictions we have put in place regarding Ms. Maxwell during her stay at Merrimack DOC. I. If you have
any questions please feel free to call or email me.
Due to the high profile status of this case Inmate Maxwell will be closely monitored. The following directives
apply and shall not be deviated from without express permission from
myself or
1.
Inmate Maxwell will be housed in M1
2.
SRT personnel will be posted in medical and will only be relieved only by SRT personnel
3.
Staff will not converse with the inmate outside of the standard communication required related to the
inmate's health and safety
4.
Inmate Maxwell will remain on a 15 minute observation watch
5.
All rounds, and touch probe rounds will be conducted and documented in XJail
6.
Third Shift Supervisors will download the touch probe rounds and camera footage from the previous day
at 0000 hours each day. The video from the medical cell DVR will be downloaded onto a USB drive and will
EFTA00010358

=== Page 2 ===
be tracked via the designated tracking form provided. Supervisors are directed to deliver this documentation
and video to
Monday July 6th
7.
Inmate Maxwell will be authorized to communicate with her legal counsel, Lawrence Vogelman. This
contact is only authorized after Atty Vogelman provides the appropriate PIN
8.
Any and all requests from Inmate Maxwell are to be directed to
only
At no time are staff authorized to make statements to the press regarding this matter or our SOP regarding this
inmate.
Supervisory Deputy United States Marshal
District of New Hampshire
Concord, New Hampshire
office
This e-mail is property of U.S. Marshals Service. It is intended only for the person or entity to which it is addressed and
may contain information that is privileged, confidential, or otherwise protected from disclosure. Distribution or copying
of this e-mail or the information contained herein by anyone other than the intended recipient is prohibited. If you have
received this e-mail in error, please notify me immediately and destroy all electronic and paper copies of this e-mail.
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of Florida
500 S. Australian Ave, Ste 400
West Palm Beach, FL 33401
Facsimile: (561) 820-8777
August 20, 2008
DELIVERY BY ELECTRONIC MAIL
Jay P. Lefkowitz, Esq.
Kirkland & Ellis LLP
Citigroup Center
153 East 53rd Street
New York, New York 10022-4675
Roy Black, Esq.
Black Srebnick Kornspan & Stumpf P.A.
201 S. Biscayne Blvd, Suite 1300
Miami, FL 33131
Re: Jeffrey Epstein
Dear Jay and Roy:
Thank you for your response to my earlier letter. The U.S. Attorney's Office shares in
your desire to implement all of the terms of the Non-Prosecution Agreement. As you are aware,
the jointly-approved Special Master, Judge Davis, has already selected an attorney representative,
Robert Josefsberg, who was accepted by both parties. The Office has conferred with Mr.
Josefsberg, who has agreed to continue in that role. In October 2007, Mr. Josefsberg expended
time, effort, and funds in preparing to serve as the attorney representative, and he will need a
written confirmation from you that his future fees and expenses will be paid in accordance with
the terms of the Non-Prosecution Agreement. Please provide me with a copy of that
correspondence for my file.
With that matter settled, I believe that the requirement for a joint written submission to the
Special Master has been extinguished. Nonetheless, I have no objection to attempting to create a
joint statement to assist Mr. Josefsberg in serving his duties. Regarding your suggestion that we
ask Judge Davis to "offer the final word on how certain clauses should be interpreted and
satisfied," I believe that the Agreement speaks for itself and any ambiguities that you perceive
will be resolved with litigation with the intended third-party beneficiaries, i.e. , the listed victims.
In light of the ongoing litigation between the United States and two of the victims, I am
concerned that efforts to modify or even interpret the Agreement will require consultation with
all of the victims, which will be unwieldy and extremely time consuming.
As to your other points, I am happy to revert to the shorter list that was prepared as of the
signing of the Non-Prosecution Agreement in September 2007, so long as the United States may
proceed to prosecute your client for those victims identified after that date. If your position is
that the Agreement covers all crimes related to victims known to the United States as of June 30,
2008, then all of those victims should be entitled to compensation. Please advise me of your
client's election by Friday morning so that the appropriate revised victim notifications may be
distributed and I can prepare the final victim list.
Copies of the victim notifications will continue to be provided to counsel for Mr. Epstein.
Please let me know whether I should continue to list Mr. Goldberger as the point of contact for
the civil litigation. Regarding your suggestion on the content of the notification letters, I intend
to use the same format that was used in the letters previously approved by Messrs. Goldberger
EFTA00013949

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and Tein, except that I will include the language from the September and October agreements. I
have enclosed a draft herewith. Because I previously provided the victims with incorrect
information-albeit with the approval of Mr. Epstein's counsel-it is imperative that I correct the
error promptly. Accordingly, if you have any substantive objections to the letter, please advise
me by tomorrow afternoon.
Sincerely,
R. Alexander Acosta
United States Attorney
By:
Assistant United States Attorney
cc:
Chief, Northern Division
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From:
To:
Subject: RE: Jeffrey Epstein
Date: Mon, 24 Nov 2008 19:34:03 +0000
Importance: Normal
Wow --- have you heard anything back?
From: Villafana, Ann Marie C. (USAFLS)
Sent: Monday, November 24, 2008 12:29 PM
To: Roy BLACK
Cc: Atkinson, Karen (USAFLS)
Subject: Jeffrey Epstein
Dear Roy:
Please review the attached letter.
Thank you.
<< File: 081124
Itr to Black.pdf >>
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
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From:
r
(USANYS) 3"
To:
(USANYS)"
Subject: Automatic reply: UMR - Epstein/DB
Date: Thu, 19 Sep 2019 12:26:02 +0000
I will be out of the office on work travel until September 20th. I will be checking email intermittently, but if you
need urgent assistance before then, please contact
at
EFTA00013464


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=== Page 1 ===
Case 1:20-cv-00484-JGK-DCF Document 114 Filed 06/16/21 Page 1 of 1
USDC SDNY
UNITED STATES DISTRICT COURT
DOCUMENT
SOUTHERN DISTRICT OF NEW YORK
ELECTRONICALLY FILED
DOC#
DATE FILED: 6.16.21
JANE DOE
Plaintiff,
20 CV 484 (JGK)
- against -
ORDER
DARREN K. INDYKE, ET AL.
Defendants.
JOHN G. KOELTL, District Judge:
Defendant, Ghislane Maxwell, seeks to have her costs in the
amount of $13.70 taxed against the plaintiff because the
plaintiff dismissed this action with prejudice against Ms.
Maxwell. The Clerk declined to tax costs because the plaintiff
disputed whether Ms. Maxwell was a prevailing party. This Court
previously found that Ms. Maxwell was a prevailing party. See
ECF No. 98 at 5. By letter dated June 10, 2021, ECF. No. 113,
counsel for the plaintiff indicated that if the Court is
inclined to grant Ms. Maxwell's request, the plaintiff will send
the plaintiff the $13.70. Because Ms. Maxwell is the prevailing
party, the plaintiff should pay the costs in the amount of
$13.70.
so ORDERED.
Dated:
New York, New York
June 16, 2021
John G. Koeltl
United States District Judge
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=== Page 1 ===
Case 1:19-cr-00490-RMB Document 56 Filed 09/04/19 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES COURTHOUSE
500 PEARL STREET
NEW YORK, NEW YORK 10007
(212) 805-6715
USDC SDNY
CHAMBERS OF
RICHARD M. BERMAN
UNITED STATES DISTRICT JUDGE
DOCUMENT ELECTRONICALLY FILED
DOC DATE #: FILED: 9/4/19
Bruce A. Green
September 4, 2019
Louis Stein Chair
Fordham University School of Law
150 West 62nd Street
Room 7-168
New York City, NY 10023
Dear Professor Green,
Thank you for your letter of August 30, 2019. I appreciate your taking the time to clarify
the record.
I learned that you had been "retained to provide opinions as an expert on legal ethics" in
V. Dershowitz following the August 27, 2019 public hearing in US V. Epstein. I learned
of your role in the
case by reading your affidavit, dated June 7, 2019, which includes
your legal ethics opinion that David Boies should be disqualified from representing Ms.
in that matter. As you are aware, both Mr. Boies and Ms.
were invited to testify at the
August 27, 2019 hearing.
I remain surprised that your advocacy of Mr. Boies' disqualification from representing
Ms. Guiffre (in a case obviously related to US V. Epstein) was not disclosed simultaneously with
your August 26, 2019 Law Journal opinion piece entitled "The Judge in Epstein's Case Should
Not Turn the Dismissal Into a Drama for the Victims." I am also surprised that you would find
the August 27, 2019 public hearing to be an inappropriate occasion for transparency in light of
Federal Rule of Criminal Procedure 57 and the Crime Victims' Rights Act, 18 U.S.C. § 3771.
You wrote: "This is an odd moment for transparency in a criminal case."
1
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=== Page 2 ===
Case 1:19-cr-00490-RMB Document 56 Filed 09/04/19 Page 2 of 2
Finally, it is unfortunate that your opinion piece may have been construed as an effort to
chill Ms.
and Mr. Boies' right to be heard under 18 U.S.C. § 3771 at the August 27,
2019 public hearing. You wrote: "[W]hatever informational interests the victims may have
would be served by affording them a chance to attend the hearing, not by giving them a speaking
role."
Sincerely,
RMB
Richard M. Berman
U.S.D.J.
cc:
AU
Martin G. Weinberg, Esq.;
Reid Weingarten, Esq.; David Boies, Esq.
2
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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
November 18, 2020
BY EMAIL & HAND
Esq.
Legal Counsel
Federal Bureau of Prisons
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Enclosed please find a laptop for Ghislaine Maxwell (Reg. No. 02879-509), an inmate at
the Metropolitan Detention Center ("MDC"). Our Office is providing this laptop to Ms. Maxwell
for the sole purpose of reviewing discovery materials in connection with the above-captioned case.
Information Technology staff at our Office have reviewed the laptop and confirmed that the laptop
has been successfully modified to meet the specifications you have requested. In particular, we
have been informed that:
The laptop contains a microphone and camera, both of which have been disabled. As a
result, the laptop has no recording capabilities.
The laptop does not contain any programs for games.
Communication capabilities have been disabled. In particular, the laptop has no Wi-Fi,
Bluetooth, or Ethernet connection capabilities.
In order to permit Ms. Maxwell to make effective use of this laptop in reviewing her
discovery, please permit her to use the accompanying charger to ensure that the laptop remains
operational throughout her review periods. Please also permit Ms. Maxwell to review the contents
of all discovery hard drives produced by our Office to the MDC in connection with the above-
referenced case on this laptop.
Please do not hesitate to contact us with any questions or concerns. Thank you for your
assistance in this matter.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
By:
Assistant United States Attorneys
Southern District of New York
Tel:
Email:
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=== Page 1 ===
From:
"
(USAFLS)"
To:
)"
Bcc: "USAHUB-USAJournal111"
Subject: Epstein documents
Date: Tue, 02 Feb 2021 19:12:08 +0000
Embedded: Epstein_documents.msg
Sender
Subject: Epstein documents
Message-Id:
<BN3P110MB02581D65E734FC2A1419FF8AF8B59@BN3P110MB0258.NAMP110.PROD.OUTLOOK.CO
M>
To:
EFTA00011269


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From:
To:
(USANYS)"
Cc:
"
)"
)"
(USANYS)"
[Contractor]"
Subject: RE: SDFL Epstein-related documents
Date: Tue, 25 Aug 2020 15:26:04 +0000
Sounds good.
From:
(USANYS)
Sent: Tuesday, August 25, 2020 11:02 AM
To:
Cc:
is
>;
is
(USANYS)
is
(USANYS)
[Contractor]
Subject: RE: SDFL Epstein-related documents
Thanks very much for the quick response,
3pm today works for us. We can circulate a dial in and look forward to
talking further then.
From:
Sent:
To:
(USANYS)
Cc:
is
)
>;
>;
(USANYS)
in
USANYS)
[Contractor]
Subject: RE: SDFL Epstein-related documents
Hello
I can do a call this afternoon. Any time between 2:00 p.m. and 4:00 p.m. is best. Alternatively, I am available tomorrow
during the same time period. Let me know which time is more convenient for you and your team. If these times don't
work, let me know and we will work out an alternate time.
In the meantime, we have all the materials in a secure room on our second floor in West Palm Beach. There are the case
files and also boxes of files that were gathered for the OPR inquiry. We have an inventory of our materials and also OPR
has their own inventory of the materials.
When OPR was here earlier, we had a scanner on that floor dedicated for their exclusive use. They were able to scan the
documents that they wanted and have those documents sent directly to their own DOJ accounts. I was overseas at the
time on detail, but I was told that this worked rather well.
A copy of our inventory is attached.
I look forward to assisting you in this matter.
EFTA00010429

=== Page 2 ===
Best regards,
Managing Assistant United States Attorney
West Palm Beach Regional Office - SDFL
From:
(USANYS)
Sent: Tuesday, August 25, 2020 9:00 AM
To:
Cc:
is
>;
is
(USANYS)
[Contractor]
Subject: SDFL Epstein-related documents
We supervise the team in New York that is currently prosecuting Ghislaine Maxwell, and
suggested
we reach out to you. As discussed briefly with
we are hoping to locate the boxes of documents and other records
regarding the prior SDFL investigation into Jeffrey Epstein and his co-conspirators that we understand are currently being
stored in the West Palm Beach office. In particular, we would like to make arrangements to review and scan those
materials in connection with our own case, and
uggested that we touch base with you on how best to do so.
I've copied the trial team here. Please let us know if you have time for a call in the near future to discuss further.
Alternatively, if there is a more appropriate point of contact on this issue, please feel free to point us in that direction.
Thanks very much,
Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
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From:
"
(USAFLS)"
To:
Subject: Read: Communications from Jeff Herman re Epstein matter
Date: Wed, 17 Sep 2008 14:44:14 +0000
Importance: Normal
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=== Page 1 ===
From: Nathan NYSD Chambers
To: Jeff Pagliuca
Laura Menninger
,
(USANYS)"
)"
Subject: 20cr330, US V. Maxwell
Date: Fri, 12 Nov 2021 02:55:17 +0000
Attachments: 20cr330_Order_11.11.21.pdf
Counsel:
Attached please find an order issued by Judge Nathan, which will be filed on the docket tomorrow morning.
Sincerely,
Chambers of the Hon. Alison J. Nathan
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From:
"
(USANYS)"
To: "
(USANYS)"
:
(USANYS)"
Subject: 2020-09-28 GM letter to Judge Nathan re discovery from other agencies v2
docx
Date: Wed, 30 Sep 2020 15:09:49 +0000
Attachments:2020-09-28_GM_letter_to_Judge_Nathan_re_discovery_from_other_agencies_v2, docx
Let me know if you have any thoughts?
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=== Page 1 ===
Independent
Epstein Victims' Compensation Program
PROTOCOL
DRAFT1
December 13, 2019
I.
Purpose and Overview
The Epstein Victims' Compensation Program (the "Program") is a voluntary, independent Program that
has been established to compensate and resolve the claims of victims/survivors of sexual abuse by Jeffrey
Epstein ("Epstein").
The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims
administration experts Kenneth R. Feinberg, Camille S. Biros and Jordana H. Feldman to design the
Program. Ms. Feldman will also serve as the Administrator of the Program (the "Administrator").
Through the Program, the Estate wishes to acknowledge the wrongs endured by victims/survivors and
offer them an opportunity to voluntarily resolve their individual claims for such sexual abuse.
The Program is governed by the following non-exclusive guiding principles:
The Program is purely voluntary. It does not affect any rights a victim may have
unless and until the Claimant accepts the offered compensation and executes a
Release. A Claimant may reject the offer of compensation and may stop participating
in the Program and withdraw the claim at any time prior to execution of the Release.
The Program is independent and will in no way be administered, controlled or
overseen by the Estate. The Administrator is responsible for all decisions relating to
the review, processing and evaluation of individual claims submitted to the Program.
The Administrator will have final, binding and exclusive authority to determine
Claimant eligibility and the valuation of each eligible individual claim. Decisions of
the Administrator made pursuant to this Protocol are not subject to review or
modification in any way by the Estate or any other party or entity.
There is no cap or limitation on the aggregate amount of funds available to
compensate all eligible Claimants or on the amount of compensation to be made to
each individual Claimant. Each individual claim will be evaluated separately by the
Administrator. The Administrator will determine, in her sole and exclusive discretion,
issues of eligibility and the amount of compensation.
1 This document is a draft of the Protocol governing the Program and is subject to input from victims/survivors, their lawyers,
other potentially interested parties, and representatives of the Estate.
1 I Page
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=== Page 2 ===
All Claimants will be treated with respect, dignity and fairness without regard to race,
color, sexual orientation, national origin, religion, gender or disability. To ensure
claims will be adjudicated fairly, the Administrator will manage the process so that
all Claimants can equally access the Program's claim process. Individuals with
disabilities will be given the opportunity to effectively communicate their claims and
to request special process accommodations.
The Program will be effective within 90 days of approval by the Superior Court of the U.S. Virgin Islands
("Effective Date")2 and is available to all victims/survivors regardless of where they were harmed, when
they were harmed, whether the claim is time-barred by the applicable statute of limitations, and whether
they have previously filed a lawsuit against or settled with Epstein and/or the Estate.
The exclusive claims period for filing a claim pursuant to this Protocol shall commence on the to-be-
determined Effective Date and shall conclude nine (9) months after that date ("Filing Deadline"). All
individual claims filed with the Program must be postmarked within this period.
II.
Eligibility Requirements
A. Eligibility Criteria
The persons eligible to participate in this Program are individuals who allege they were sexually abused
by Epstein. In addition, the following criteria apply:
The claim of sexual abuse must be directed against Epstein.
An individual whose claim is time-barred by the applicable statute of limitations may participate
in the Program provided that other eligibility criteria are met.
An individual who previously entered into a settlement agreement resolving a claim of sexual
abuse against Epstein may participate in the Program provided that other eligibility criteria are
met.
An individual who allegedly assisted Epstein in procuring other victims/survivors may participate
in the Program where there is a credible basis to determine that the individual acted under
duress as a result of her own sexual abuse by Epstein, provided that other eligibility criteria are
met.
If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with
prejudice any existing lawsuits or legal actions or claims filed against the Estate or related entities
and/or individuals. The Claimant must provide proof of such dismissal along with or prior to the
signed acceptance letter and executed Release in order to receive payment.
2 The final version of the Protocol will include dates certain identifying the commencement date of the Program and
registration and filing deadlines, as explained below.
2 I Page
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=== Page 3 ===
B. Legal Representatives of Claimants
An individual may file a claim on a victim's behalf where that individual has been granted legal authority
to act in a representative capacity pursuant to appropriate law. The "Legal Representative" of an
individual Claimant shall mean: (1) in the case of a Claimant who is currently a minor, a parent or legal
guardian authorized by law to serve as the minor's legal representative; (2) in the case of an incompetent
or legally incapacitated Claimant, a person who has been duly appointed as the Claimant's legal
representative in accordance with applicable law; or (3) an attorney authorized to represent the Claimant
for purposes of pursuing a claim through this Program.
Legal Representatives must provide proper documentation demonstrating representative capacity. Such
proof may include a power of attorney, documentation showing the individual's appointment as guardian
or guardian ad litem, or a copy of a retainer agreement showing legal representation signed by both the
Claimant and the attorney.
III.
Claims Administration - Submission, Evaluation and Determination
A. Claims Submission Process
Individuals who have filed a lawsuit, legal action or claim against Epstein and/or the Estate on or before
the Effective Date will be sent a Claim Form and other relevant Program information, including
Instructions for completion and submission of the Claim Form and a list of Frequently Asked Questions.
Individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the Estate on or
before the Effective Date may register to participate in this Program on the Program's website at
www.EpsteinVictimsCompensationProgram.com To register, such individuals must complete a
questionnaire setting forth their name, contact information, a summary description of the nature of the
claim and other requested information. Upon registration, the Administrator will perform a preliminary
review to consider if the individual is eligible to participate in the Program. If the Administrator deems
that the individual is eligible to participate in the Program, she will then send that individual a Claim Form
and other relevant Program information.
Note: The fact that an individual is sent a Claim Form and other relevant Program information indicates
that the Administrator has determined that such individual is eligible to participate in the Program. It
does not indicate that the Administrator has determined that such individual is eligible to receive
compensation. That determination is made only after a Claim Form and all required documentation has
been submitted and evaluated by the Administrator.
Registrations will be accepted by the Administrator from the Effective Date through a date that is 45 days
prior to the Filing Deadline ("Registration Deadline"). It is important to note that the Registration Deadline
is separate from, and precedes, the Filing Deadline. As explained above, all claims must be filed by the
Filing Deadline.
3 This website is in the process of being developed and is yet operational.
3 I Page
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=== Page 4 ===
All Claim Forms must be completed and postmarked no later than the Filing Deadline. Claim Forms
should be mailed via overnight courier (a pre-paid courier voucher will be included with each packet) to
the Administrator at the following address or uploaded to the Program website at
www.EpsteinVictimsCompensationProgram.com:
Epstein Victims' Compensation Program
c/o Jordana H. Feldman, Administrator
[Address - To Be Inserted]
Claimants are invited to provide documentation identified in the Claim Form, and any other corroborating
or supporting information sufficient to substantiate the claim, satisfy eligibility requirements, and allow
the Administrator to review, process and evaluate the claim. If the claim is being presented by a Legal
Representative, then the Legal Representative will be responsible for submitting the necessary
documentation relating to the represented Claimant.
Additional documentation may be requested at the discretion of the Administrator. Both the Claimant
and the Estate will be afforded the opportunity to submit to the Administrator any information deemed
relevant to the Administrator's evaluation and determination of the claim before the Administrator's final
disposition of the claim.
If a Claimant submits an incomplete or deficient claim, the Administrator will notify the Claimant, explain
the additional information that is needed, and work with the Claimant or the Claimant's Legal
Representative (where applicable) to assist in submitting a complete claim.
B. Claims Evaluation and Determination
Claims will be evaluated in the order in which they are received, with the Administrator evaluating each
submitted individual claim in a prompt and fair manner. Claims will only be determined once all required
documentation has been submitted to the Administrator
1. Factors Considered in Evaluating Claims
As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
information available, whether the allegations of sexual abuse are credible. The Administrator will
consider appropriate factors and corroborative support, including but not limited to:
The level of documentation, corroboration or other circumstantial evidence regarding the nature
and extent of the abuse, the frequency, location and other details of the abuse, and the age of
the victim at the time of the abuse. Non-exhaustive examples of such evidence include (i)
medical or psychiatric counseling/therapy records relevant to the abuse, and
(ii) contemporaneous written notification or other correspondence (e.g., letters, emails) of the
abuse by the Claimant to law enforcement authorities, parents, friends or others.
Whether there exists any information and/or pertinent findings offered by the appropriate
Office of the District Attorney or other law enforcement agency.
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Whether the Administrator finds the claims of the individual to be credible after complete review
of all relevant documentation and other evidence provided by the Claimant and the Estate.
As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
information available, the amount of compensation that should be offered to each eligible Claimant. The
Administrator will consider appropriate factors and corroborative support, including but not limited to:
The nature, duration and extent of the sexual abuse suffered by the Claimant.
The age of the Claimant at the time of the sexual abuse.
The nature and extent of the Claimant's physical or psychological damage resulting from the
sexual abuse, and the effect of the sexual abuse on the Claimant.
The credibility of the claim based upon all of the facts and circumstances, supporting
documentation and corroborating evidence.
Whether the claim is time-barred under the applicable statute of limitations.
Whether the Claimant previously entered into a settlement agreement with Epstein and received
a payment pursuant to such agreement.
The Administrator will confidentially send the Claimant a compensation determination letter including the
following: (1) the Administrator's eligibility decision regarding the claim; (2) the amount of compensation
offered; (3) a Release to be signed by the Claimant if the Claimant accepts the offered compensation; and
(4) a Payment Option Form. The Administrator's offer shall be valid for 60 days from the date of the
compensation determination letter.
The Administrator's determinations in this Program will not be binding on any potential criminal
investigation involving the same or similar allegations or Claimant.
2. Opportunities to be Heard
The Claimant will be afforded an opportunity to be heard, either before or after the Administrator renders
her determination. Upon request by the Claimant, the Administrator will be available to meet in person,
by video conference/Skype, or by teleconference to further discuss the claim. These meetings are
completely optional and voluntary. Requests to meet with the Administrator should be sent by email
claimantservices@epsteinvictimscompensationprogram.com and will be scheduled at a mutually
convenient time and location. The Administrator may also request a meeting with a Claimant or her Legal
Representative at a reasonable mutually convenient time and location, though the Claimant is not
obligated to attend any such meeting.
4 This email address is not yet active.
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=== Page 6 ===
3. Release
By submitting a claim to the Program, a Claimant is seeking to resolve all claims relating to allegations of
sexual abuse against Epstein and/or the Estate, related entities and/or individuals. If a Claimant chooses
to accept the offer of compensation pursuant to the Program, the Claimant will be required to sign and
execute a full Release, in a form satisfactory to the Estate, of all past and future claims relating to such
allegations of sexual abuse against the Estate, related entities and/or individuals. A Claimant may reject
the offer of compensation and may stop participating in the Program and withdraw the claim at any time
prior to the execution of the Release.
The Release will waive any rights the Claimant and her heirs, descendants, legatees or beneficiaries
may have to assert any claims relating to allegations of sexual abuse against the Estate, related entities
and/or individuals, to file an individual legal action relating to such allegations, or to participate in any
legal action associated with such allegations, except as a witness. However, the Release will not
operate to preclude or limit the Claimant's ability to report and discuss allegations of sexual abuse with
law enforcement officials or anyone else.
Before signing a Release, the Claimant must consult with an attorney. If the Claimant is not represented
by an attorney, the Program will provide an attorney to provide free legal counseling to the Claimant
for the sole purpose of advising the Claimant concerning the language and binding nature of the
Release.
No one affiliated with the Program will provide tax or legal advice to those receiving payments under
the Program. Claimants are urged to consult with a tax advisor concerning any questions regarding tax
liability for payments pursuant to the Program.
4. Payments
Upon the Claimant's acceptance of the Administrator's determination, the Administrator's receipt of
the Claimant's executed Release and, where applicable, dismissal with prejudice of any existing lawsuit
or legal actions or claims against the Estate or related entities and/or individuals, the Administrator will
initiate payment by check or electronic funds transfer to each eligible Claimant as directed by the
Claimant. Checks will be sent to Claimants via overnight courier service.
C. Program Integrity
For the purpose of protecting both the integrity of the Program and financial resources for eligible
Claimants, the Administrator will institute all necessary measures to prevent payment of fraudulent
claims, including taking steps to verify claims and analyze submissions for inconsistencies, irregularities
or duplication.
6 I Page
EFTA00011033

=== Page 7 ===
Each Claimant who signs the Claim Form at the time of submission certifies that the information provided
in the Claim Form is true and accurate to the best of the Claimant's knowledge, and that the Claimant
understands that false statements or claims made in connection with such submission may result in fines,
imprisonment and/or any other remedy available by law. Claims that appear to be potentially fraudulent
or to contain false information will be forwarded to federal, state or local law enforcement agencies
and/or the appropriate Office of the District Attorney for possible investigation and prosecution.
D. Confidentiality/Privacy
The Program is confidential. By filing a claim with the Program, the Claimant or her Legal
Representative (where applicable) agrees that information submitted by the Claimant pursuant to the
Program will be used and/or disclosed by the Administrator and her designees only for the following
purposes:
1) Processing and evaluating the Claimant's claim;
2) Administering the Program and other Program-related work; and
3) Reports to law enforcement where appropriate.
When documents maintained or submitted by the Estate become part of a Claimant's file for purposes
of the Program, such materials will be reviewed by the Administrator to assist in processing and
evaluating the claim, but will otherwise remain confidential. These files are not available for inspection,
review or copying by the Claimant or her representatives during or after the Program, and all pertinent
settlement privileges and other privileges apply.
To protect the privacy of Claimants participating in the Program, all personal information provided by
the Claimant during this process will be returned or destroyed within one year after the conclusion of
the Program.
Individual Claimants are not bound by any rules of confidentiality. Claimants may, at their sole and
voluntary option, disclose information in their possession regarding their claim, their compensation and
their experience with the Program.
All confidentiality requirements are subject to law, regulation and judicial process.
The Administrator may, on a periodic basis, publish reports regarding the Program's claims processing or
other activities in an effort to provide transparency. Such reports will report on an aggregate level only.
No individual Claimant information will be published or disclosed in a way that compromises Claimant
confidentiality.
7 I Page
EFTA00011034


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00010097.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
04/06/2021 11:28 EDT
Generated By:
Page 1 of 3
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
(Eastern)
Code
Num.
Loc
Loc
P
08/16/2019
vs
23
I
A272
APIS
ON BOARD
LAX
LHR
22:01
P
08/01/2019
vs
24
O
APIS
ON BOARD
LHR
LAX
00:00
P
05/26/2019
DL
574
I
A272
APIS
ON BOARD
LAX
MEX
22:18
P
05/23/2019
DL
573
0
APIS
ON BOARD
MEX
LAX
00:00
P
09/21/2017
VS
23
I
A272
APIS
ON BOARD
LAX
LHR
21:53
P
09/04/2017
VS
8
O
APIS
ON BOARD
LHR
LAX
00:00
P
08/13/2017
AC
556
I
A338
APIS
ON BOARD
LAX
YVR
19:39
P
08/11/2017
AC
557
0
APIS
ON BOARD
YVR
LAX
00:00
P
07/06/2016
NZ
1
I
A273
APIS
ON BOARD
LAX
LHR
22:32
P
07/06/2016
NZ
1
I
APIS
NOT ON
LAX
LHR
00:00
BOARD
P
06/26/2016
NZ
1
I
APIS
NOT ON
LAX
LHR
00:00
BOARD
P
06/05/2016
NZ
2
O
APIS
ON BOARD
LHR
LAX
00:00
P
09/17/2015
NZ
1
I
A273
APIS
ON BOARD
LAX
LHR
23:29
P
08/27/2015
NZ
2
O
APIS
ON BOARD
LHR
LAX
00:00
P
11/30/2014
PR
102
I
A273
APIS
ON BOARD
LAX
MNL
21:47
P
11/21/2014
PR
103
O
APIS
ON BOARD
MNL
LAX
00:00
P
09/19/2014
vs
23
I
A272
APIS
ON BOARD
LAX
LHR
22:52
P
09/06/2011
VS
23
I
A272
APIS
ON BOARD
LAX
LHR
23:20
P
10/04/2010
BA
269
I
A273
APIS
ON BOARD
LAX
LHR
22:57
P
09/21/2010
BA
282
0
APIS
LHR
LAX
00:00
P
09/21/2010
BA
282
0
APIS
LHR
LAX
00:00
P
09/27/2009
vs
7
I
A272
APIS
PASSENGER
LAX
LHR
18:06
For Official Use Only / Law Enforcement Sensitive
SDNY_GM_02753139
CONFIDENTIAL
EFTA00010097

=== Page 2 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS - Person Encounter List
04/06/2021 11:28 EDT
Generated By:
Page 2 of 3
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
(Eastern)
Code
Num.
Loc
Loc
P
05/17/2009
OW
4954
I
A741
AIRLINE
MIA
NAS
12:00
(NOT
API)
P
10/19/2007
MY
310
O
APIS
PASSENGER
STN
LAX
00:00
V
09/19/2007
vs
7
I
A272
AIRLINE
LAX
LHR
18:01
(NOT
API)
P
07/02/2006
vs
23
I
A272
AIRLINE
LAX
LHR
21:42
(NOT
API)
P
04/03/2006
vs
7
I
A272
AIRLINE
LAX
LHR
18:57
(NOT
API)
P
12/06/2005
UA
956
O
APIS
PASSENGER
LHR
JFK
00:00
P
11/27/2005
UA
905
I
A472
APIS
PASSENGER
JFK
LHR
15:50
P
02/29/2004
vs
7
I
A272
AIRLINE
LAX
LHR
21:33
(NOT
API)
Total Number of Records: 30
Legend
Loc
Codes
Value
MEX
MEXICO CITY, JUAREZ INTERNATIONAL
NAS
NASSAU INTL
LAX
LOS ANGELES, CA INTL
YVR
VANCOUVER INTL
MIA
MIAMI INTL, FL
LHR
LONDON / HEATHROW INTL
MNL
MANILA
STN
LONDON, STANSTED
JFK
JOHN F KENNEDY INTL
Doc Type
Codes
Value
P
P - PASSPORT
V
V VISA
Site Code
For Official Use Only / Law Enforcement Sensitive
SDNY_GM_02753140
CONFIDENTIAL
EFTA00010098

=== Page 3 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
04/06/2021 11:28 EDT
Generated By:
Page 3 of 3
Codes
Value
A472
A472 - NEW YORK, JFK AIRPORT, TERM 7
A272
A272 - CBP-LOS ANGELES, LAX TERM 2
A273
A273 - LOS ANGELES, BRADLEY AP LAX
A338
A338 - CBP-VANCOUVER, INTL APT PRE-CL
A741
A741 - CBP-NASSAU, BAHAMAS PRECLEAR
For Official Use Only / Law Enforcement Sensitive
SDNY_GM_02753141
CONFIDENTIAL
EFTA00010099


c1: EFTA00009929
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00009929.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: SHU Photos/Number of Steps
Date: Wed, 18 Sep 2019 14:15:22 +0000
Hey
I know FBI was taking photos of the SHU generally and measuring the number of steps from Epstein's cell to the guard
desk. Do you have those photos and can you provide them to us? Thank you.
Also, let us know if you need a hard drive from us for Thomas' phone.
Thanks.
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00009929


c1: EFTA00010351
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00010351.pdf
c6: pdf
c7: images
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=== Page 1 ===
From:
)"
To:
Subject: RE: documents for Relativity
Date: Mon, 29 Apr 2019 23:30:42 +0000
Importance: Normal
Great - thanks very much.
From:
Sent: Monday, April 29, 2019 11:56
To:
Cc:
is
is
Subject: RE: documents for Relativity
All of the data has been loaded to Relativity and is available for review. Please let me know if there are any questions.
Thank you.
From:
Sent: Wednesday, April 24, 2019 11:36 AM
To:
Cc:
is
is
Subject: RE: documents for Relativity
We've received some additional documents in this same production we'd like to include in the same general subfolder on
Relativity ("BSF second production" under "BSF returns"), please. I'm sending them in a separate folder link so that they
don't mess up your process with the initial results; they're here:
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#2018 SDNYinvestigation\Subpoena
Returns\ Boies Schiller\2019-04-23, Boies Schiller second subpoena response (follow-up)
Please note there are a few things from that folder that do NOT need to be uploaded - the folder titled "!Original Zips"
and the two PDF documents (in the main folder) don't need to go onto Relativity. And I think I neglected to give similar
info for the original folder linked to below ("2019-04-18, Boies Schiller second subpoena response") - in that folder, we do
not need the "!Original Zips" folder or its contents, and do not need the three PDF documents in the main folder to be
uploaded.
As always, please let me know if any questions or issues, and thanks very much.
From:
Sent: Monday, April 22, 2019 15:55
To:
EFTA00010351

=== Page 2 ===
Cc:
is
is
Subject: RE: documents for Relativity
We can keep the folder structure that currently exists. If I have any questions regarding the documents I will let you
know.
Thank you.
From:
Sent: Monday, April 22, 2019 3:51 PM
To:
Cc:
i
is
Subject: RE: documents for Relativity
Following up on the below, and for the same case - US V. Epstein (USAO # 2018R01618) - could we please load the
documents in the following folder into Relativity:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNYinvestigation\Subpoena
Returns\ Boies Schiller\2019-04-18, Boies Schiller second subpoena response
In terms of structure, they can go under the "BSF returns" subfolder (under the folder "Subpoena Returns") under a new
subfolder identified as "BSF second production". And under that, we'd like to keep the same folder structure as exists at
the link. Does that work?
And I don't believe there is DVD information (as in the "BSF first production" documents), but if there is, please let us
know. Please also let me know if any questions or if any other information would be helpful, and if you could let us know
when it's all uploaded?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Thursday, March 28, 2019 11:16
To:
Cc:
is
is
Subject: RE: documents for Relativity
Perfect, thanks very much.
From:
Sent: Thursday, March 28, 2019 09:02
To:
)
EFTA00010352

=== Page 3 ===
Cc:
i
is
Subject: RE: documents for Relativity
Hello
The documents would need to be converted to a different format. I will talk to someone about getting the documents
converted to a different format.
Thank you.
From:
Sent: Wednesday, March 27, 2019 7:15 PM
To:
Cc:
is
i
Subject: RE: documents for Relativity
That's no problem, we don't need those on Relativity. Separately, though will we be able to play those video files *not*
on a DVD? That is, we only have them in electronic format (in the file folders) - I haven't tried to play them, so maybe it's
just as easy as that, but wanted to check if we need to get them processed in some other fashion to be able to view
independently of a DVD player.
thanks,
From:
Sent: Tuesday, March 26, 2019 09:32
To:
Cc:
is
is
Subject: RE: documents for Relativity
Good Morning
I have noticed that some of these documents contain data that appears to be from a DVD. A DVD contains a bunch of
separate files to make everything play on a DVD, but it will not make sense to load DVD information into Relativity. The
following should not be loaded to Relativity:
1.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q*3\lFS09LP\_AMUFM*3\S90B8H*H\B3KTU3*5\2MQV991
I\G6WHHA~F\7EJDCF~7\Interview H. R\VIDEO_TS
2.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q^3\FS09LP\_AMUFM*3\S90B8H*H\B3KTU3*5\2MQV99
I\GWR892~P\60AFYC~X\Interview J. H\VIDEO_TS
3.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q^3\FS09LP\_AMUFM*3\S90B8H*H\B3KTU3~5\2MQV99~
I\GWR892~P\60AFYCX\Interview: S. V\VIDEO_TS
4.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q*3\lFS09L*P\_AMUFM*3\S90B8H*H\B3KTU3*S\2MQV99
EFTA00010353

=== Page 4 ===
I\GYCEJB~B\53V7CE~B\Interview A. D\VIDEO_TS
5.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q^3\FS09LP\_AMUFM*3\S90B8H*H\B3KTU3*5\2MQV99
I\GYCEJB~B\53V7CE~B\Interview A. T\VIDEO_TS
6. \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY
investigation\Subpoena Returns\ Boies Schiller\2019-03-04, Boies Schiller first subpoena response\ SUBPOENA
RESPONSE 004582 (State Disc 1)\2. Walkthrough Video
Please let me know if there are any questions.
Thank you.
From:
Sent: Monday, March 25, 2019 7:00 PM
To:
Cc:
i
is
is
Subject: RE: documents for Relativity
Could we please load the documents in the following folder into Relativity for US V. Epstein (USAO # 2018R01618):
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#2018 SDNYinvestigation\Subpoena
Returns\Boies Schiller\2019-03-04, Boies Schiller first subpoena response
In terms of structure, we'd like to create a folder identified as "Subpoena Returns" (at the same level as "FBI Case File" is
currently), and in a subfolder within Subpoena Returns, a folder titled "BSF returns," and within that a subfolder identified
as "BSF first production" that the docs in the above link can be deposited into (including any additional subfolders). Does
that work?
Please let me know if any questions or if any other information would be helpful, and if you could please let us know
when it's all uploaded?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00010354


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c0:
=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: case records scanning
Date: Mon, 12 Oct 2020 16:51:14 +0000
Embedded: RE:_case_records_scanning.msg
Sender:
Subject: RE: case records scanning
Message-Id:
<CY1P110MB04880D606A267AC23F43F7E2ED070@CY1P110MB0488.NAMP110.PROD.OUTLOOK.CO
M>
To:
Cc:
Cc:
EFTA00013244


c1: EFTA00013532
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00013532.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
"Acosta, Alex (USAFLS)"
Subject: Epstein
Date: Fri, 07 Dec 2007 22:05:56 +0000
Importance: Normal
Hello - Any word? Am I free to send out the victim notification letter? And, is it alright to send copies of the
victim notification letter to Mr. Josefsberg?
Assistant U.S. Attorney
Phone
Fax
EFTA00013532


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c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To: Karas NYSD Chambers
, Bruce Barket
Cc: Aida Leisenring
>, , Michael Bachrach
John Diaz
(USANYS)"
(USANYS)"
>, "Kenneth J. Montgomery Esq"
Subject: RE: Letter regarding jail conditions and court appearance
Date: Tue, 25 Aug 2020 00:05:09 +0000
Attachments: 2020.08.24_letter_to_KMK_re_MCC_conditions.pdf
Dear Judge Karas,
Pursuant to the Court's August 21 order, attached please find the Government's letter.
Respectfully submitted,
Co-Chief, Narcotics Unit
O:
From: Karas NYSD Chambers
Sent: Friday, August 21, 2020 1:22 PM
To: Bruce Barket
Cc: Aida Leisenring
>;
>; ; Michael Bachrach
>;
>; ; John Diaz
is
is
(USANYS)
is
(USANYS)
i
is
(USANYS)
Subject: Re: Letter regarding jail conditions and court appearance
All,
Attached please find a memo endorsement from Judge Karas.
-Chambers of Judge Karas
From: Bruce Barket
Sent: Thursday, August 20, 2020 6:24 PM
To: Karas NYSD Chambers
Subject: FW: Letter regarding jail conditions and court appearance
Good afternoon,
EFTA00010427

=== Page 2 ===
I sent this to
but wanted to forward here as well. Can you confirm that the judge will see it?
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
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: Bruce Barket
Sent: Thursday, August 20, 2020 12:50 PM
To:
@nysd.uscourts.gov'
@nysd.uscourts.gov>
Cc: Aida Leisenring
@barketepstein.com>; tonyricco
in
>; Michael Bachrach
>; Kenneth J. Montgomery Esq
>; 'john diaz
(
)'
i
>;
>;
(USANYS)
>;
(USANYS)
is
(USANYS)
)'
Subject: Letter regarding jail conditions and court appearance
I hope all is well. Can you please bring this letter to the attention of the judge? Note that I copied the lawyer for the MCC
and the prosecution team as well as firewall counsel. Thank you.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
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
EFTA00010428


c1: EFTA00010380
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00010380.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Cc:
Subject: Re: Media Inquiry from
- Daily Mail - Jeffrey Epstein inquiry
Date: Fri, 31 Jul 2020 19:12:03 +0000
FWIW: https://nymag.com/intelligencer/2020/07/jeffrey-epstein-document-release-ghislane-maxwel.html
Sent from my iPhone
On Jul 31, 2020, at 1:16 PM,
)
wrote:
Hi
,
We don't have this document -- it sounds like it's an unsealed filing from a civil suit, and those filings are
voluminous, so we don't know which document that is (we're not tracking the unsealed documents).
Thanks,
Original Message
From:
)
Sent: Friday, July 31, 2020 12:45 PM
To:
i
)
Cc:
Subject: FW: Media Inquiry from
- Daily Mail - Jeffrey Epstein inquiry
Rather than ask this reporter for a copy of the doc (below), would you happen to have it? Main is asking.
Thanks.
Original Message
From:
Sent: Friday, July 31, 2020 12:43 PM
To: Press <Press@jmd.usdoj.gov>; NPO@ic.fbi.gov;
Subject: RE: Media Inquiry from
- Daily Mail - Jeffrey Epstein inquiry
+SDNY team. If you don't have copy of this civil litigation filing reporter is referencing, can you ask reporter
for copy of doc?
Original Message
From: no-reply@usdoj.gov <no-reply@usdoj.gov>
Sent: Friday, July 31, 2020 12:21 PM
To: Press <Press@jmd.usdoj.gov>
Subject: Media Inquiry from
- Daily Mail - Jeffrey Epstein inquiry
EFTA00010380

=== Page 2 ===
Date Friday, July 31, 2020 - 12:21 pm EDT
Name:
Email Address:
Topic: Federal Bureau of Investigation (FBI)
Media Outlet: Daily Mail - Jeffrey Epstein inquiry
Deadline: ASAP
Inquiry:
Hello, I'm a journalist with the Daily mail and am looking to find out if you have any comment on the claim in
newly unsealed court documents that Prince Andrew and Alan Dershowitz put pressure on the DOJ to give
Jeffrey Epstein a favorable plea deal in 2007. The documents were unsealed in a civil case brought by
, an Epstein victim, against Ghislaine Maxwell, his alleged madam. Please email or call me on
EFTA00010381


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c3: VOL00008
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c0:
=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
February 2, 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:
In recognition of the Government's ongoing discovery obligations, today we are producing
the materials listed in the below index. These discovery materials are stamped with control
numbers SDNY_GM_02742303 through SDNY_GM_02742750. One of the items included in
this production is the final report of the Office of Professional Responsibility ("OPR") regarding
the resolution of the 2006-2008 criminal investigation of Jeffrey Epstein by the U.S. Attorney's
Office for the Southern District of Florida (the "OPR Report"). Although the OPR Report is
publicly available and accessible through multiple websites, the Government has elected to
produce a copy to you as a courtesy.
In addition, due to an inadvertent error in Bates stamping in the prior production, which
the Government just discovered, we are reproducing certain of the materials in the below index.
These items were originally produced with incorrect Bates numbers that resulted in overlaps.
These errors have now been corrected. These discovery materials are now stamped with the correct
control numbers SDNY_GM_00328069.001 through SDNY_GM_00328069.794.
EFTA00011267

=== Page 2 ===
Page 2
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case.¹ This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
AT&T subpoena return, January 28,
SDNY GM 02742303
SDNY GM 02742395
2021
Confidential
FBI collected item log regarding
highly confidential responsive
SDNY GM 002742396
SDNY GM 002742398
materials
FBI report regarding review of
SDNY GM 002742399
SDNY GM 002742400
responsive digital evidence
FBI collected item log regarding 10
yearbooks collected from West Palm
SDNY GM 002742401
SDNY GM 002742402
Beach
Office of Professional Responsibility
SDNY GM 002742403
SDNY GM 002742750
report dated November 2020
REPRODUCTION, JPMorgan Chase
SDNY GM 00328069.001
SDNY GM 00328069.794
materials
Confidential
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials or if you wish to arrange a time
to review physical items in the FBI's custody.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
Assistant United States Attorneys
1
Files in PDF format designated as "confidential" under the protective order have been stamped
"confidential." However, certain files cannot be individually labeled as confidential on the
documents themselves due to their file format.
EFTA00011268


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=== Page 1 ===
From:
To:
Subject: Epstein
Date: Fri, 25 Apr 2008 17:45:10 +0000
Importance: Normal
Decision? The victims are applying for social security benefits!!!!
EFTA00013864


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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
November 16, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today the Government is producing additional materials, including Jencks Act and
Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced
case. Enclosed please find an index detailing the materials included in today's production.
The Government is also producing today certain materials relating to individuals the
Government does not currently intend to call as witnesses at trial in the above-referenced case.
These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the
Government does not expect to call these individuals to testify at trial. Instead, these materials
contain, among other things, certain witness statements. Enclosed please find an index detailing
these materials. This production should not be taken to indicate that the Government believes it
has any obligation to provide all of these materials; rather, we make this production as a courtesy.
Moreover, although the Government presently does not intend to call the individuals listed in the
enclosed index, we reserve the right to do so and will notify you should the Government determine
that it intends to call any of these individuals at trial.
EFTA00010162

=== Page 2 ===
Page 2
Please note that this letter, the enclosed index, and the enclosed materials are governed
by the July 31, 2020 Protective Order in this case. In particular, the materials are designated
as "confidential" under the Protective Order. The index is itself designated as "confidential,"
because it includes information regarding records designated as "confidential" under the
Protective Order. The Department of Justice directed this office to cease the dissemination of
materials marked with the word "confidential" in order to avoid potential confusion with markings
reserved for classified documents. Accordingly, in order to note the appropriate designation of
this production under the operative Protective Order in this case, the materials being produced
today are marked with the following label: "SUBJECT TO PROTECTIVE ORDER
PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs
of the Protective Order that govern today's production.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by: s/
Assistant United States Attorneys
EFTA00010163


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
)"
(USANYS)"
)"
Subject: RE: agent communications
Date: Sun, 22 Aug 2021 19:11:42 +0000
Hi all,
Following up on this, can you let me know whether we're on track for this deadline? Apologies for pestering, but we'll
need to make this deadline in order to meet our court-ordered 3500 deadline.
Thanks very much,
From:
Sent: Tuesday, August 10, 2021 6:09 PM
To:
(NY) (FBI)
Cc:
)
is
(USANYS)
Subject: agent communications
Hi
and
and I spoke about this today, but I wanted to recap our conversation in an email so that everyone is on the same
page about what types of communications we'll need you to gather. As we discussed, we would like to receive these
materials no later than September 15th, so that we have enough time to review and process them for 3500 productions.
I'll send around a calendar invitation so that everyone can keep track of the deadline. There are two categories of
materials to gather:
For
and anyone else at C20 or working with C20 (including victim specialists in New York or
elsewhere):
We will need any and all communications with witnesses, or attorneys for witnesses.
This includes all electronic communications, including emails and text messages.
We will need these materials for all witnesses, regardless of whether they are testifying or not, and
regardless of whether they were part of the Maxwell phase of the investigation.
For
and
..
We will need all of their communications, reports, or other writings about the Epstein/Maxwell
investigation, both internal and external.
We will need all forms of electronic communications - documents, emails, text messages, chats/instant
messages, or anything else.
This also includes any type of report or notes (formal or informal) in connection with this case.
Thanks,
EFTA00010614

=== Page 2 ===
Assistant United States Attorney
EFTA00010615


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=== Page 1 ===
From:
To
Cc:
Subject: RE: Epstein
Date: Fri, 09 Nov 2007 15:13:48 +0000
Importance: Normal
Attachments: 071109_Epstein_Article.pdf
Hi
and
:
Here is an article from today's Palm Beach Post. I especially like the part about how the "feds
were overreaching the whole time."
Do you want to do a conference call some time this morning? I have to leave for a sentencing at 12:30 and will
be back in the office at around 3:00.
Thank you.
From:
Sent: Friday, November 09, 2007 9:34 AM
To:
Cc: Acosta,
(USAFLS)
Subject: FW: Epstein
Let me know what you think
From: Jay Lefkowitz [mailto:3Lefkowitz@kirkland.com]
Sent: Thursday. November 08, 2007 6:01 PM
To:
Subject: Epstein
Jeff,
As requested, attached is our response to your November 5 letter.
Regards,
Jay
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
EFTA00013701

=== Page 2 ===
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
EFTA00013702


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=== Page 1 ===
To:
Gibby <Gibby.Cohen@mindspring.com>
From:
"G. Max" <gmax1@mindspring.com>
Subject:
Re:
Too bad, I am already counting on you
Gx
At 12:02 PM 11/6/2001 -0500, you wrote:
Don't count on me - I'm too old to be counted on
Gibby
At 09:37 AM 11/6/01 -0500, you wrote:
I am counting on you
Gx
At 05:41 AM 11/6/2001 -0500, you wrote:
Good Morning
I returned today to find no suggestions in my emails for JE trainer - still looking -
have a few more rocks still to turn over - but not looking too hopeful
Gibby
At 06:05 PM 11/2/01 -0500, you wrote:
Your a star - he wants someone to come to the hse. The instructor has to
be female youngish and attractive otherwise he will loose interest
rapidly. He is looking for someone who can tone, flex and stretch
Thanks -
Your desperately seeking an instructor
PS
If you had to rate the top 10 gyms in the city where would they be + any
masseuses in the same vein as the exercise instructor?
At 05:56 PM 11/2/2001 -0500, you wrote:
Where does he want to train in a facility or someone to
come to the house - does he want a weight training person a
stretcher/dancer type - give me a little more color and
logistics and I'll see what I can do
Gibby
At 05:50 PM 11/2/01 -0500, you wrote:
Gibby I need your help. JE is looking for an
EFTA00011435

=== Page 2 ===
exercise instructor to work out with. He likes,
well you know what he likes. Plse can you call
me or let me know if you know of anyone or if
you can point me to the right direction to go to
a gym where you know I can meet someone
who might do the trick
Thanks
Gx
EFTA00011436


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=== Page 1 ===
From:
To:
@gmail.com>
@usdoj.gov>,
Subject: Final Voucher 10894369(1) approved by
now awaiting further approval
Date: Fri, 10 Jan 2020 13:44:16 +0000
Importance: Normal
Dear
Final voucher 10894369(1) has been approved by
now awaiting further approval.
Trip ID: 10894369
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13261 - U.S. V. Epstein - Witness Interviews
Destination:
S
Dates:
Current status: Pending Voucher Approval
EFTA00010275


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=== Page 1 ===
From:
To:
Subject: RE: Epstein
Date: Sun, 23 Mar 2008 01:41:04 +0000
Importance: Normal
I recommended calling the police as well. I will pass this on to
The DOJ Victim-Witness coordinator is going to call
all the victims on Monday to offer the services of the pro bono lawyers and I will recommend that she add something about
calling the police in case of any further harassment. Thanks.
Original Message
From:
Sent: Saturday March 22 2008 9:36 PM
To:
Cc:
Subject. Epstein
Hi
Can't
give the parents a contact the local PD so they can call the police at a moment's notice and file a police
report? I'm hoping the DC mtgs end soon so we can proceed. My fear is that drawing
nto this will side track that
goal.
Sent from my BlackBerry Wireless Handheld
Original Message
From:
To:
Cc:
Sent: Sat Mar 22 20:51:02 2008
Subject: Epstein
Hi all - So sorry to bother you on a Saturday, but I am hoping that I can persuade you to reach out to
about Epstein's
investigators harassing the girls.
received a frantic call today about Epstein's investigators bothering the parents of
one of the victims. According to the victim, he demanded to see the victim and when he saw her, he told the victim that
they had video of the girl and were planning to put it on the internet. We don't believe that Epstein actually has video of
any of the girls, and
has calmed the girl down, but this activity seems to be getting more aggressive. Remember
also that Epstein is using the state criminal case to subpoena depositions of victims in the federal case (who are not part of
the state indictment) to get information about our investigation. These actions do not seem consistent with what Epstein's
attorneys are supposed to be trying to work out with
in DC. Any chance
will ask Epstein's people to call off
their dogs until he makes his decision?
EFTA00013659


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=== Page 1 ===
From:
(USAFLS)"
To: Roy BLACK
Bcc:
(USAFLS)"
Subject: RE: Jeffrey Epstein
Date: Tue, 12 Aug 2008 16:06:41 +0000
Importance: Normal
Hi Roy -- Can you give me a call? We need to discuss something.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phon
Fax
Original Message
From: Roy BLACK [mailto:
Sent: Monday, August 11, 2008 11:40 PM
To:
(USAFLS)
Subject: Jeffrey Epstein
I have conferred with the lawyers on the team. They all thank you for agreeing to oppose any disclosure of the 9/24/07 agreement.
We firmly believe this document is not discoverable in the civil cases. However if the court rules against you on this we request that you
further ask that any disclosure be subject to a strong protective order prohibiting dissemination to anyone except counsel to the petitioners.
We are particularly concerned because civil lawyers are more apt to publicize something like this than those of us who litigate on the
criminal side of the docket. You may recall one lawyer standing on the bridge to palm beach railing over his misconceptions of the case.
This is the typical vehicle they use to get more plaintiffs. You had also asked what documents were disclosed in the state court. As part of
counsels obligation to fully disclose any promises or inducements which led to the plea agreement, the 9/24/07 agreement was filed with
the court. It was filed under seal. Once again I want to re-assure you that Mr. Epstein and his counsel intend to stand by their agreements. If
you or anyone in the USAO have any concern about a possible breach please call or email me again so we can discuss any dispute or
misunderstanding and allay any concerns. Thanks again. Roy
EFTA00014124


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=== Page 1 ===
From:
To:
Subject: Epstein
Date: Tue, 22 Apr 2008 17:16:46 +0000
Importance: Normal
Did you ever hear from
?
will be gone after the 10th for several weeks.
EFTA00013863


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=== Page 1 ===
From:
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To:
(USAFLS)"
Subject: RE: Epstein
Date: Tue, 27 Nov 2007 20:32:11 +0000
Importance: Normal
I did not copy Josefsberg - I knew I was misspelling his name - drats. Thanks
From:
(USAFLS)
Sent: Tuesday, November 27, 2007 2:07 PM
To:
(USAFLS)
Subject: RE: Epstein
Hi
- You didn't copy Bob on this, did you? It is Josefsberg. Otherwise, great e-mail. I am waiting for a call
back from Barry about the date.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
From:
(USAFLS)
Sent: Tuesday, November 27, 2007 1:55 PM
To: Jay Lefkowitz
Cc: Acosta, Alex (USAFLS)
Subject: Epstein
Jay,
Please accept my apologies for not getting back to you sooner but I was a little under the weather yesterday. I hope that
you enjoyed your Thanksgiving.
Regarding the issue of due diligence concerning Judge Davis' selection, I'd like to make a few observations. First, Guy Lewis
has known for some time that Judge Davis was making reasonable efforts to secure Aaron Podhurst and Bob Josephsberg
for this assignment. In fact, when I told you of Judge Davis's selection during our meeting last Wednesday, November 21ˢᵗ,
you and Professor Dershowitz seemed very comfortable, and certainly not surprised, with the selection. Podhurst and
Josephsberg are no strangers to nearly the entire Epstein defense team including Guy Lewis, Lili Ann Sanchez, Roy Black,
and, apparently, Professor Dershowitz who said he knew Mr. Josephsberg from law school. Second, Podhurst and
Josephsberg have long-standing stellar reputations for their legal acumen and ethics. It's hard for me to imagine how
much more vetting needs to be done.
The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims of the anticipated upcoming
events and their rights associated with the agreement entered into by the United States and Mr. Epstein in a timely
fashion. Tomorrow will make one full week since you were formally notified of the selection. I must insist that the vetting
EFTA00013706

=== Page 2 ===
process come to an end. Therefore, unless you provide me with a good faith objection to Judge Davis's selection by COB
tomorrow, November 28, 2007, I will authorize the notification of the victims. Should you give me the go-ahead on
Podhurst and Josephsberg selection by COB tomorrow, I will simultaneously send you a draft of the letter. I intend to
notify the victims by letter after COB Thursday, November 29th. Thanks,
EFTA00013707


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 10643456-2(1) approved by
now awaiting further
approval
Date: Thu, 24 Oct 2019 20:10:09 +0000
Importance: Normal
Dear
Final voucher 10643456-2(1) has been approved by
now awaiting further approval.
Trip ID: 10643456-2
Voucher ID: 1
Voucher type: Final
Traveler name
Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews
Destination: Santa Monica, CA, United States
Dates: 2019-09-17 - 2019-09-20
Current status: Pending Voucher Approval
Voucher total expenses: 2152.79
Estimated trip cost: 2489.21
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0010
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00010272


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Witness Immunity
Date: Mon, 27 Sep 2021 18:08:43 +0000
Attachments: 2021.09.24_PSEU_Immunity_Form_(flat).pdf.
Hi
,
Thanks very much for reviewing this. I've attached the full application form, which contains this information. If you have
any questions or if a call would be useful, please let me know.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
From:
(CRM)
Sent: Monday, September 27, 2021 2:05 PM
To:
Subject: Witness Immunity
Good afternoon
:
I've been assigned your witness immunity request. Could you please email me the information regarding Ms.
invovlement in the scheme and the information she proffered? I'll turn to your request now. If you
need to reach me, my contact information is below. Thanks.
Policy & Statutory Enforcement Unit
Office of Enforcement Operations
Criminal Division
U.S. Department of Justice
Direct:
DOJ Cell:
Office:
PSEU's Intranet Site - Forms, etc.
EFTA00011432


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=== Page 1 ===
STATEMENT IN SUPPORT OF REGISTRATION OF A UNITED STATES
CIVIL AIRCRAFT IN THE NAME OF A
LIMITED LIABILITY COMPANY.
Accepted CF Mar/31/2017
PLAN D, LLC
=, a limited liability company of a United States Citizen and is eligible to register aircraft
in its name. In this regard, we make to following representations:
I.
The full name of the Applicant LLC is: PLAN D, LLC
=1
II.
The state in which this LLC is lawfully organized is: U.S. VIRGIN ISLANDS
.
III.
The effective date of the LLC is: OCTOBER 19, 2012
#
IV. The name of each of the members of the LLC and the type of entity of each member
(i.e.: individual, corporation, partnership, etc.)
Name
Type of Entity
U.S. Citizenship Verification
Jeffrey E. Epstein
Individual
Y X
N
Y
N
Y
N
Y
N
Additional Members listed on additional pages:
Y
N
V.
This LLC is managed by Managers or Members (Circle One)
VI. The manager(s) or member(s) of this LLC may act independently: Y X N
VII. The name of the Manager of this LLC LAWRENCE VISOSKI
Be
The Manager is a(n) X
individual
corporation
partnership
other
The undersigned certifies that he/she/it understands that an LLC is eligible to register aircraft in its name provided
that:
(1) at least 2/3rds of the managers or managing members are "U.S. Citizens" within the meaning of 49 U.S.C.
Section 40102(a)(15)(C) and:
(2) at least 75% of the voting interest or units is owned or controlled by persons who are "U.S.citizens" or
citizens of one of its possessions; and specifically that AN LLC CANNOT REGISTER AS A NON-CITIZENS
CORPORATION.
If any member of this LLC is not a United States Citizen as defined in 40102(a)(15)(C) an explanation appears below
to support the certification that this LLC is a "U.S. Citizen" as required by 49 U.S.C. Section 40102(a)(15)(C).
The undersigned hereby also certifies that the information given herein is true and correct and meets all citizenship
specifications as required by the Federal Aviation Administration.
PLAN D, LLC
By:
LCC Lawrence Visoski
Its: Manager
EFTA00009952

=== Page 2 ===
EFTA00009953
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2017 MAR 29 A 9:09
OKLAHOMA CITY
OKLAHOMA


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein update
Date: Wed, 19 Mar 2008 18:15:58 +0000
Importance: Normal
Hi
- I am hoping that you have an update from
I wanted to fill you in on recent events.
Yesterday we did the first half of the grand jury presentation on the indictment. Many of the grand jurors
expressed thanks for our return. After a break as I walked into the room, I overheard one juror telling another
that he had been concerned that we were going to "whitewash" this case and not charge it.
Epstein's lawyers are using the civil lawsuits as an excuse to harass a number of the victims. One girl,
to be served with a
subpoena for a deposition. It is scheduled for Monday.
A national crime victims service organization has received a grant from the Justice Department to provide legal
representation to victims. They have agreed to provide counsel for our victims. The only problem is that the
lawyers are located in Maryland. But they will try to find pro bono lawyers here to help out.
I also told
that one of our victims tried to commit suicide last week. The FBI's victim-witness coordinator
is doing her best to get counseling for all of our needy victims, but I just can't stress enough how important it is
for these girls to have a resolution in this case. The "please be patient" answer is really wearing thin, especially
when Epstein's group is still on the attack while we are forced to wait on the sidelines.
Thank you.
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
EFTA00013549


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
(USANYS)"
Subject: RE: Daubert motion
Date: Tue, 09 Nov 2021 03:37:45 +0000
Attachments: Exhibit_B.pdf
Thanks,
I'd been planning to redact the exhibits, but the attached one is somewhat complicated to redact. Do
we think Judge Nathan would let us just file it under seal? If we do, we can docket the whole motion and just submit this
one exhibit under seal.
From
Sent: Monday, November 8, 2021 9:43 PM
To:
Cc:
USANYS)
Subject: RE: Daubert motion
Thanks very much,
I've reviewed and have no substantive edits. There were a few typos, but I gather from the
email chain that multiple proofreads are ongoing, so don't want to clutter your inbox with track changes on those. Agree,
there is no need to redact this filing and agree with your proposed approach to the exhibits.
From:
Sent: Monday, November 8, 2021 7:02 PM
To:
Cc:
(USANYS)
Subject: FW: Daubert motion
Hi
This is the version ready for you, and specifically, Part I.C.4-6.
Also, team, I don't think we need to redact this filing, but we definitely want to redact the defense expert notice and the
attached defense list of material, so I'm inclined to just file these temporarily under seal again. Let me know your
thoughts, and l'll add our customary sealing footnote.
From:
Sent: Monday, November 8, 2021 6:57 PM
To:
Cc:
)
Subject: Daubert motion
Hey
Passing the pen back to you while I'm joining the Rocchio witness prep.
EFTA00009983

=== Page 2 ===
I've inputted the chiefs' comments,
S comments, and the citecheck from
I'll be done with the webex at 10 and
will finalize the exhibit attachments then. So that leaves inputting the intern citecheck from
which I've also
attached, making sure those two articles don't contain any bombs before we file them, and anything else you have the
time or inclination to do.
Thank you again for all your help with this!
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00009984


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=== Page 1 ===
MCC NEW YORK
Monday July 22, 2019
NEW YORK, NY
Page 1
Daily Assignment Roster
6 07:00 - 15:00
9 12:00 - 20:00
Post
Split Shift 2 00:00 - 08:00
3 06:00 14:00
8 08:00 - 16:00
10 14:00 - 22:00
12 16:00 - 00:00
CAPTAIN
CAPTAIN SEC
OPS LT
2
06:00 14:00
ACT LT
3
**10
oT
ADMIN LT
**6
08:30 15:00
SHU LT
**10 <unassigned>
SIS LT
**6
SIS LT #2
6 <unassigned>
SIA
8 <unassigned>
SIS TECH #2
3
PHONE MONITOR
8 <unassigned>
SEC OFFICER #1
3 <unassigned>
SEC OFFICER #2
8
$
TOOL ROOM
**6 <unassigned>
SEARCH OFFICER
8
2
OFF
8
3
OFF
**8 <unassigned>
LOBBY
3
**10
OT
CONTROL #1
**2
8
**12
CT
CONTROL #2
**3
10
(NC)
INTERNAL
2
**8
12
OT
INTERNAL #2
**2 <unassigned>
12
ATTY CONF
**8
**12
OT
UNIT 2
**2
8
**12
OT
CT
UNIT 3
2
8
**12
(NC)
5 NORTH
2
8
**12
5 SOUTH
**2
**8
**12
oT
OT
oT
7 NORTH
**2
**8
**12
OT (NC)
OT
OT (NC)
7 SOUTH
**2
**8
**12
OT 00:00 01:00
(NC)
9 NORTH
**2
12
oT
oT
SHU #1
**2
**8
12
OT (NC)
SHU #2
"2
8
**12
OT (NC)
OT
SHU #3
**3
10
SHU #4
8
**12
OT
19/2020 10:38:28 AM
SDNY_00013446
Page 01
EFTA00009713

=== Page 2 ===
Monday July 22, 2019
Page 2
10 SOUTH #1
10 SOUTH #2
3 <unassigned>
**10
16:00 00:00
REC OFFICER #1
**3 <unassigned>
REC OFFICER #2
**3 <unassigned>
11 NORTH
**2
CT
OT
11 SOUTH
11 SOUTH #2
0
REAR GATE
OSP #1
SANITATION OFF
**2 <unassigned>
VISIT #1
VISIT #2
VISIT #3
****Special Assignments****
EPO OFFICE
8
ESCORT OFF #1
0
ESCORT OFF #2
LOBBY #2
OT (NC) 13:00 20:00
TOWN DRIVER
10
PHONE RM
8 <unassigned>
PHONE RM 2
**8
OSP #1
01 01:00 08:00 01:00
OPS LT
**10
OT 14:00 16:00
****Back Page Categories****
DAY OFF
SICK. I FAVE
ANNUAL LEAVE
19/2020 10:38:31 AM
SDNY_00013447
Page 02
EFTA00009714

=== Page 3 ===
Monday July 22, 2019
Page 3
LWOP
LWOP(M)
AWOL
SUSPENSION
OFFICIAL TIME
COP
IF TRAINING
TIME OFF AWARD
****Change Records****
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
TOOL ROOM
6
[Sick / Annual]
<Unassigned>
KS 7/14 13:31
[Sick / Annual]
[Removed]
KS 7/14 13:54
5 SOUTH
2 <Unassigned>
8 10 SOUTH #1
Y RW 7/15 11:58
Shift
Staff
OT/CT Start End
5 SOUTH
OT
10 SOUTH #1
CONTROL #2
3
Annual Leave
<Unassigned>
KS 7/16 07:54
(sp)PHONE RM
8
3 CONTROL #2
<Unassigned>
KS 7/16 07:54
SHU #1
8
LWOP(M)
<Unassigned>
KS 7/16 09:22
INTERNAL
8
Annual Leave
<Unassigned>
KS 7/16 09:29
[Inserted NCS]
[Sick/Annual]
RW 7/16 11:43
(sp)LOBBY #2
9 <Unassigned>
[Sick / Annual]
RW 7/16 11:43
(sp)LOBBY #2
9
[Time Change]
RW 7/16 11:44
Shift
Staff
OT/CT Start End
LOBBY #2
oT 13:00 20:00
ATTY CONF
8 <Unassigned>
2 UNIT 3
Y RW 7/16 14:37
Shift
Staff
OT/CT Start End
ATTY CONF
oT
UNIT 3
UNIT 2
2 <Unassigned>
12 ATTY CONF
Y RW 7/18 08:34
Shift
Staff
OT/CT Start End
UNIT 2
oT
ATTY CONF
INTERNAL
8 <Unassigned>
2 INTERNAL
Y RW 7/18 10:01
Shift
Staff
OT/CT Start End
INTERNAL
oT
INTERNAL
19/2020 10:38:33 AM
SDNY_00013448
Page 03
EFTA00009715

=== Page 4 ===
Monday July 22, 2019
Page 4
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
SHU LT
10
Sick Leave
<Unassigned>
KS 7/18 10:19
INTERNAL #2
2 <Unassigned>
Annual Leave
Y RW 7/18 11:12
Shift
Staff
OT/CT Start End
INTERNAL #2
CT
Annual Leave
LWOP
8 PHONE RM 2(sp)
KS 7/18 11:35
[Inserted NCS)
[Sick/Annual]
RW 7/19 10:18
SHU #2
2 <Unassigned>
[Sick / Annual]
RW 7/19 10:19
(sp)LOBBY #2
9
[Time Change]
RW 7/19 10:55
Shift
Staff
OT/CT Start End
LOBBY #2
CT 13:00 20:00
[Inserted NCS]
[Sick/Annual]
RW 7/19 12:08
11 NORTH
12
<Unassigned>
[Sick / Annual]
RW 7/19 12:09
OSP #1
2
<Unassigned>
10 LOBBY
Y DM 7/20 21:40
Shift
Staff
OT/CT Start End
OSP #1
oT
LOBBY
5 SOUTH
8 <Unassigned>
12 5 SOUTH
Y KS 7/21 11:33
Shift
Staff
OT/CT Start End
5 SOUTH
oT
5 SOUTH
ACT LT
10 <Unassigned>
3 SHU LT
Y KS 7/21 13:55
Shift
Staff
OT/CT Start End
ACT LT
OT
SHU LT
9 NORTH
2 <Unassigned>
12 10 SOUTH #1
Y MR 7/21 14:58
Shift
Staff
OT/CT Start End
9 NORTH
OT
10 SOUTH #1
11 NORTH
2 <Unassigned>
12 9 NORTH
Y MR 7/21 15:04
Shift
Staff
OT/CT Start End
11 NORTH
OT
9 NORTH
SHU #2
12 <Unassigned>
27 SOUTH
MR 7/21 15:04
SHU #1
8 <Unassigned>
2 SANITATION OFF
MR 7/21 15:06
7 NORTH
2 <Unassigned>
12 UNIT 3
Y MR 7/21 15:54
Shift
Staff
OT/CT Start End
7 NORTH
oT
UNIT 3
7 SOUTH
2 <Unassigned>
12 7 SOUTH
Y MR 7/21 17:26
Shift
Staff
OT/CT Start End
7 SOUTH
OT
7 SOUTH
SHU #1
2 <Unassigned>
12 11 SOUTH #2
Y MR 7/21 17:30
Shift
Staff
OT/CT Start End
SHU #1
oT
11' SOUTH #2
REC OFFICER #2
3
Sick Leave
<Unassigned>
MR 7/21 19:36
CONTROL #1
2
Sick Leave
<Unassigned>
MR 7/21 20:52
19/2020 10:38:33 AM
SDNY_00013449
Page 04
EFTA00009716

=== Page 5 ===
Monday July 22, 2019
Page 5
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
CONTROL #1
2 <Unassigned>
Annual Leave
Y MR 7/21 20:54
Shift
Staff
OT/CT Start End
CONTROL #1
OT
Annual Leave
CONTROL #1
2
[Time Change]
MR 7/21 20:54
Shift
Staff
OT/CT Start End
CONTROL #1
CT
INTERNAL #2
2
[Sick / Annual]
<Unassigned>
MR 7/21 20:54
[Sick / Annual]
[Removed]
MR 7/21 20:54
3
OFF
8
Sick Leave
<Unassigned>
DM 7/21 23:08
OSP #1
2
[Time Change]
DM 7/22 00:47
Shift
Staff
OT/CT Start End
OSP #1
OT 00:00 01:00
(sp)OSP #1
2 <Unassigned>
12 7 SOUTH
Y DM 7/22 00:48
Shift
Staff
OT/CT Start End
OSP #1
oT 01:00 08:00
7 SOUTH
7 SOUTH
2
[Time Change]
DM 7/22 00:48
Shift
Staff
OT/CT Start End
7 SOUTH
OT 00:00 01:00
9 NORTH
8 <Unassigned>
2 11 SOUTH
Y DM 7/22 05:17
Shift
Staff
OT/CT Start End
9 NORTH
OT
11 SOUTH
7 NORTH
8 <Unassigned>
25 NORTH
Y DM 7/22 05:18
Shift
Staff
OT/CT Start End
7 NORTH
oT
5 NORTH.
7 SOUTH
8 <Unassigned>
Day Off
Y DM 7/22 05:22
Shift
Staff
OT/CT Start End
7 SOUTH
OT
Day Off
7 SOUTH
8
[Sick / Annual]
<Unassigned>
DM 7/22 05:22
[Sick / Annual]
[Removed]
DM 7/22 05:22
SHU #3
3 <Unassigned>
3 REC OFFICER #1
JD 7/22 06:11
(sp)ESCORT OFF #1
8
[Time Change]
CM 7/22 07:36
Shift
Staff
OT/CT Start End
ESCORT OFF #1
07:00 15:00
(sp)ESCORT OFF #2
8
[Time Change]
CM 7/22 07:36
Shift
Staff
OT/CT Start End
ESCORT OFF #2
07:00 15:00
CONTROL #1
12 <Unassigned>
12 5 SOUTH
RW 7/22 08:23
VISIT #2
9 <Unassigned>
3 SHU #3
Y RW 7/22 08:28
Shift
Staff
OT/CT Start End
VISIT #2
OT
SHU #3
SHU #4
12 <Unassigned>
6 CAPTAIN SEC
Y RW 7/22 08:30
Shift
Staff
OT/CT Start End
SHU #4
OT
CAPTAIN SEC
11 NORTH
12
[Sick / Annual]
<Unassigned>
RW 7/22 08:31
[Sick / Annual]
[Removed]
RW 7/22 08:31
19/2020 10:38:33 AM
SDNY_00013450
Page 05
EFTA00009717

=== Page 6 ===
Monday July 22, 2019
Page 6
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
ADMIN LT
6
Sick Leave
<Unassigned>
KS 7/22 09:12
ADMIN LT
6 <Unassigned>
Sick Leave
Y KS 7/22 09:12
Shift
Staff
OT/CT Start End
ADMIN LT
08:30 15:00
Sick Leave
07:00 08:30
LOBBY
10
Sick Leave
<Unassigned>
RW 7/22 09:25
5 NORTH
12
Sick Leave
<Unassigned>
CM 7/22 09:55
SHU #4
12
[Sick / Annual]
<Unassigned>
RW 7/22 10:22
[Sick / Annual]
[Removed]
RW 7/22 10:22
LOBBY
10 <Unassigned>
6 CAPTAIN SEC
Y RW 7/22 10:22
Shift
Staff
OT/CT Start End
LOBBY
OT
CAPTAIN SEC
CAPTAIN
6
[Time Change]
RW 7/22 10:23
Shift
Staff
OT/CT Start End
CAPTAIN
06:00 14:00
SHU #4
12 <Unassigned>
8 SHU #2
Y JD 7/22 10:31
Shift
Staff
OT/CT Start End
SHU #4
OT
SHU #2
SHU #2
12
SHU #4 12
[SWAP]
JD 7/22 10:38
Assignment Swap
5 SOUTH
12 <Unassigned>
12 SHU #4
JD 7/22 10:39
7 NORTH
12
Day Off
<Unassigned>
RW 7/22 10:42
[Inserted NCS]
[Sick/Annual]
JD 7/22 10:43
11 NORTH
8 <Unassigned>
[Sick / Annual]
JD 7/22 10:43
[Inserted NCS]
[Sick/Annual]
JD 7/22 10:43
7 SOUTH
8 <Unassigned>
[Sick / Annual]
JD 7/22 10:43
[Inserted NCS]
[Sick/Annual]
JD 7/22 10:53
7 NORTH
12 <Unassigned>
[Sick / Annual]
JD 7/22 10:53
5 NORTH
12 <Unassigned>
8 UNIT 3
Y JD 7/22 11:06
Shift
Staff
OT/CT Start End
5 NORTH
OT
UNIT 3
5 NORTH
12
UNIT 2 12
[SWAP]
JD 7/22 11:06
Assignment Swap
11 NORTH
12 <Unassigned>
8 11 SOUTH
Y JD 7/22 11:08
Shift
Staff
OT/CT Start End
11 NORTH
OT
11 SOUTH
VISIT #2
9
[Time Change]
MR 7/22 11:51
Shift
Staff
OT/CT Start End
VISIT #2
OT 14:00 20:00
SHU #4
12 <Unassigned>
Day Off
Y RW 7/22 12:49
Shift
Staff
OT/CT Start End
SHU #4
OT
Day Off
SIS LT
6 <Unassigned>
Annual Leave
TD 7/22 13:02
10 SOUTH #2
10 <Unassigned>
12 5 SOUTH
MR 7/22 14:11
19/2020 10:38:34 AM
SDNY_00013451
Page 06
EFTA00009718

=== Page 7 ===
Monday July 22, 2019
Page 7
Relieved Officer's
Relieving Officer's
Ret
Post
Splt Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
10 SOUTH #2
10
[Time Change]
MR 7/22 14:12
Shift
Staff
OT/CT Start End
10 SOUTH #2
16:00 00:00
5 SOUTH
12 <Unassigned>
8 SHU #4
Y JD 7/22 14:12
Shift
Staff
OT/CT Start End
5 SOUTH
OT
SHU #4
(sp)OPS LT
10 <Unassigned>
8 OPS LT
Y JD 7/22 15:56
Shift
Staff
OT/CT Start End
OPS LT
OT
14:00
16:00
OPS LT
06:00 14:00
UNIT 2
12
[Time Change]
SJ 7/22 18:39
Shift
Staff
OT/CT
Start
End
UNIT 2
CT
CAPTAIN SEC
6
[Time Change]
SJ 7/22 18:39
Shift
Staff
OT/CT
Start
End
CAPTAIN SEC
06:00 14:00
11 NORTH
2
[Time Change]
KS 7/23 09:24
Shift
Staff
OT/CT
Start
End
11 NORTH
CT
Annual Leave
TIME OFF AWARD
KS 7/23 10:19
(sp)LOBBY #2
9
[Time Change]
KS 8/6 12:59
Shift
Staff
OT/CT Start End
LOBBY #2
OT
13:00
20:00
AWOL
LWOP
KS 8/19 15:34
LWOP
AWOL
KS 8/27 12:48
AWOL
LWOP
KS 8/27 12:48
AWOL
LWOP
CM 9/16 02:55
Sick Leave
LWOP
CM 10/30 09:17
Recapitulation
Morning Watch
6
AM Watch
6
Day Watch
23
PM Watch
5
Evening Watch
12
**Back Page Categories**
Day Off
23
Sick Leave
5
Annual Leave
4
LWOP
4
LWOP(M)
3
AWOL
7
SUSPENSION
1
OFFICIAL TIME
1
COP
2
IF TRAINING
3
TIME OFF AWARD
1
Total Correctional Svcs. Staff: 106
Non Correctional Svcs. Staff: 12
Overtime Occurrences: 24
Comptime Occurrences: 3
Ops Lt. Evening Watch Signature:
19/2020 10:38:34 AM
SDNY_00013452
EFTA00009719

=== Page 8 ===
Monday July 22, 2019
Page 8
Captain's Signature:
19/2020 10:38:34 AM
SDNY_00013453
Page 08
EFTA00009720

=== Page 9 ===
MCC NEW YORK
Tuesday July 23, 2019
NEW YORK, NY
Page 1
Daily Assignment Roster
6 07:00 - 15:00
9 12:00 - 20:00
Post
Split Shift 2 00:00 08:00
3 06:00 - 14:00
8 08:00 - 16:00
10 14:00- 22:00
12 16:00 - 00:00
CAPTAIN
6
CAPTAIN SEC
6
OPS LT
**2
**8
12
ACT LT
3
**10
OT
ADMIN LT
6
$
SHU LT
3
**10 <unassigned>
SIS LT
6 <unassigned>
SIS LT #2
**6
OT 08:00 10:30
SIA
8 <unassigned>
SIS TECH #1
8 <unassigned>
SIS TECH #2
3
PHONE MONITOR
8
$
SEC OFFICER #1
3 <unassigned>
SEC OFFICER #2
8
$
TOOL ROOM
**6 <unassigned>
SEARCH OFFICER
8
2
OFF
8
3
OFF
**8 <unassigned>
LOBBY
3
10
CONTROL #1
2
8
**12
(NC)
CONTROL #2
**3
10
(NC)
INTERNAL
**2
**8
**12
OT (NC) 00:00 01:30
INTERNAL #2
n
**12
CT
ATTY CONF
**8
**12
OT
OT
UNIT 2
2
8
12
UNIT 3
**2
8
12
oT
5 NORTH
**2
**8
**12
OT
OT (NC)
5 SOUTH
**2
**8
12
oT
7 NORTH
**2
8
12
OT
oT
7 SOUTH
2
**8
12
9 NORTH
**2
**8
12
oT
SHU #1
**2
**8
12
OT
SHU
"2
**8
**12
oT
OT
OT (NC)
SHU #3
**3
10
(NC)
SHU #4
**8
**12 <unassigned>
OT
10 SOUTH #1
2
**8
12
19/2020 10:38:45 AM
SDNY_00013454
Page 09
EFTA00009721

=== Page 10 ===
Tuesday July 23, 2019
Page 2
10 SOUTH #2
3 <unassigned>
**10
oT
REC OFFICER #1
3
$
REC OFFICER #2
3
11 NORTH
**2
12
CT
(NC)
11 SOUTH
**2
**8
12
oT
11 SOUTH #2
12
(NC)
REAR GATE
8
OSP #1
2
8
12
SANITATION OFF
2
VISIT #1
9
VISIT #2
**9
OT
VISIT #3
9
****Special Assignments***
EPO OFFICE
8
ESCORT OFF #1
**8
**10
07:30 15:30
OT 15:30 16:00
ESCORT OFF #2
**8
**10
07:30 15:30
oT 15:30 16:00
LOBBY #2
**9
OT (NC)
PHONE RM
8
TOWN DRIVER
10
SUICIDE WATCH
**2
OT (NC) 01:30 08:00
11 NORTH
8
$
CT 08:00 08:45
SHU PROPERTY
**12
OT (NC) 16:00 20:00
****Back Page Categories****
DAY OFF
SICK LEAVE
ANNUAL LEAVE
COMPTIME USED
19/2020 10:38:48 AM
SDNY_00013455
Page 10
EFTA00009722

=== Page 11 ===
Tuesday July 23, 2019
Page 3
LWOP
LWOP(M)
AWOL
SUSPENSION
OFFICIAL TIME
COP
IF TRAINING
TIME OFF AWARD
****Change Records****
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
TOOL ROOM
6
[Sick / Annual]
<Unassigned>
KS 7/14 13:31
[Sick / Annual]
[Removed]
KS 7/14 13:52
CONTROL #2
3
Annual Leave
<Unassigned>
KS 7/16 07:54
(sp)PHONE RM 2
8
3 CONTROL #2
<Unassigned>
KS 7/16 07:54
SHU #1
8
LWOP(M)
<Unassigned>
KS 7/16 09:22
INTERNAL
8
Annual Leave
<Unassigned>
KS 7/16 09:29
INTERNAL
8
<Unassigned>
E
87 SOUTH
KS 7/16 12:07
UNIT 3
2 <Unassigned>
Annual Leave
Y RW 7/17 15:58
Shift
Staff
OT/CT Start End
UNIT 3
OT
Annual Leave
ATTY CONF
8 <Unassigned>
Annual Leave
Y RW 7/18 08:00
Shift
Staff
OT/CT Start End
ATTY CONF
OT
Annual Leave
7 SOUTH
8 <Unassigned>
29 NORTH
Y RW 7/18 10:11
Shift
Staff
OT/CT Start End
7 SOUTH
OT
9 NORTH
SHU LT
10
Sick Leave
<Unassigned>
KS 7/18 10:19
LWOP
8 PHONE RM 2(sp)
KS 7/18 11:35
5 SOUTH
2 <Unassigned>
8 10 SOUTH #1
Y RW 7/18 12:10
Shift
Staff
OT/CT Start End
5 SOUTH
OT
10 SOUTH #1
[Inserted NCS)
[Sick/Annual]
RW 7/19 10:19
19/2020 10:38:49 AM
SDNY_00013456
Page 11
EFTA00009723

=== Page 12 ===
Tuesday July 23, 2019
Page 4
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
INTERNAL
2 <Unassigned>
[Sick / Annual]
RW 7/19 10:19
10 SOUTH #2
10 <Unassigned>
Annual Leave
Y RW 7/19 12:15
Shift
Staff
OT/CT Start End
10 SOUTH #2
OT
Annual Leave
$
ACT LT
10 <Unassigned>
8 OPS LT
Y JD 7/21 14:10
Shift
Staff
OT/CT Start End
ACT LT
OT
OPS LT
SHU #2
2 <Unassigned>
12 SHU #4
Y RW 7/22 08:21
Shift
Staff
OT/CT Start End
SHU #2
OT
SHU #4
VISIT #2
9 <Unassigned>
3 REC OFFICER #1 Y RW 7/22 08:26
Shift
Staff
OT/CT Start End
VISIT #2
OT
REC OFFICER #1
$
VISIT #2
9
$
[Sick / Annual]
<Unassigned>
RW 7/22 08:27
[Sick / Annual]
[Removed]
RW 7/22 08:27
7 NORTH
2 <Unassigned>
12 7 NORTH
Y RW 7/22 08:34
Shift
Staff
OT/CT Start End
7 NORTH
OT
7 NORTH
11 NORTH
2 <Unassigned>
Day Off
Y RW 7/22 08:45
Shift
Staff
OT/CT Start End
11 NORTH
OT
Day Off
(sp)PHONE RM 2
8
Sick Leave
KS 7/22 09:05
SHU #1
2 <Unassigned>
12 SHU #1
Y RW 7/22 09:20
Shift
Staff
OT/CT Start End
SHU #1
OT
SHU #1
[Inserted NCS]
[Sick/Annual]
RW 7/22 09:39
SHU #3
3 <Unassigned>
[Sick / Annual]
RW 7/22 09:39
SHU #4
8 <Unassigned>
2 SANITATION OFF Y RW 7/22 10:04
Shift
Staff
OT/CT Start End
SHU #4
OT
SANITATION OFF
SHU #1
8 <Unassigned>
8 SHU #2
RW 7/22 10:19
SHU #2
8 <Unassigned>
Day Off
Y RW 7/22 10:19
Shift
Staff
OT/CT Start End
SHU #2
oT
Day Off
7 NORTH
2
[Sick / Annual]
<Unassigned>
RW 7/22 10:43
[Sick / Annual]
[Removed]
RW 7/22 10:43
9 NORTH
8 <Unassigned>
2 UNIT 2
Y RW 7/22 11:04
Shift
Staff
OT/CT Start End
9 NORTH
OT
UNIT 2
11 NORTH
8 <Unassigned>
2 11 SOUTH
MR 7/22 14:34
5 NORTH
8 <Unassigned>
25 NORTH
MR 7/22 14:37
19/2020 10:38:50 AM
SDNY_00013457
Page 12
EFTA00009724

=== Page 13 ===
Tuesday July 23, 2019
Page 5
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
INTERNAL #2
2 <Unassigned>
Annual Leave
Y RW 7/22 14:45
Shift
Staff
OT/CT Start End
INTERNAL #2
CT
Annual Leave
7 NORTH
2 <Unassigned>
Day Off
Y RW 7/22 14:58
Shift
Staff
OT/CT Start End
7 NORTH
OT
Day Off
VISIT #2
9 <Unassigned>
3 REC OFFICER #1
Y RW 7/22 15:26
Shift
Staff
OT/CT Start End
VISIT #2
oT
REC OFFICER #1
5 NORTH
2
<Unassigned>
12 UNIT 3
Y MR 7/22 18:12
Shift
Staff
OT/CT Start End
5 NORTH
OT
UNIT 3
11 SOUTH
2
<Unassigned>
12 UNIT 2
Y SJ 7/22 19:21
Shift
Staff
OT/CT Start End
11 SOUTH
OT
UNIT 2
INTERNAL
12
<Unassigned>
12 SHU #4
SJ 7/22 19:22
SHU #2
2
[Sick / Annual]
<Unassigned>
SJ 7/22 21:14
[Sick / Annual]
[Removed]
SJ 7/22 21:14
SHU #2
2
<Unassigned>
12 INTERNAL #2
Y SJ 7/22 21:14
Shift
Staff
OT/CT Start End
SHU #2
OT
INTERNAL #2
5 SOUTH
2
[Sick / Annual]
<Unassigned>
GA 7/22 22:08
[Sick / Annual]
[Removed]
GA 7/22 22:08
5 SOUTH
2 <Unassigned>
12 INTERNAL
Y GA 7/22 22:12
Shift
Staff
OT/CT Start End
5 SOUTH
oT
INTERNAL
[Inserted NCS]
[Sick/Annual]
GA 7/23 04:30
(sp)Suicide Watch
2
<Unassigned>
[Sick / Annual]
GA 7/23 04:31
(sp)Suicide Watch
2
[Time Change]
GA 7/23 04:31
Shift
Staff
OT/CT Start End
Suicide Watch
OT 01:30 08:00
INTERNAL
2
[Time Change]
GA 7/23 04:32
Shift
Staff
OT/CT Start End
INTERNAL
OT
00:00 01:30
11 SOUTH
8
Sick Leave
<Unassigned>
GA 7/23 05:05
7 NORTH
8
<Unassigned>
E
8 INTERNAL
JD 7/23 07:13
INTERNAL
8
<Unassigned>
E
87 NORTH
JD 7/23 07:16
7 NORTH
8 <Unassigned>
29 NORTH
Y JD 7/23 07:17
Shift
Staff
OT/CT Start End
7 NORTH
oT
9 NORTH
7 SOUTH
8
[Sick / Annual]
<Unassigned>
JD 7/23 07:17
[Sick / Annual]
[Removed]
JD 7/23 07:17
7 SOUTH
8 <Unassigned>
E
8 INTERNAL
JD 7/23 07:17
19/2020 10:38:50 AM
SDNY_00013458
Page 13
EFTA00009725

=== Page 14 ===
Tuesday July 23, 2019
Page 6
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
INTERNAL
8
<Unassigned>
$
83
OFF
JD 7/23 07:18
CONTROL #1
12
<Unassigned>
12 ATTY CONF
RW 7/23 08:27
ATTY CONF
12 <Unassigned>
Day Off
Y RW 7/23 08:28
Shift
Staff
OT/CT Start End
ATTY CONF
OT
Day Off
[Inserted NCS]
[Sick/Annual]
JD 7/23 08:31
11 SOUTH
8 <Unassigned>
[Sick / Annual]
JD 7/23 08:31
11 NORTH
8
11 SOUTH
[SWAP]
JD 7/23 08:47
Assignment Swap
SHU #4
12 <Unassigned>
6 CAPTAIN SEC
Y RW 7/23 09:07
Shift
Staff
OT/CT Start End
SHU #4
OT
CAPTAIN SEC
11 NORTH
2
[Time Change]
KS 7/23 09:25
Shift
Staff
OT/CT Start End
11 NORTH
$
CT
5 SOUTH
8 <Unassigned>
IF TRAINING
JD 7/23 09:35
IF TRAINING
0
Sick Leave
JD 7/23 09:36
(sp)11 NORTH
8 <Unassigned>
Day Off
Y JD 7/23 09:52
Shift
Staff
OT/CT Start End
11 NORTH
CT
08:00 08:45
Day Off
$
[Inserted NCS]
[Sick/Annual]
RW 7/23 09:58
(sp)LOBBY #2
9 <Unassigned>
[Sick / Annual]
RW 7/23 09:58
SIS LT #2
6 <Unassigned>
2 OPS LT
Y JD 7/23 09:58
Shift
Staff
OT/CT Start End
SIS LT #2
oT 08:00 10:30
OPS LT
Annual Leave
TIME OFF AWARD
KS 7/23 10:19
SHU #4
12
[Sick / Annual]
<Unassigned>
RW 7/23 10:32
[Sick / Annual]
[Removed]
RW 7/23 10:32
(sp)ESCORT OFF #1
8
[Time Change]
JD 7/23 10:46
Shift
Staff
OT/CT Start End
ESCORT OFF #1
07:30 15:30
(sp)ESCORT OFF #2
8
$
[Time Change]
JD 7/23 10:46
Shift
Staff
OT/CT Start End
ESCORT OFF #2
$
07:30 15:30
[Inserted NCS]
[Sick/Annual]
RW 7/23 11:21
(sp)SHU PROPERTY
12 <Unassigned>
$
[Sick / Annual]
RW 7/23 11:21
(sp)SHU PROPERTY
12
[Time Change]
MR 7/23 11:37
Shift
Staff
OT/CT Start End
SHU PROPERTY
$
OT 16:00 22:00
[Inserted NCS]
[Sick/Annual]
MR 7/23 11:47
SHU #2
12 <Unassigned>
[Sick / Annual]
MR 7/23 11:47
5 NORTH
12
Sick Leave
<Unassigned>
JD 7/23 12:08
[Inserted NCS]
[Sick/Annual]
JD 7/23 12:32
5 NORTH
12 <Unassigned>
[Sick / Annual]
JD 7/23 12:32
19/2020 10:38:50 AM
SDNY_00013459
Page 14
EFTA00009726

=== Page 15 ===
Tuesday July 23, 2019
Page 7
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
(sp)SHU PROPERTY
12
[Time Change)
JD 7/23 18:31
Shift
Staff
OT/CT Start End
SHU PROPERTY
OT
16:00
20:00
(sp)ESCORT OFF #1
10 <Unassigned>
8 ESCORT OFF
Y JD 7/24 07:30
#1(sp)
Shift
Staff
OT/CT
Start
End
ESCORT OFF #1
OT
15:30
16:00
ESCORT OFF #1
07:30
15:30
(sp)ESCORT OFF #2
10 <Unassigned>
8 ESCORT OFF
Y JD 7/24 07:30
#2(sp)
Shift
Staff
OT/CT
Start
End
ESCORT OFF #2
OT
15:30
16:00
ESCORT OFF #2
07:30 15:30
Annual Leave
Comptime Used
TD 8/5 08:03
AWOL
LWOP
KS 8/19 15.34
LWOP
$
AWOL
KS 8/27 12:48
AWOL
LWOP
KS 8/27 12:48
AWOL
$
LWOP
CM 9/16 02:55
Sick Leave
LWOP
CM 10/30 09:17
****Recapitulation****
Morning Watch
8
AM Watch
7
Day Watch
24
PM Watch
5
Evening Watch
14
**Back Page Categories**
Sick Leave
4
Day Off
19
Annual Leave
4
Comptime Used
1
LWOP 4
LWOP(M) 3
AWOL 7
SUSPENSION 1
OFFICIAL TIME
1
COP
2
IF TRAINING
1
TIME OFF AWARD
1
Total Correctional Svcs. Staff: 106
Non Correctional Svcs. Staff: 14
Overtime Occurrences: 25
Comptime Occurrences: 3
Ops Lt. Evening Watch Signature:
Captain's Signature:
19/2020 10:38:51 AM
SDNY_00013460
EFTA00009727

=== Page 16 ===
MCC NEW YORK
Friday August 09, 2019
NEW YORK, NY
Page 1
Daily Assignment Roster
07:00 - 15:00
9 12:00 - 20:00
Post
Split Shift 2 00:00 08:00
3 06:00 - 14:00
08:00 - 16:00
10 14:00 - 22:00
12 16:00 - 00:00
CAPTAIN
6
CAPTAIN SEC
**6
06:00 14:00
OPS LT
2
8
**12
(NC)
ACT LT
**3
**10
oT
OT 16:00 22:00
SHU LT
**3 <unassigned>
SIS LT
**6 <unassigned>
SIS LT #2
6 <unassigned>
SIA
8 <unassigned>
SIS TECH #1
8 <unassigned>
PHONE MONITOR
**8 <unassigned>
SEC OFFICER #1
3 <unassigned>
SEC OFFICER #2
8
$
TOOL ROOM
6 <unassigned>
SEARCH OFFICER
8
2
OFF
**8 <unassigned>
3
OFF
**8
$
LOBBY
**3
**10
OT
CONTROL #1
**2
8
12
OT
CONTROL #2
**3
10
INTERNAL
**2
**8
12
OT
INTERNAL #2
**2
12
OT (NC)
ATTY CONF
**8
12
UNIT 2
**2
**8
12
(NC)
UNIT 3
**2
8
12
5 NORTH
2
**8
12
(NC) 08:00 12:00
5 NORTH
Y
**8
(NC) 12:00 16:00
5 SOUTH
"2
**8
12
OT (NC)
7 NORTH
"2
8
**12
oT
oT (NC)
7 SOUTH
**2
**8
**12
OT
OT (NC)
oT
9 NORTH
"2
$
**8
$
12
oT
SHU #1
**2
8
**12
OT
OT (NC)
SHU #2
"*2
**8
12
OT (NC)
SHU #3
**3
10
SHU #4
8
**12 <unassigned>
06:00 14:00
19/2020 10:39:17 AM
SDNY_00013461
Page 16
EFTA00009728

=== Page 17 ===
Friday August 09, 2019
Page 2
10 SOUTH #1
**2
**8
12
OT
OT
10 SOUTH #2
3 <unassigned>
10
REC OFFICER #1
3 <unassigned>
REC OFFICER #2
**3 <unassigned>
11 NORTH
**2
**8
**12
OT
oT
11 SOUTH
**2
**8
**12
OT
OT (NC)
11 SOUTH #2
**12
REAR GATE
8
OSP #1
2
8
$
**12
$
SANITATION OFF
**2 <unassigned>
VISIT #1
9
$
VISIT #2
**9
oT 14:00 20:00
VISIT #3
9
****Special Assignments****
PHONE RM
8
PHONE RM 2
**8 <unassigned>
EPO OFFICE
**3
07:00 15:00
LOBBY #2
9
ESCORT OFF #1
**8
06:30 14:30
ESCORT OFF #2
**8
06:30 14:30
TNWDVR
**10
OT 14:00 22:00
ESCORT OFF #3
**8
TREATY LT
**2
**10
00:00 04:00
OT 15:00 22:30
TREATY 1
**10
$
OT 16:00 22:30
TREATY 2
**10
OT (NC) 07:30 22:30
DRY CELL
**12
OT 16:00 00:00
TREATY#4
**2
OT (NC) 00:00 04:00
****Back Page Categories****
DAY OFF
$
(NC)
(NC)
(NC)
(NC)
(NC)
$
19/2020 10:39:19 AM
SDNY_00013462
Page 17
EFTA00009729

=== Page 18 ===
Friday August 09, 2019
Page 3
SICK LEAVE
ANNUAL LEAVE
04:00 08:00
$
LWOP
$
LWOP(M)
AWOL
SUSPENSION
OFFICIAL TIME
COP
IF TRAINING
****Change Records****
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
LOBBY
3 <Unassigned>
8 PHONE RM 2(sp)
KS 7/28 13:49
(sp)PHONE RM 2
8
<Unassigned>
8 PHONE RM 3(sp)
KS 7/28 13:49
SHU #1
2
COP
<Unassigned>
KS 8/4 09:39
Day Off
[Sick / Annual]
KS 8/4 11:56
[Sick / Annual]
[Removed]
KS 8/4 12:00
MILITARY LEAVE
12 SHU #1
KS 8/4 12:51
SHU #1
12
Sick Leave
<Unassigned>
KS 8/4 12:52
11 SOUTH
8
COP
<Unassigned>
KS 8/4 12:54
[Inserted NCS]
[Sick/Annual]
RW 8/5 08:33
SHU #2
2 <Unassigned>
[Sick / Annual]
RW 8/5 08:34
INTERNAL
8 <Unassigned>
2 UNIT 3
Y RW 8/5 08:42
Shift
Staff
OT/CT Start End
INTERNAL
OT
UNIT 3
7 SOUTH
2 <Unassigned>
12 OSP #1
Y RW 8/5 08:58
Shift
Staff
OT/CT Start End
7 SOUTH
oT
OSP #1
[Inserted NCS]
[Sick/Annual]
RW 8/5 09:09
INTERNAL #2
2 <Unassigned>
[Sick / Annual]
RW 8/5 09:09
19/2020 10:39:21 AM
SDNY_00013463
Page 18
EFTA00009730

=== Page 19 ===
Friday August 09, 2019
Page 4
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
11 SOUTH
2 <Unassigned>
8 SHU #1
Y RW 8/5 09:40
Shift
Staff
OT/CT Start End
11 SOUTH
OT
SHU #1
[Inserted NCS]
[Sick/Annual]
RW 8/5 09:53
SHU #1
2 <Unassigned>
[Sick / Annual]
RW 8/5 09:53
[Inserted NCS]
[Sick/Annual]
RW 8/5 09:53
SHU #4
12 <Unassigned>
[Sick / Annual]
RW 8/5 09:53
SHU #4
12
[Time Change]
RW 8/5 09:54
Shift
Staff
OT/CT Start End
SHU #4
$
CT
10 SOUTH #1
2 <Unassigned>
12 ATTY CONF
Y RW 8/5 09:59
Shift
Staff
OT/CT Start End
10 SOUTH #1
OT
ATTY CONF
7 SOUTH
12 <Unassigned>
29 NORTH
Y RW 8/5 10:22
Shift
Staff
OT/CT Start End
7 SOUTH
OT
9 NORTH
(sp)ESCORT OFF #2
8 <Unassigned>
2 UNIT 2
Y RW 8/5 11:02
Shift
Staff
OT/CT Start End
ESCORT OFF #2
OT
UNIT 2
10 SOUTH #1
8 <Unassigned>
2 UNIT 2
Y JD 8/6 06:48
Shift
Staff
OT/CT Start End
10 SOUTH #1
OT
UNIT 2
[Sick / Annual]
[Removed]
JD 8/6 06:48
(sp)ESCORT OFF #2
8
[Sick / Annual]
<Unassigned>
JD 8/6 06:48
(sp)ESCORT OFF #2
8
<Unassigned>
Annual Leave
JD 8/6 06:50
3
OFF
8 <Unassigned>
$
8 PHONE MONITOR
JD 8/6 07:07
CONTROL #2
3 <Unassigned>
10 LOBBY
RW 8/6 10:07
SHU #3
3
<Unassigned>
8 SHU #2
RW 8/6 11:40
ACT LT
3
C
Sick Leave
<Unassigned>
KS 8/6 14:12
[Inserted]
[Sick/Annual]
KS 8/6 14:29
[Inserted]
[Sick/Annual]
KS 8/6 14:29
[Inserted]
[Sick/Annual]
KS 8/6 14:29
[Inserted]
[Sick/Annual]
KS 8/6 14:29
[Sick / Annual]
IF TRAINING
KS 8/6 14:32
[Sick / Annual]
IF TRAINING
KS 8/6 14:32
[Sick / Annual]
IF TRAINING
KS 8/6 14:32
[Sick / Annual]
IF TRAINING
KS 8/6 14:33
[Inserted NCS]
[Sick/Annual]
SJ 8/6 20:12
7 SOUTH
8 <Unassigned>
[Sick / Annual]
SJ 8/6 20:12
SANITATION OFF
2
Annual Leave
<Unassigned>
RW 8/7 07:52
7 SOUTH
2
[Sick / Annual]
<Unassigned>
RW 8/7 08:27
[Sick / Annual]
[Removed]
RW 8/7 08:27
7 SOUTH
2 <Unassigned>
2 7 NORTH
RW 8/7 08:27
19/2020 10:39:21 AM
SDNY_00013464
Page 19
EFTA00009731

=== Page 20 ===
Friday August 09, 2019
Page 5
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
7 NORTH
2 <Unassigned>
12 OSP #1
Y RW 8/7 08:27
Shift
Staff
OT/CT Start End
7 NORTH
OT
OSP #1
9 NORTH
8 <Unassigned>
2 INTERNAL
Y RW 8/7 10:06
Shift
Staff
OT/CT Start End
9 NORTH
OT
INTERNAL
LOBBY
10 <Unassigned>
Annual Leave
Y RW 8/7 10:24
Shift
Staff
OT/CT Start End
LOBBY
oT
Annual Leave
$
VISIT #2
9 <Unassigned>
6 CAPTAIN SEC
Y RW 8/7 10:27
Shift
Staff
OT/CT Start End
VISIT #2
OT 14:00 20:00
CAPTAIN SEC
CAPTAIN SEC
6
[Time Change]
RW 8/7 10:28
Shift
Staff
OT/CT Start End
CAPTAIN SEC
06:00 14:00
(sp)TNWDVR
10 <Unassigned>
8 EPO OFFICE(sp) Y RW 8/7 10:29
Shift
Staff
OT/CT Start End
TNWDVR
OT 14:00
EPO OFFICE
West, R$
06:00
(sp)EPO OFFICE
3 <Unassigned>
8 EPO OFFICE(sp)
RW 8/7 10:29
11 NORTH
12 <Unassigned>
2 11 NORTH
Y RW 8/7 11:37
Shift
Staff
OT/CT Start End
11 NORTH
OT
11 NORTH
ACT LT
3 <Unassigned>
Day Off
Y JD 8/7 13:36
Shift
Staff
OT/CT Start End
ACT LT
OT
Day Off
SHU #1
12 <Unassigned>
2 OSP #1
Y RW 8/8 07:12
Shift
Staff
OT/CT Start End
SHU #1
OT
OSP #1
11 SOUTH
8 <Unassigned>
8 UNIT 2
JD 8/8 08:56
[Inserted NCS]
[Sick/Annual]
JD 8/8 08:56
UNIT 2
8 <Unassigned>
[Sick / Annual]
JD 8/8 08:56
CONTROL #1
2
Sick Leave
<Unassigned>
RW 8/8 12:33
CONTROL #1
2 <Unassigned>
Annual Leave
Y RW 8/8 12:37
Shift
Staff
OT/CT Start End
CONTROL #1
oT
Annual Leave
SHU #4
12
[Sick / Annual]
<Unassigned>
JD 8/8 13:36
[Sick / Annual]
[Removed]
JD 8/8 13:36
[Inserted NCS]
[Sick/Annual]
JD 8/8 13:41
SHU #4
12 <Unassigned>
[Sick / Annual]
JD 8/8 13:41
[Inserted NCS]
[Sick/Annual]
DM 8/8 15:34
5 SOUTH
2 <Unassigned>
[Sick / Annual]
DM 8/8 15:34
5 SOUTH
8 <Unassigned>
27 SOUTH
MC 8/8 15:50
19/2020 10:39:21 AM
SDNY_00013465
Page 20
EFTA00009732

=== Page 21 ===
Friday August 09, 2019
Page 6
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
7 SOUTH
2 <Unassigned>
8 11 NORTH
Y DM 8/8 15:54
Shift
Staff
OT/CT Start End
7 SOUTH
oT
11 NORTH
SHU #2
8 <Unassigned>
12 11 SOUTH #2
Y DM 8/8 17:59
Shift
Staff
OT/CT Start End
SHU #2
OT
11 SOUTH #2
[Sick / Annual]
[Removed]
MC 8/8 18:06
INTERNAL #2
2
[Sick / Annual]
<Unassigned>
MC 8/8 18:06
2
OFF
8
Sick Leave
<Unassigned>
MC 8/8 18:23
SHU #1
2
[Sick / Annual]
<Unassigned>
DM 8/8 19:02
[Sick / Annual]
[Removed]
DM 8/8 19:02
[Inserted NCS]
[Sick/Annual]
DM 8/8 19:02
INTERNAL #2
2
<Unassigned>
[Sick / Annual]
DM 8/8 19:02
SHU #1
2
<Unassigned>
12 9 NORTH
Y DM 8/8 19:04
Shift
Staff
OT/CT Start End
SHU #1
OT
9 NORTH
SHU #2
8
[Sick / Annual]
<Unassigned>
CP 8/9 06:53
[Sick / Annual]
[Removed]
CP 8/9 06:53
SHU #2
8
<Unassigned>
8 11 NORTH
CP 8/9 06:54
11 NORTH
8
<Unassigned>
12 11 SOUTH #2
Y CP 8/9 06:55
Shift
Staff
OT/CT Start End
11 NORTH
oT
11 SOUTH #2
SHU #4
8
<Unassigned>
3 REC OFFICER #2
CP 8/9 06:55
SHU #4
8
[Time Change]
CP 8/9 06:55
Shift
Staff
OT/CT Start End
SHU #4
06:00 14:00
5 NORTH
8
Sick Leave
<Unassigned>
CP 8/9 07:15
(sp)ESCORT OFF #1
8
[Time Change]
JD 8/9 07:15
Shift
Staff
OT/CT Start End
ESCORT OFF #1
06:30 14:30
(sp)ESCORT OFF #2
8
[Time Change]
JD 8/9 07:15
Shift
Staff
OT/CT Start End
ESCORT OFF #2
06:30 14:30
(sp)ESCORT OFF #3
8 <Unassigned>
3 CONTROL #2
JD 8/9 07:16
CONTROL #2
3
<Unassigned>
8 PHONE RM 2(sp)
JD 8/9 07:16
[Inserted NCS]
[Sick/Annual]
CP 8/9 07:46
5 NORTH
8 <Unassigned>
[Sick / Annual]
CP 8/9 07:46
SHU LT
3
Sick Leave
<Unassigned>
CP 8/9 07:50
(sp)TNWDVR
10
[Sick / Annual]
<Unassigned>
RW 8/9 08:03
[Sick / Annual]
[Removed]
RW 8/9 08:03
(sp)TNWDVR
10 <Unassigned>
3 SHU #3
Y RW 8/9 08:03
Shift
Staff
OT/CT Start End
TNWDVR
OT
14:00
SHU #3
SIS LT
6
Annual Leave
<Unassigned>
JD 8/9 08:53
19/2020 10:39:22 AM
SDNY_00013466
Page 21
EFTA00009733

=== Page 22 ===
Friday August 09, 2019
Page 7
Relieved Officer's
Relieving Officer's
Ret
Post
Splt Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
OPS LT
12
Sick Leave
<Unassigned>
CP 8/9 08:58
OPS LT
12 <Unassigned>
10 ACT LT
CP 8/9 08:58
ACT LT
10 <Unassigned>
8 ATTY CONF
Y CP 8/9 08:59
Shift
Staff
OT/CT Start End
ACT LT
OT
ATTY CONF
7 NORTH
12
Sick Leave
<Unassigned>
RW 8/9 09:05
(Inserted NCS]
[Sick/Annual]
RW 8/9 09:08
ACT LT
10
[Time Change]
CP 8/9 09:09
Shift
Staff
OT/CT Start End
ACT LT
OT 16:00 22:00
7 NORTH
12 <Unassigned>
[Sick / Annual]
RW 8/9 09:09
(sp)TREATY LT
10 <Unassigned>
3 EPO OFFICE(sp)
Y RW 8/9 09:47
Shift
Staff
OT/CT Start End
TREATY LT
OT
15:00
EPO OFFICE
07:00 15:00
(sp)TREATY 1
10 <Unassigned>
$
83
OFF
Y RW 8/9 09:47
Shift
Staff
OT/CT Start End
TREATY 1
$
OT
3
OFF
$
(sp)TREATY 1
10
$
[Time Change]
RW 8/9 09:48
Shift
Staff
OT/CT Start End
TREATY 1
$
OT
16:00
[Inserted NCS]
[Sick/Annual]
RW 8/9 09:57
(sp)TREATY 2
10 <Unassigned>
[Sick / Annual]
RW 8/9 09:57
SHU #1
12
[Sick / Annual]
<Unassigned>
CP 8/9 10:59
[Sick / Annual]
[Removed]
CP 8/9 10:59
[Inserted NCS]
[Sick/Annual]
CP 8/9 11:12
SHU #1
12 <Unassigned>
[Sick / Annual]
CP 8/9 11:13
[Inserted NCS]
[Sick/Annual]
CP 8/9 11:32
11 SOUTH
12
Sick Leave
[Sick / Annual]
CP 8/9 11:32
SHU #4
12
[Sick / Annual]
<Unassigned>
CP 8/9 13:40
[Sick / Annual]
[Removed]
CP 8/9 13:40
(sp)DRY CELL
12 <Unassigned>
8 11 SOUTH
Y MC 8/9 14:41
Shift
Staff
OT/CT Start End
DRY CELL
OT
16:00
00:00
11 SOUTH
(sp)TREATY LT
10
[Time Change]
RW 8/9 22:45
Shift
Staff
OT/CT Start End
TREATY LT
OT
15:00
22:30
(sp)TREATY 1
10
$
[Time Change]
RW 8/9 22:45
Shift
Staff
OT/CT Start End
TREATY 1
$
OT
16:00
22:30
(sp)TREATY 2
10
[Time Change]
RW 8/9 22:45
Shift
Staff
OT/CT Start End
TREATY 2
OT
07:30 22:30
(sp)TREATY LT
2 <Unassigned>
Day Off
Y TD 8/10 21:02
Shift
Staff
OT/CT Start End
TREATY LT
CT
00:00
03:00
Day Off
19/2020 10:39:22 AM
SDNY_00013467
Page 22
EFTA00009734

=== Page 23 ===
Friday August 09, 2019
Page 8
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
(sp)TREATY LT
2
[Sick / Annual]
<Unassigned>
TD 8/10 21:04
[Sick / Annual]
[Removed]
TD 8/10 21:04
(sp)TREATY LT
2 <Unassigned>
Annual Leave
Y TD 8/10 21:05
Shift
Staff
OT/CT Start End
TREATY LT
oT 00:00 03:00
Annual Leave
[Inserted NCS]
$
[Sick/Annual]
TD 8/10 21:05
(sp)TREATY#4
2
<Unassigned>
[Sick / Annual]
TD 8/10 21:05
(sp)TREATY#4
2
[Time Change]
TD 8/10 21:06
Shift
Staff
OT/CT Start End
TREATY#4
OT 00:00 04:00
(sp)TREATY LT
2
[Time Change]
TD 8/10 21:06
Shift
Staff
OT/CT Start End
TREATY LT
OT 00:00 04:00
[Inserted NCS]
[Sick/Annual]
KS 8/13 08:53
5 NORTH
Y 8
[Sick / Annual]
[Sick / Annual]
KS 8/13 08:53
Shift
Staff
OT/CT Start End
[Sick / Annual]
5 NORTH
08:00 12:00
5 NORTH
8
[Time Change]
KS 8/13 08:54
Shift
Staff
OT/CT Start End
5 NORTH
12:00 16:00
[Sick / Annual]
[Removed]
JD 8/14 06:35
AWOL
$
LWOP
KS 8/19 15:38
[Sick / Annual]
[Removed]
TD 8/19 16:53
(sp)TREATY LT
2
[Sick / Annual]
<Unassigned>
TD 8/19 16:53
(sp)TREATY LT
2
<Unassigned>
Annual Leave
Y TD 8/19 16:53
Shift
Staff
OT/CT Start End
TREATY LT
00:00 04:00
Annual Leave
04:00 08:00
(sp)TNWDVR
10
$
[Time Change]
KS 8/21 10:41
Shift
Staff
OT/CT Start End
TNWDVR
$
OT 14:00 22:00
AWOL
LWOP
KS 8/22 14:27
AWOL
LWOP
KS 8/27 12:49
AWOL
LWOP
CM 9/16 02:23
LWOP
AWOL
CM 9/16 02:58
****Recapitulation****
Morning Watch
9
AM Watch
4
Day Watch
21
PM Watch 6
Evening Watch
13
**Back Page Categories**
Day Off 18
Sick Leave
9
Annual Leave
7
LWOP 3
LWOP(M) 2
AWOL 8
SUSPENSION 1
OFFICIAL TIME
1
19/2020 10:39:23 AM
SDNY_00013468
EFTA00009735

=== Page 24 ===
Friday August 09, 2019
Page 9
COP 4
IF TRAINING 4
Total Correctional Svcs. Staff: 110
Non Correctional Svcs. Staff: 16
Overtime Occurrences: 29
Comptime Occurrences: 0
Ops Lt. Evening Watch Signature:
Captain's Signature:
19/2020 10:39:23 AM
SDNY_00013469
Page 24
EFTA00009736

=== Page 25 ===
MCC NEW YORK
Saturday August 10, 2019
NEW YORK, NY
Page 1
Daily Assignment Roster
6 07:00 - 15:00
9 12:00 - 20:00
Post
Split Shift 2 00:00 08:00
3 06:00 - 14:00
8 08:00 - 16:00
10 14:00 - 22:00
12 16:00 - 00:00
OPS LT
2
**8
**12
ACT LT
**3
$
**10
(NC)
OT
SHU LT
8 <unassigned>
SIS TECH #1
8 <unassigned>
PHONE MONITOR
**8 <unassigned>
SEARCH OFFICER
**8 <unassigned>
LOBBY
**3 <unassigned>
**10
CONTROL #1
**2
**8
12
OT (NC)
(NC)
CONTROL #2
**3
10
OT
(NC)
INTERNAL
**2
$
**8
**12
oT (NC)
oT
INTERNAL #2
**2
12
OT
ATTY CONF
**8 <unassigned>
**12 <unassigned>
UNIT 2
2
**8
**12
(NC)
OT (NC)
UNIT 3
**2
**8
12
OT
5 NORTH
**2
**8
12
$
5 SOUTH
**2
**8
**12
OT (NC)
OT
OT (NC)
7 NORTH
"2
8
**12
OT
OT
OT
7 SOUTH
**2
**8
**12
oT (NC)
oT (NC)
9 NORTH
2
**8
**12
OT
SHU #1
**2
**8
**12
oT
OT
SHU #2
**2
**8
$
**12
OT (NC)
OT
SHU #3
**3
10
OT 08:00 16:00
SHU #4
**8
**12
OT (NC)
10 SOUTH #1
**2
**8
**12
oT
10 SOUTH #2
**3
$
10 <unassigned>
OT (NC) 08:00 14:00
11 NORTH
2
8
12
11 SOUTH
**2
**8
**12
OT
OT
11 SOUTH #2
**12
OT
OSP #1
"2
**8
$
**12
OT
SANITATION OFF
2 <unassigned>
VISIT #1
**8 <unassigned>
VISIT #2
**8 <unassigned>
VISIT #3
**8 <unassigned>
19/2020 10:39:46 AM
SDNY_00013470
Page 25
EFTA00009737

=== Page 26 ===
Saturday August 10, 2019
Page 2
****Special Assignments***
PHONE RM
**8 <unassigned>
STAFF SEARCH
**10 <unassigned>
LOBBY #2
**8
OT (NC)
DRY CELL
**2
**8
OT
ESCORT #1
**8
OT
ESCORT #2
**8
$
CST
**8
$
oT 10:30 17:30
EMERGENCY
**10
OT (NC) 14:00 16:00
SIS LT
**8
**12
CT 08:00 16:00
CT 16:00 00:00
ESCORT #3
**8
OT 08:00 10:00
CAPTAIN
**8
CT 08:00 21:00
CST #2
**8
OT (NC) 10:30 16:30
CST.
**8
CT (NC) 10:30 18:30
****Back Page Categories****
DAY OFF
(NC)
(NC)
$
(NC)
$
$
SICK LEAVE
ANNUAL LEAVE
19/2020 10:39:49 AM
SDNY_00013471
Page 26
EFTA00009738

=== Page 27 ===
Saturday August 10, 2019
Page 3
LWOP
COP
****Change Records****
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
OPS LT
12 <Unassigned>
Annual Leave
SJ 7/30 20:22
OPS LT
8
OPS LT 12
[SWAP]
SJ 7/30 20:22
Assignment Swap
11 SOUTH #2
12
[Sick / Annual]
<Unassigned>
KS 8/4 11:56
[Sick / Annual]
[Removed]
KS 8/4 12:00
9 NORTH
8
Annual Leave
<Unassigned>
SJ 8/4 12:25
[Inserted NCS]
[Sick/Annual]
RW 8/5 08:34
SHU #2
2 <Unassigned>
[Sick / Annual]
RW 8/5 08:34
[Inserted NCS]
[Sick/Annual]
RW 8/5 08:35
INTERNAL
8
<Unassigned>
[Sick / Annual]
RW 8/5 08:36
SHU #3
3 <Unassigned>
2 UNIT 3
Y RW 8/5 08:43
Shift
Staff
OT/CT Start End
SHU #3
OT 08:00 14:00
UNIT 3
CONTROL #2
3 <Unassigned>
Day Off
Y RW 8/5 08:45
Shift
Staff
OT/CT Start End
CONTROL #2
OT
Day Off
VISIT #3
8 <Unassigned>
12 10 SOUTH #1
Y RW 8/5 08:46
Shift
Staff
OT/CT Start End
VISIT #3
OT
10 SOUTH #1
7 SOUTH
2 <Unassigned>
12 OSP #1
Y RW 8/5 08:58
Shift
Staff
OT/CT Start End
7 SOUTH
oT
OSP #1
[Inserted NCS]
[Sick/Annual]
RW 8/5 09:38
5 SOUTH
2 <Unassigned>
[Sick / Annual]
RW 8/5 09:38
[Inserted NCS]
[Sick/Annual]
RW 8/5 09:56
CONTROL #1
2 <Unassigned>
[Sick / Annual]
RW 8/5 09:56
INTERNAL #2
2 <Unassigned>
Day Off
Y RW 8/5 12:48
Shift
Staff
OT/CT Start End
INTERNAL #2
OT
Day Off
[Inserted NCS]
[Sick/Annual]
RW 8/5 12:53
11 SOUTH
2 <Unassigned>
[Sick / Annual]
RW 8/5 12:53
10 SOUTH #1
2 <Unassigned>
8 VISIT #1
Y RW 8/6 12:30
Shift
Staff
OT/CT Start End
10 SOUTH #1
oT
VISIT #1
ACT LT
3
C
Sick Leave
<Unassigned>
KS 8/6 14:12
19/2020 10:39:50 AM
SDNY_00013472
Page 27
EFTA00009739

=== Page 28 ===
Saturday August 10, 2019
Page 4
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous
Status
Shft Changed By
[Inserted]
[Sick/Annual]
KS 8/6 14:29
[Inserted]
[Sick/Annual]
KS 8/6 14:29
[Inserted]
[Sick/Annual]
KS 8/6 14:29
[Inserted]
[Sick/Annual]
KS 8/6 14:29
[Sick / Annual]
Day Off
KS 8/6 14:32
[Sick / Annual]
Day Off
KS 8/6 14:32
[Sick / Annual]
Day Off
KS 8/6 14:32
[Sick / Annual]
Day Off
KS 8/6 14:33
5 SOUTH
12 <Unassigned>
12 11 SOUTH
SJ 8/6 19:27
7 NORTH
12
Annual Leave
<Unassigned>
SJ 8/6 19:27
ACT LT
3 <Unassigned>
10 ACT LT
SJ 8/6 19:29
ACT LT
10 <Unassigned>
8 OPS LT
Y SJ 8/6 19:30
Shift
Staff
OT/CT Start End
ACT LT
OT
OPS LT
[Inserted NCS]
[Sick/Annual]
SJ 8/6 20:14
7 SOUTH
8 <Unassigned>
[Sick / Annual]
SJ 8/6 20:14
[Inserted NCS]
[Sick/Annual]
SJ 8/6 20:15
7 SOUTH
12 <Unassigned>
[Sick / Annual]
SJ 8/6 20:15
7 SOUTH
2
[Sick / Annual]
<Unassigned>
RW 8/7 08:30
[Sick / Annual]
[Removed]
RW 8/7 08:30
7 SOUTH
2 <Unassigned>
27 NORTH
RW 8/7 08:31
7 NORTH
2 <Unassigned>
12 OSP #1
Y RW 8/7 08:31
Shift
Staff
OT/CT Start End
7 NORTH
OT
OSP #1
[Inserted NCS]
[Sick/Annual]
RW 8/7 08:36
VISIT #2
8 <Unassigned>
[Sick / Annual]
RW 8/7 08:36
SHU #2
8 <Unassigned>
2 INTERNAL
Y RW 8/7 10:07
Shift
Staff
OT/CT Start End
SHU #2
oT
INTERNAL
INTERNAL #2
2
[Sick / Annual]
<Unassigned>
RW 8/7 10:26
[Sick / Annual]
[Removed]
RW 8/7 10:26
7 NORTH
12 <Unassigned>
Day Off
Y RW 8/7 12:01
Shift
Staff
OT/CT Start End
7 NORTH
OT
Day Off
[Inserted NCS]
[Sick/Annual]
GA 8/8 02:36
SHU #1
8 <Unassigned>
[Sick / Annual]
GA 8/8 02:36
11 SOUTH
12 <Unassigned>
25 NORTH
Y RW 8/8 07:15
Shift
Staff
OT/CT Start End
11 SOUTH
OT
5 NORTH
INTERNAL
12
D
Annual Leave
<Unassigned>
RW 8/8 11:52
19/2020 10:39:50 AM
SDNY_00013473
Page 28
EFTA00009740

=== Page 29 ===
Saturday August 10, 2019
Page 5
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
INTERNAL #2
2 <Unassigned>
12 UNIT 2
Y JD 8/9 10:22
Shift
Staff
OT/CT Start End
INTERNAL #2
OT
UNIT 2
OSP #1
2
Sick Leave
<Unassigned>
CP 8/9 11:00
(sp)DRY CELL
2 <Unassigned>
8 11 NORTH
Y MC 8/9 16:39
Shift
Staff
OT/CT Start End
DRY CELL
OT
11 NORTH
OSP #1
2 <Unassigned>
12 ATTY CONF
Y MC 8/9 16:59
Shift
Staff
OT/CT Start End
OSP #1
OT
ATTY CONF
SHU #1
2 <Unassigned>
12 SHU #1
Y MC 8/9 17:19
Shift
Staff
OT/CT Start End
SHU #1
oT
SHU #1
11 SOUTH
2
[Sick / Annual]
<Unassigned>
MC 8/9 18:05
[Sick / Annual]
[Removed]
MC 8/9 18:05
11 SOUTH
2 <Unassigned>
12 9 NORTH
Y MC 8/9 18:29
Shift
Staff
OT/CT Start End
11 SOUTH
OT
9 NORTH
(sp)LOBBY #2
8
Sick Leave
<Unassigned>
GA 8/9 22:06
5 SOUTH
8 <Unassigned>
12 11 NORTH
Y GA 8/9 22:09
Shift
Staff
OT/CT Start End
5 SOUTH
OT
11 NORTH
[Inserted NCS]
[Sick/Annual]
GA 8/9 22:28
(sp)LOBBY #2
8 <Unassigned>
[Sick / Annual]
GA 8/9 22:28
LOBBY
3
Sick Leave
<Unassigned>
GA 8/9 22:37
LOBBY
10
Sick Leave
<Unassigned>
GA 8/9 23:18
(sp)PHONE RM
8
Sick Leave
<Unassigned>
GA 8/9 23:46
SEARCH OFFICER
8
Sick Leave
<Unassigned>
GA 8/10 04:54
CONTROL #1
8
Sick Leave
<Unassigned>
GA 8/10 04:54
9 NORTH
8 <Unassigned>
27 SOUTH
Y GA 8/10 04:59
Shift
Staff
OT/CT Start End
9 NORTH
oT
7 SOUTH
OSP #1
8
Sick Leave
<Unassigned>
GA 8/10 05:05
Sick Leave
0
Annual Leave
GA 8/10 05:06
11 SOUTH
8 <Unassigned>
87 NORTH
SJ 8/10 05:32
OSP #1
8
<Unassigned>
$
8 PHONE MONITOR
SJ 8/10 05:53
LOBBY
10 <Unassigned>
10 STAFF
SJ 8/10 05:57
SEARCH(sp)
(sp)DRY CELL
8
<Unassigned>
8 11 SOUTH
SJ 8/10 06:01
11 SOUTH
8 <Unassigned>
8 DRY CELL(sp)
SJ 8/10 06:02
(sp)DRY CELL
8 <Unassigned>
85 NORTH
SJ 8/10 06:02
19/2020 10:39:51 AM
SDNY_00013474
Page 29
EFTA00009741

=== Page 30 ===
Saturday August 10, 2019
Page 6
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
5 NORTH
8 <Unassigned>
25 NORTH
Y SJ 8/10 06:04
Shift
Staff
OT/CT Start End
5 NORTH
OT
5 NORTH
11 SOUTH
12
[Sick / Annual]
<Unassigned>
SJ 8/10 06:04
[Sick / Annual]
[Removed]
SJ 8/10 06:04
LOBBY
3 <Unassigned>
Day Off
Y SJ 8/10 06:07
Shift
Staff
OT/CT Start End
LOBBY
OT
Day Off
SHU #3
3
[Sick / Annual]
<Unassigned>
SJ 8/10 06:17
[Sick / Annual]
[Removed]
SJ 8/10 06:17
CONTROL #2
3
[Sick / Annual]
<Unassigned>
SJ 8/10 06:18
[Sick / Annual]
[Removed]
SJ 8/10 06:18
SHU #3
3
<Unassigned>
[Time Change]
SJ 8/10 06:18
Shift
Staff
OT/CT Start End
SHU #3
<Unassigned>
SEARCH OFFICER
8
<Unassigned>
8 UNIT 2
SJ 8/10 06:20
UNIT 2
8 <Unassigned>
25 NORTH
Y SJ 8/10 06:20
Shift
Staff
OT/CT Start End
UNIT 2
OT
5 NORTH
5 NORTH
8
[Sick / Annual]
<Unassigned>
SJ 8/10 06:20
[Sick / Annual]
[Removed]
SJ 8/10 06:20
5 NORTH
8
<Unassigned>
8 SEARCH OFFICER
SJ 8/10 06:23
CONTROL #1
8
<Unassigned>
8 UNIT 3
SJ 8/10 06:27
UNIT 3
8 <Unassigned>
2 UNIT 3
Y SJ 8/10 06:27
Shift
Staff
OT/CT Start End
UNIT 3
OT
UNIT 3
ACT LT
10
[Sick / Annual]
<Unassigned>
SJ 8/10 06:44
[Sick / Annual]
[Removed]
SJ 8/10 06:44
ACT LT
10 <Unassigned>
3 ACT LT
SJ 8/10 06:44
ACT LT
3 <Unassigned>
$
10 ACT LT
SJ 8/10 08:31
7 NORTH
8 <Unassigned>
25 NORTH
Y SJ 8/10 10:28
Shift
Staff
OT/CT Start End
7 NORTH
OT
5 NORTH
UNIT 2
8
[Sick / Annual]
<Unassigned>
SJ 8/10 10:29
[Sick / Annual]
[Removed]
SJ 8/10 10:29
[Inserted NCS]
[Sick/Annual]
SJ 8/10 10:29
UNIT 2
8 <Unassigned>
[Sick / Annual]
SJ 8/10 10:29
(sp)ESCORT #1
8
<Unassigned>
2 INTERNAL
Y SJ 8/10 10:31
Shift
Staff
OT/CT Start End
ESCORT #1
OT
INTERNAL
(sp)ESCORT #2
8 <Unassigned>
12 SHU #2
Y SJ 8/10 10:31
Shift
Staff
OT/CT Start End
ESCORT #2
OT
SHU #2
$
19/2020 10:39:51 AM
SDNY_00013475
Page 30
EFTA00009742

=== Page 31 ===
Saturday August 10, 2019
Page 7
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
[Inserted NCS]
[Sick/Annual]
SJ 8/10 10:32
SHU #3
3 <Unassigned>
[Sick / Annual]
SJ 8/10 10:32
SHU #3
3
[Time Change]
SJ 8/10 10:33
Shift
Staff
OT/CT Start End
SHU #3
OT 08:00 16:00
SHU #2
8
$
[Sick / Annual]
<Unassigned>
SJ 8/10 10:33
[Sick / Annual]
[Removed]
SJ 8/10 10:33
SHU #2
8 <Unassigned>
8 ATTY CONF
SJ 8/10 10:33
SHU #4
8
<Unassigned>
2 UNIT 3
Y SJ 8/10 10:34
Shift
Staff
OT/CT Start End
SHU #4
oT
UNIT 3
CONTROL #2
3 <Unassigned>
Day Off
Y SJ 8/10 10:34
Shift
Staff
OT/CT Start End
CONTROL #2
oT
Day Off
LOBBY
3
[Sick / Annual]
<Unassigned>
SJ 8/10 10:34
[Sick / Annual]
[Removed]
SJ 8/10 10:34
INTERNAL
8
[Sick / Annual]
<Unassigned>
SJ 8/10 10:35
[Sick / Annual]
[Removed]
SJ 8/10 10:35
[Inserted NCS]
[Sick/Annual]
SJ 8/10 10:36
INTERNAL
8 <Unassigned>
[Sick / Annual]
SJ 8/10 10:37
[Inserted NCS]
[Sick/Annual]
SJ 8/10 10:37
10 SOUTH #2
3 <Unassigned>
[Sick / Annual]
SJ 8/10 10:38
10 SOUTH #2
3
[Time Change]
SJ 8/10 10:38
Shift
Staff
OT/CT Start End
10 SOUTH #2
OT 08:00 14:00
SHU #1
8
[Sick / Annual]
<Unassigned>
SJ 8/10 10:38
[Sick / Annual]
[Removed]
SJ 8/10 10:38
SHU #1
8 <Unassigned>
8 VISIT #1
SJ 8/10 10:38
UNIT 3
8
[Sick / Annual]
<Unassigned>
SJ 8/10 10:39
[Sick / Annual]
[Removed]
SJ 8/10 10:39
UNIT 3
8 <Unassigned>
12 10 SOUTH #1
Y SJ 8/10 10:39
Shift
Staff
OT/CT Start End
UNIT 3
oT
10 SOUTH #1
VISIT #2
8
[Sick / Annual]
<Unassigned>
SJ 8/10 10:40
[Sick / Annual]
[Removed]
SJ 8/10 10:40
VISIT #3
8
[Sick / Annual]
<Unassigned>
SJ 8/10 10:40
[Sick / Annual]
[Removed]
SJ 8/10 10:40
5 SOUTH
12
Sick Leave
<Unassigned>
SJ 8/10 10:41
SHU #1
12
Sick Leave
<Unassigned>
SJ 8/10 10:41
(Inserted NCS]
[Sick/Annual]
MC 8/10 12:20
5 SOUTH
12 <Unassigned>
[Sick / Annual]
MC 8/10 12:20
INTERNAL
12 <Unassigned>
8 SHU #2
Y MC 8/10 12:51
Shift
Staff
OT/CT Start End
INTERNAL
$
oT
SHU #2
$
19/2020 10:39:51 AM
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Page 8
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
(sp)DRY CELL
12 <Unassigned>
8 DRY CELL(sp)
Y MC 8/10 13:00
Shift
Staff
OT/CT Start End
DRY CELL
oT
DRY CELL
SHU #1
12 <Unassigned>
TS
8 CONTROL #1
Y MC 8/10 13:04
Shift
Staff
OT/CT Start End
SHU #1
OT
CONTROL #1
11 SOUTH
12 <Unassigned>
8 10 SOUTH #1
Y MC 8/10 13:05
Shift
Staff
OT/CT Start End
11 SOUTH
oT
10 SOUTH #1
11 SOUTH #2
12 <Unassigned>
8 5 NORTH
Y MC 8/10 13:06
Shift
Staff
OT/CT Start End
11 SOUTH #2
oT
5 NORTH
ACT LT
10 <Unassigned>
8 OPS LT
Y MC 8/10 13:07
Shift
Staff
OT/CT Start End
ACT LT
oT
OPS LT
(sp)ESCORT #2
8
[Sick / Annual]
<Unassigned>
SJ 8/10 13:36
[Sick / Annual]
[Removed]
SJ 8/10 13:36
(sp)ESCORT #2
8 <Unassigned>
12 SHU #2
SJ 8/10 13:36
UNIT 2
12
Sick Leave
8 UNIT 2
Y SJ 8/10 13:39
Shift
Staff
OT/CT Start End
UNIT 2
OT
UNIT 2
[Sick / Annual]
[Removed]
MC 8/10 14:05
SHU #4
8
[Sick / Annual]
<Unassigned>
MC 8/10 14:05
SHU #3
3
[Sick / Annual]
<Unassigned>
MC 8/10 14:05
[Sick / Annual]
[Removed]
MC 8/10 14:05
[Inserted NCS]
[Sick/Annual]
MC 8/10 14:05
SHU #4
8 <Unassigned>
[Sick / Annual]
MC 8/10 14:06
SHU #3
3 <Unassigned>
2 UNIT 3
Y MC 8/10 14:06
Shift
Staff
OT/CT Start End
SHU #3
oT
08:00
16:00
UNIT 3
(sp)CST
8 <Unassigned>
$
Day Off
Y SJ 8/10 14:16
Shift
Staff
OT/CT Start End
CST
$
oT
10:30
Day Off
$
(sp)CST
8 <Unassigned>
$
Day Off
Y SJ 8/10 14:16
Shift
Staff
OT/CT Start End
CST
$
oT
10:30
Day Off
$
(sp)EMERGENCY
10 <Unassigned>
3 ACT LT
Y MC 8/10 14:24
Shift
Staff
OT/CT Start End
EMERGENCY
oT 14:00
ACT LT
(sp)EMERGENCY
10
[Time Change]
MC 8/10 14:24
Shift
Staff
OT/CT Start End
EMERGENCY
OT
14:00
16:00
19/2020 10:39:52 AM
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Page 9
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
SHU #2
12 <Unassigned>
8 DRY CELL(sp)
Y SJ 8/10 15:52
Shift
Staff
OT/CT Start End
SHU #2
OT
DRY CELL
SHU #4
12 <Unassigned>
12 9 NORTH
SJ 8/10 16:15
9 NORTH
12 <Unassigned>
12 ATTY CONF
SJ 8/10 16:17
(sp)DRY CELL
12
[Sick / Annual]
<Unassigned>
SJ 8/10 16:22
[Sick / Annual]
[Removed]
SJ 8/10 16:22
(sp)SIS LT
8 <Unassigned>
Day Off
Y TD 8/10 20:53
Shift
Staff
OT/CT Start End
SIS LT
CT 08:00 16:00
Day Off
(sp)SIS LT
12 <Unassigned>
Day Off
Y TD 8/10 20:54
Shift
Staff
OT/CT Start End
SIS LT
CT 16:00 22:00
Day Off
(sp)CST
8
$
[Time Change]
SJ 8/10 20:59
Shift
Staff
OT/CT Start End
CST
$
OT 10:30 17:30
(sp)ESCORT #3
8 <Unassigned>
Sick Leave
Y SJ 8/10 21:01
Shift
Staff
OT/CT Start End
ESCORT #3
OT
08:00
10:00
Sick Leave
(sp)SIS LT
12
$
[Time Change]
TD 8/10 21:19
Shift
Staff
OT/CT Start End
SIS LT
CT
16:00
23:00
(sp)SIS LT
12
[Time Change]
TD 8/10 23:12
Shift
Staff
OT/CT Start End
SIS LT
CT 16:00 00:00
(sp)Captain
8 <Unassigned>
Day Off
Y JD 8/12 18:42
Shift
Staff
OT/CT Start End
Captain
08:00 21:00
Day Off
(sp)Captain
8
[Time Change]
JD 8/12 18:45
Shift
Staff
OT/CT Start End
Captain
(sp)Captain
8
Day Off
<Unassigned>
JD 8/12 19:54
(sp)CAPTAIN
8 <Unassigned>
Day Off
Y JD 8/12 19:57
Shift
Staff
OT/CT Start End
CAPTAIN
CT 08:00 21:00
Day Off
Sick Leave
LWOP
CM 9/22 08:15
[Inserted NCS]
[Sick/Annual]
MC 10/21 07:45
(sp)CST #2
8 <Unassigned>
[Sick / Annual]
MC 10/21 07:45
(sp)CST #2
8
[Time Change]
MC 10/21 07:45
Shift
Staff
OT/CT Start End
CST #2
oT 10:30 16:30
[Inserted NCS]
[Sick/Annual]
CM 11/10 12:15
(sp)CST.
8 <Unassigned>
[Sick / Annual]
CM 11/10 12:15
(sp)CST.
8
[Time Change]
CM 11/10 12:16
Shift
Staff
OT/CT Start End
CST.
CT 10:30 18:30
19/2020 10:39:52 AM
SDNY_00013478
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EFTA00009745

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Saturday August 10, 2019
Page 10
Recapitulation**
Morning Watch
8
AM Watch
0
Day Watch
11
PM Watch
2
Evening Watch
9
**Back Page Categories**
Day Off
61
Sick Leave
11
Annual Leave
5
LWOP 1
COP
2
Total Correctional Svcs. Staff: 110
Non Correctional Svcs. Staff: 16
Overtime Occurrences: 36
Comptime Occurrences: 4
Ops Lt. Evening Watch Signature:
Captain's Signature:
19/2020 10:39:52 AM
SDNY_00013479
EFTA00009746


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=== Page 1 ===
From:
(USAFLS)"
To:
(USAFLS)"
Cc: "Acosta, Alex (USAFLS)"
Subject: Re: Epstein
Date: Thu, 03 Jul 2008 17:11:33 +0000
Importance: Normal
Thanks
Original Message
From:
(USAFLS)
To:
(USAFLS)
Sent: Thu Jul 03 11:36:42 2008
Subject: Epstein
Hi
- I just got an earful from the last of the victims' lawyers. He is a former Broward County ASA and he represents three victims.
He says that his clients can name many more victims and wanted to know if we can get out of the deal. I told him that, at this time,
assuming that Epstein performs the last piece of the agreement, we are bound. He asked that, if there is the slightest hesitation on Epstein's
part of completing his performance, that he and his clients be allowed to consult with our office before making a decision.
I also couldn't remember if I told you about our meeting with the Sheriff's Office about the jail. Epstein is out at the stockade, not the jail.
Goldberger and some psychiatrist have already met with him and have told him that, if he receives any less favorable treatment than others,
Ken Starr and the whole crew will sue. He also told me that Epstein was "brilliant" and that he has already offered to teach GED classes. I
sort of cocked my head at the "brilliant" comment and said, you know he only has a high school diploma, right? (I used my best, "don't
believe the hype" voice. He was clearly shocked, and I explained that Epstein usually claims to have at least a master's degree, but other
than a few college courses, he had no education above a high school diploma, which I think makes him ineligible to teach a GED course.)
He also told us that Epstein is eligible for work release and will be placed on work release - in direct contradiction to what he told the
agents a few months ago.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
EFTA00014007


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=== Page 1 ===
Exhibit X
EFTA00011177

=== Page 2 ===
The Honourable Alison I Nathan
United States District Court
Southern District of New York
United States Courthouse
Dear Your Honour,
2nd November 2020
R:E: Miss Ghislaine Maxwell - Bail Application
I am sending this character reference in the knowledge that it will be presented to the court at
Ghislaine's bail hearing. The content of this letter is the truth and within my knowledge.
Both
I first met Ghislaine
Ghislaine and her immediate family have been family friends for decades
Following our first encounter we became close
friends and remained in constant touch ever since. We would always speak on her birthday which
falls on Christmas Day.
Ghislaine and I would regularly socialize together and
amongst many other adoring friends and family members. I was
immediately drawn to Ghislaine when I first met her and both her honesty and integrity shone
through from the moment we first met and I was therefore delighted to be asked
adores Ghislaine and it deeply disturbs me that a
country as great as the United States would even think that Ghislaine poses a danger to children or
minors and further to this I would have absolutely no hesitation in allowing Ghislaine to look after
at any time.
Ghislaine is a prominent individual and I believe she will fight these charges to the end. She will not
evade justice and is not in any way a flight risk. She should be granted bail immediately so that she
can form a proper defence to these horrendous charges. She has faced monstrous allegations in the
press that forced her to have to worry about her safety.
I am not being paid or retained to provide this letter. I would however respectfully be prepared to
offer any financial surety that I can afford in order to meet any bail pledge that the court may set. I
await the courts decision and remain on standby should I be asked to fulfil any such commitment.
Yours faithfully
1 of 1
EFTA00011178


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=== Page 1 ===
From:
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To: "Jay Lefkowitz"
Cc:
(USAFLS)"
>, "Acosta, Alex (USAFLS)"
Subject: Epstein - Letter to Judge Davis
Date: Wed, 24 Oct 2007 21:29:36 +0000
Importance: Normal
Attachments: 071015_Special_Master_Letter5.wpd
Jay,
Here is the latest and hopefully final version of the letter to Judge Davis.
EFTA00013622


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10810414-1 approved by
now awaiting further
approval
Date: Thu, 05 Dec 2019 14:39:30 +0000
Importance: Normal
Dear
Travel authorization 10810414-1 has been approved by
now awaiting further approval.
Trip ID: 10810414
Traveler name:
Purpose: R20NYS13179 - U.S. V. Epstein - Witness Interview
Destination: Santa Monica, CA, United States
Dates: 2019-11-13 - 2019-11-15
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.
EFTA00010356


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=== Page 1 ===
From:
To:
Subject: FW: Cite-checked omnibus MOL
Date: Fri, 26 Feb 2021 18:55:16 +0000
Attachments: 2021.02.26_GM_Omnibus_Opposition_to_Defense_Motions.ebd.docx
It will surprise you not at all to learn that, unlike
took this beyond just proofreading and included some
substantive line edits/comments.
would you please take a look at the changes in your sections to confirm you
are ok with them being input into the final version? I'll do the same for my sections.
EFTA00011516

=== Page 2 ===
EFTA00011517


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: RE: Question re emails
Date: Sat, 10 Oct 2020 16:09:51 +0000
Thanks very much.
From:
(USANYS)
Sent: Saturday, October 10, 2020 8:37 AM
To:
)
Cc:
(USANYS)
is
(USANYS)
>;
Subject: Re: Question re emails
Thanks
we agree. First, this goes beyond what we said we would do or told the court we would do. Second, in
any event, we are separately gathering any potentially relevant emails from the agent with victims or witnesses. Third, we
have no reason to believe there were significant gaps in retention or collection for
such that we would expect
that any of his emails with her would be in what we already have.
On Oct 9, 2020, at 9:05 PM,
)
wrote:
Chiefs,
Today, we spoke with SA
one of the original FBI agents from the Florida investigation of Epstein.
told us he has a number of emails with AUSA
regarding the case. Our view is that we do not need to collect
those emails from
because we have already received thousands of
emails, which were collected by OPR
and should encompass any emails with the FBI about the Epstein case.
is going to send us any emails he received
from victims or witnesses. We also discussed other documents
has in his possession from the Epstein
investigation and asked him to send us any that sounded potentially discoverable.
Please let us know if this approach sounds right to you or if you would like to discuss.
Thanks,
EFTA00013243


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=== Page 1 ===
From:
To:
Bcc:
Subject: Epstein
Date: Wed, 18 Jun 2008 16:06:43 +0000
Importance: Normal
Hi guys
and I put in a call to Roy Black this morning. He was "unavailable," so we left a message.
has approved an immunity request for one of the New York victims/recruiters.
is out so we are
going to send it down to you, but I wondered who it should go to first, one of you or
Thanks.
EFTA00013996


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of Florida
500 South Australian Ave., Suite 400
West Palm Beach, FL 33401
(561) 820-8711
Facsimile: (561) 820-8777
August 21, 2008
VIA FACSIMILE AND U.S. MAIL
Michael E. Dutko, Esq.
Bogenschutz & Dutko
600 S. Andrews Ave, Suite 500
Fort Lauderdale, FL 33301-2802
Re: Jeffrey Epstein
: AMENDED NOTIFICATION OF
-
IDENTIFIED VICTIM
Dear Mr. Dutko:
By virtue of this letter, the United States Attorney's Office for the Southern District of
Florida asks that you provide the following amended notice to your client,
Some
of the information contained in the July 20, 2008 letter to Ms.
was inaccurate, so please
advise her of the following changes.
As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter referred to
as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony
solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the
15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and
2008-cf-009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
followed by an additional six months' imprisonment, followed by twelve months of Community
Control 1, with conditions of community confinement imposed by the Court.
In light of the entry of the guilty plea and sentence, the United States has agreed to defer
federal prosecution in favor of this state plea and sentence, subject to certain conditions,
including the following:
1. An independent Special Master was assigned the task of selecting an attorney
representative to represent the victims in connection with civil litigation between
the victims and Mr. Epstein. The Special Master selected Robert Josefsberg, Esq.
of the firm Podhurst Orseck, P.A., a highly-respected and experienced attorney.
Ms.
is not obligated to use Mr. Josefsberg as her civil attorney, but, as
explained in greater detail below, Mr. Josefsberg's services will be provided at no
cost to Ms.
because Mr. Epstein is obligated to pay the costs and fees of the
attorney-representative. Also, Mr. Epstein and his attorneys can only contact Ms.
via Mr. Josefsberg, assuming that she would like Mr. Josefsberg to serve as
her attorney.
2. If Ms.
elects to file suit against Mr. Epstein pursuant to Title 18, United
States Code, Section 2255, Mr. Epstein will not contest the jurisdiction of the
United States District Court for the Southern District of Florida over his person
and/or the subject matter, and Mr. Epstein waives his right to contest liability and
also waives his right to contest damages up to an amount as agreed to between Ms.
and Mr. Epstein, so long as Ms.
elects to proceed exclusively under
18 U.S.C. $ 2255, and she waives any other claim for damages, whether pursuant to
state, federal, or common law. Notwithstanding this waiver, Epstein's agreement
EFTA00013947

=== Page 2 ===
with the United States, his waivers and failure to contest liability and such damages
in any suit are not to be construed as an admission of any criminal or civil liability.
3. As stated above, Mr. Epstein has agreed to pay the fees of the attorney
representative selected by the independent third party. This provision, however,
shall not obligate Epstein to pay the fees and costs of contested litigation filed
against him. Thus, if after consideration of potential settlements, Ms.
and
Mr. Josefsberg elect to file a contested lawsuit pursuant to 18 U.S.C. $ 2255 or she
elects to pursue any other contested remedy, the obligation to pay the costs of the
attorney representative, as opposed to any statutory or other obligations to pay
reasonable attorneys fees and costs such as those contained in Section 2255 to bear
the costs of the attorney representative, shall cease.
Mr. Josefsberg will be contacting you within the next week to explain these terms and to
determine if he may contact Ms.
directly. If you would like to contact Mr. Josefsberg
directly, he can be reached at
If Ms.
has selected other counsel to represent her, or if she does so in the future,
and she decides to pursue a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that
he be contacted at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400,
West Palm Beach, FL 33401.
In addition, a judge has ordered that the United States make available to any designated
victim (and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United
States, so long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a
Protective Order entered by the Court. If Ms.
would like to review the Agreement,
please let me know, and I will forward a copy of the Protective Order for her signature.
As I stated in my earlier notification, please understand that neither the U.S. Attorney's
Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil
litigation, but we again thank you and your client for all of her assistance during the course of
this investigation.
UNITED STATES ATTORNEY
By:
ASSISTANT U.S. ATTORNEY
cc: Robert Josefsberg, Esq.
Jack Goldberger, Esq.
EFTA00013948


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=== Page 1 ===
From:
To:
Subject: Meet re Epstein
Date: Thu, 25 Apr 2019 13:24:08 +0000
Importance: Normal
Attachments: unnamed
EFTA00013352


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=== Page 1 ===
From:
To:
Bcc:
Subject: Emailing: Conf Plea Negotiations final.wpd
Date: Mon, 02 Jun 2008 16:46:33 +0000
Importance: Normal
Attachments: Conf_Plea_Negotiations_final.wpd
Conf Plea Negotiations final.wpd>
Hi
Here it is. It was presented at the July 31st meeting, I believe.
The message is ready to be sent with the following file or link attachments:
Conf Plea Negotiations final.wpd
Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your
e-mail security settings to determine how attachments are handled.
EFTA00013887


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=== Page 1 ===
LAW OFFICES OF
GERALD B. LEFCOURT, P.C.
A PROFESSIONAL CORPORATION
148 EAST 78TH STREET
NEW YORK, NEW YORK 10021
GERALD B. LEFCOURT
TELEPHONE
lefcourt@lefcourtlaw.com
(212) 737-0400
FACSIMILE
(212) 988-6192
SHERYL E. REICH
reich@lefcourtlaw.com
RENATO C. STABILE
stabile@lefcourtlaw.com
FAITH A. FRIEDMAN
frledman@lefcourtlaw.com
May 22, 2007
VIA E-MAIL
Deputy Chief, Northern Region
Office of the United States Attorney
Southern District of Florida
500 South Australian Avenue, Suite 400
West Palm Beach, Florida 33401
Jeffrey Epstein
Dear Mr.
I write as counsel to Jeffrey Epstein, the subject of a grand jury investigation being
conducted by your office.
I understand from you that in the next month or two a decision will be made by your
office whether to seek an indictment of Mr. Epstein. This will confirm that, prior to any such
decision being made, I and other attorneys on behalf of Mr. Epstein will be given an opportunity
to meet with you.
Additionally, because we believe that any decision to indict requires both a complex legal
analysis in a detailed factual context and resolution of significant policy concerns, if our meeting
does not resolve the matter, we would like an opportunity to make a presentation first to
Chief of the Criminal Division, and
First Assistant United States
,
Attorney, and then, again, if no resolution is reached, the opportunity to meet with United States
EFTA00013733

=== Page 2 ===
LAW OFFICES OF
GERALD B. LEFCOURT, P.C.
Deputy Chief, Northern Region
Office of the United States Attorney
Southern District of Florida
May 22, 2007
Page 2
Attorney Alexander Acosta.
Thank you for your cooperation in this matter. If you have any questions, please do not
hesitate to call.
Very truly yours,
Serald Lefesurt
Gerald B. Lefcourt
cc:
EFTA00013734


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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From:
Date: November 14, 2021
Re:
United States V. Ghislaine Maxwell
Court Docket No:
20 Cr. 330 (AJN)
USAO No:
2018R01618
Witness Name:
Witness DOB:
(Name/DOB as printed here will be forwarded to travel agency and then to TSA and must
exactly match the witness's driver's license or other travel ID or TSA will not permit the
witness to fly.)
Witness Address:
Witness TelNos (mobile):
Witness e-mail:
Witness Needed to Appear in SDNY on
Date: December 8, 2021
Time: 12 p.m.
Witness Needed to Appear for:
Trial ( )
Date:
Grand Jury ( )
Date:
Trial/GJ Prep (X)
Date: December 9 and 10, 2021
Estimated Dates Witness will Arrive: December 8, 2021
Depart: December 10, 2021
Is the person a Fact Witness and not an Expert Witness?
(Yes/No): Yes
Current Federal Civilian or Military Employee?
(Yes/No): No
Is the Witness Facing Criminal Charges?
(Yes/No): No
Does the Witness Reside Outside the Continental United States?
(Yes/No): No
Is this Witness a Victim-Witness?
(Yes/No): No
Hotel Required?
(Yes/No): Yes
Has the Witness advised you of any unusual travel expenses?
(Yes/No): No
Unusual expenses of fact witnesses can include
special travel arrangements
care for dependent child or incapacitated family member left at home
rev. 2019.11.19
EFTA00010150

=== Page 2 ===
kennel fees for pets
necessary travel companion
extra baggage (more than one bag)
Please describe the unusual expense:
For Victim-Witness Coordinator:
1. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW
is apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should
be used.
For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to
court/GJ testimony.
Witnesses may only be brought in under the FEWS appropriation for grand jury testimony that
has been scheduled and where the witness is expected to testify before the grand jury; court
testimony; or preparation for same. Any other witness travel, e.g., for investigative interviews,
must be covered by the investigating component from litigative funds. See
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
EFTA00010151


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
)"
)"
Subject
Date: Sat, 09 Oct 2021 19:14:55 +0000
Attachments: 2020.06.20_20.23_RE_Epstein_search_warrant_documents_(151).pdf;
2020.08.04_18.03_RE_EXTERNAL_EMAIL_-_RE_Epstein_Evidence_status_(94).pdf;
2020.10.09_19.05_Epstein_HDs.pdf; 2020.10.09_21.03_Bronx_evidence_-
pulling_evidence_pdf
As
and I previewed, here are a few email exchanges with
Thanks
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00013424


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=== Page 1 ===
From:
To: Edward Friedland
)"
Cc: Joseph Pecorino
>, Matthew Rogers
Subject: RE: Maxwell Link
Date: Mon, 29 Nov 2021 18:10:49 +0000
Inline-Images: image001.jpg
Thanks. We'll roll it out.
From: Edward Friedland
Sent: Monday, November 29, 2021 1:07 PM
To:
is
Cc: Joseph Pecorino
>; Matthew Rogers
is
>;
Subject: Re: Maxwell Link
Good with me.
Thanks.
Sent from my BlackBerry - the most secure mobile device
From:
Sent: November 29, 2021 1:05 PM
To:
Cc:
Subject: RE: Maxwell Link
CAUTION - EXTERNAL:
Joe, Ed, here's what we're ready to post, unless you have any correction:
November 29, 2021
Victim Attendance at Trial in United States V. Ghislaine Maxwell
In orders dated October 14 and November 24, 2021, the S.D.N.Y. Court outlined procedures for public access to the trial in
this matter. (Trial began on November 29, 2021, with jury selection.) Specifically, consistent with the District's COVID-19
protocols, the Court will ensure public access (with COVID-19 distancing) to the trial in the courtroom itself and in
several overflow rooms at the courthouse with live feeds of the proceedings. Beyond the live feeds within the
courthouse, the trial will not be further broadcast; nor will there be any telephonic dial-in to the proceedings. Victim
access will be coordinated by the U.S. Attorney's Office Victim-Witness Coordinator,
), and Mr. Joseph Pecorino of the Court's District Executive Office
). Victims who wish to attend the trial may contact either one of those persons
for further information.
EFTA00010943

=== Page 2 ===
COVID-19 Protocols. Per the S.D.N.Y. Response to COVID-19, anyone who appears at any S.D.N.Y. courthouse must
complete a questionnaire on the date of the proceeding prior to entering the courthouse. All visitors must also have their
temperature taken when they arrive at the courthouse. Only persons who meet the entry requirements established by the
questionnaire and whose temperatures are below 100.4 degrees will be allowed to enter the courthouse. All visitors must
wear a mask that covers the person's nose and mouth. Bandannas, gaiters, and masks with valves are not permitted. If a
person does not have an approved mask, a screener will provide one. Anyone who fails to comply with the COVID-19
protocols that have been adopted by the Court will be required to leave the courthouse. There are no exceptions. For more
information, please see https://www.nysd.uscourts.gov/covid-19-coronavirus.
From: Edward Friedland
Sent: Monday, November 29, 2021 12:01 PM
To:
is
Cc: Joseph Pecorino
>; Matthew Rogers
Subject: FW: Maxwell Link
This info on your web page is outdated and is causing the public to try and access the Maxwell matter by phone. Can you
pull down the access number info and update with the latest order which says in-person?
Edward A. Friedland, Esq.
District Court Executive
United States District Court
Southern District of New York
From: Joseph Pecorino
Sent: Monday, November 29, 2021 11:57 AM
To: Edward Friedland
Subject: Maxwell Link
https://www.justice.gov/usao-sdny/united-states-v-ghislaine-maxwel
UNTED STATES DISTRICT COURT
Joseph Pecorino
Office of the District Executive
United States District Court
Southern District of New York
Email:
NEWYORK
Office:
to
PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
EFTA00010944


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=== Page 1 ===
Exhibit D
EFTA00010008

=== Page 2 ===
Epstein donations
C.O.U.O. Foundation. Inc $17000.00 Single Donation 04/09/2003
2002-2003 Annual Fund
Received
4/9/2003
C.O.U.Q. Foundation Inc
Jesse Philos Foundation $50000.00 Single Donation 06/24/1999
1999-2000 Annual Fund
Received
6/24/1999
Jesse Philips Foundation
Jesse Philips Foundation $22900.00 Single Donation 07/29/1998
1998-1999 Annual Fund
Received
7/29/1998
Jesse Phillps Foundation
Jesse Phillos Foundation $7100.00 Single Donation 07/29/1998
1998-1999 Annual Fund
Received
7/29/1998
Jesse Philips Foundation
Jesse Phillps Foundation $20000.00 Single Donation 07/29/1998
1998-1999 Annual Fund
Received
7/29/1998
Jesse Philips Foundation
Philips Foundation $5000.00 Single Donation 09/04/1997
1997-1998 Annual Fund
Received
9/4/1997
Philips Foundation
Phillps Foundation $5000.00 Single Donation 09/04/1997
1997-1998 Annual Fund
Received
9/4/1997
PhRos Foundation
Philips Foundation $40000.00 Single Denation 09/04/1997
1997-1998 Annual Fund
Received
9/4/1997
Philips Foundation
Waxner Foundation $185000.00 Single Donation 07/25/1994
Capital Projects
Received
7/25/1994
Wexner Foundation
Jeffrey Epstein $15000.00 Single Donation 11/12/1993
Capital Projects
Received
11/12/1993
Jeffrey Enstein Household
Jeffrey Epstein $12000.00 Single Donation 07/20/1993
1993-1994 Annual Fund
Received
7/20/1993
Jeffrey Epstein Household
Jeffrey Epstein $10000.00 Single Donation 05/19/1993
1992-1993 Annual Fund
Received
5/19/1993
Jeffrey Eastein Household
Jeffrey Epstein $1000.00 Single Donation 05/22/1992
Conversion Campaign
Received
5/22/1992
Jeffrey Eastein Household
Jeffrey Epstein $1658.50 Single Denation 04/27/1992
Conversion Campaign
Received
4/27/1992
Jeffrey Enstein Household
Jeffrey Epstein $3000.00 Single Donation 04/01/1992
Conversion Campaign
Received
4/1/1992
Jeffrey Epstein Household
Jeffrey Epstein $1000.00 Single Donation 04/23/1991
Conversion Campaign
Received
4/23/1991
Jeffrey Eostem Household
Juliery Epstein $2646.98 Single Donation 11/16/1990
Conversion Campaign
Received
11/16/1990
Jeffrey Epstein Household
Jeffrey Epstein $500.00 Single Donation 10/31/1990
Conversion Campaign
Received
10/31/1990
Jeffrey Eostein Household
Jeffrey Epstain $1700.00 Single Donation 10/12/1990
Conversion Campaign
Received
10/12/1990
Jeffrey Epstein Household
Infirey Epstain $300.00 Single Donation 09/26/1990
Conversion Campaign
Received
9/26/1990
Jeffrey Enstein Household
Jeffroy Epstain $1000.00 Single Donation 09/26/1990
Conversion Campaign
Received
9/26/1990
Jeffrey Enstein Household
Jeffrey Epstein $10.00 Single Donation 05/04/1980
Conversion Campaign
Received
5/4/1990
Jeffrey Epstein Household
EFTA00010009


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=== Page 1 ===
From: "Acosta, Alex (USAFLS)"
To:
(USAFLS)"
(USAFLS)"
Cc:
(USAFLS)"
Subject: Re: Letter from Brad Edwards
Date: Sat, 02 Aug 2008 16:23:34 +0000
Importance: Normal
As I recall, we also believed that contacting the victims would compromise them as potential witnesses. Epstein argued very forcefully
that they were doing this for the money, and we did not want to discuss liability with them, which was key part of agree.
Original Message
From:
(USAFLS)
To:
(USAFLS)
Cc: Acosta, Alex (USAFLS);
(USAFLS)
Sent: Fri Aug 01 20:18:55 2008
Subject: Letter from Brad Edwards
This is the latest letter from Brad Edwards. They are willing to agree that there are no charges against Epstein in federal court, and he
entered pleas of guilty in state court and is incarcerated in Palm Beach County. However, they ask us to also agree to two facts regarding
the deferral of prosecution agreement and the reason why the victims were not consulted.
As to the reasons why the victims were not consulted, the confidentiality provision would not seem to be the reason for not consulting,
since there was no "agreement" until Epstein and our office reached agreement in September 2007. The confidentiality provision was
not binding until there was an actual agreement. My understanding is that the victims were not consulted (with the exception of the FBI
agents meeting with
in September 2007), because we did not believe the Crime Victims Rights Act applied.
They also still want a free transcript and any FBI 302's prepared for the meeting with
I intend to call Edwards on Monday and tell him we cannot produce the agreement due to the confidentiality provision (and not due to a
lack of courtesy on our part). I will then ask if he still wants to meet. I will be back from Columbia on Thursday, so I can meet with
them on Thursday or Friday. Are you available on those dates
?
Thanks.
<<edwards-ltr2.pdf>>
EFTA00014116


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=== Page 1 ===
Event: Hearing on Epstein Motn to Stay (AMV)
Start Date: 2009-06-12 14:00:00 +0000
End Date: 2009-06-12 16:00:00 +0000
Organizer:
Location: J. Marra
Class: X-PERSONAL
Date Created: 2015-04-04 00:21:58 +0000
Date Modified: 2015-07-22 20:34:55 +0000
Priority: 5
EFTA00013489


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=== Page 1 ===
From:
To:
Subject: RE: Letter re Epstein work release
Date: Wed, 10 Dec 2008 14:58:47 +0000
Importance: Normal
is here, I gave her an extra copy for the Col. She is going to wait to hear from you. Thx
Original Message
From:
Sent: Wednesday, December 10, 2008 9:58 AM
To:
Subject: Re: Letter re Epstein work release
No. His can go out. Those are different letters. Thx
Original Message
From:
To:
Sent: Wed Dec 10 09:25:16 2008
Subject: RE: Letter re Epstein work release
Mr. Josefsberg's letters are in the FedEx bin, wait?
Original Message
From:
Sent: Wednesday, December 10, 2008 9:19 AM
To:
Cc:
Subject: Letter re Epstein work release
Hi guys. Any comments on the Epstein work release letter?
is all ready to hand deliver it. Thanks.
EFTA00014032


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=== Page 1 ===
From:
(USANYS)"
To: "Berman, Geoffrey (USANYS)"
Bec:
(USANYS)"
Subject: Re:
Date: Thu, 21 May 2020 09:46:03 +0000
Yes. I've asked
> On May 20, 2020, at 9:32 PM, Berman, Geoffrey (USANYS)
wrote:
>
> Can we schedule Epstein property meeting for Friday? It's pretty light.
EFTA00013458


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=== Page 1 ===
From:
)"
To:
Cc:
)"
Subject: Re: Epstein
Date: Thu, 25 Apr 2019 01:17:05 +0000
Importance: Normal
10 works for both of us, thanks.
Sent from my iPhone
>
On Apr 24, 2019, at 9:15 PM,
wrote:
V
>
Okay, sounds good - glad to hear it went well. Would 930 or 10 work?
>
>
Sent from my iPhone
V
On Apr 24, 2019, at 9:13 PM,
)
wrote:
Sorry, just realized how late it is. The update is it went well, and we covered a lot of ground. We are happy to
brief you tomorrow if there's a time that works for you.
Sent from my iPhone
On Apr 24, 2019, at 9:10 PM,
)
wrote:
Thanks- we are leaving now and will call momentarily.
Sent from my iPhone
On Apr 24, 2019, at 6:54 PM,
wrote:
Good luck this evening - hope it is going well. Please give us at least a brief update when you finish.
Sent from my iPhone
EFTA00013276


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=== Page 1 ===
From:
Subject: Notes from 2020.11.19 Call with Sternheim, Everdell, and Cohen
Date: Thu, 19 Nov 2020 19:33:56 +0000
2020.11.19 Call with
Cohen: two things want to discuss; recent developments related to conditions in MDC; renewed bail application
planning to make
Sternheim: recent conditions are that yesterday she was whisked out of area she spends the day in; she asked what
was going on; said they were giving her a test; she wanted to speak to her lawyers before the test; she was told if
she did not take the test, she would be put in SHU for 21 days; if she did take the test, would be in SHU for 14
days; then given 2 COVID tests; appears that staff near her had COVID/was coughing; heard other guard say heard
that has COVID; she is in her isolation cell; every time open hatch, they spray it so chemicals are in her area; big
issue is that they repeatedly search her (strip search, wand); after search, get up close and personal and look in
her mouth (invitation to infection);
o When got her laptop today, it was out of power, had to wait for power cord; environment where can't work;
has to balance pad
0 Only reason would get sick it's because of BOP staff; my understanding is that rigid conditions under which
detained (and haven't seen ever before, not even Tartaglione) - if that's because of Epstein, she will get
sick on BOP's watch, will create another nightmare for the Government
0 Never had clients for terrorism, violence, murder treated the way GM is treated
Cohen: over 100 years of experience in this district collectively; never seen anything like this before; would like to
see you in person ideally next week or at least by Zoom
o Want to walk you through the renewed bail application have spent 3.5 months putting substantial work
into; believe it addresses concerns Government raised at the hearing and in submissions; believe it
addresses concerns raised by the Court
o Would need same level of confidentiality described in the protective order (financial information; personal,
private information; suretor information); want to make sure covered by protective order
0 Related request is that when we file, which we feel we have to do soon, if GM remains in, it will likely be the
first of many calls in light of current COVID situation; would need to file under seal and would like your
consent as well
O Show real evidence of threats to her and family members and those close to her
: really appreciate you coming to us with concerns about conditions of confinement and opening dialogue about
bail application; in terms of bail application, we are happy to listen and take a look at what you have, will go in
with an open mind, but can't at this stage preview or predict what our position will be. In terms of how to treat
information you share with us on Monday and sealing, would have to run up the chain; would prefer to do by
video
: able to tell us about what kinds of activities or dissemination concerns you have;
Cohen: if thought covered by PO, not sure that covered by PO; asking to have things treated as if designated
confidential under the order
Everdell: in order to describe what our proposed bail package is, going to have discuss info that is confidential and
sensitive, including for potential co-signers; includes their properties, financial information
Cohen: understand that everything needs to be made known to gov't, pretrial, and court, but beyond that
: want us to treat any information provided to us as if marked confidential under PO?
EFTA00011142

=== Page 2 ===
Everdell: could only use for purposes of bail application; would not publicly disseminate or disclose; would only be
shared with prosecution team; individuals looking to come forward are nervous b/c of notoriety of the case; want
to give comfort that what telling at meeting will be treated confidentiality and won't be disclosed
: in evaluating potential bail application, for financial information, might contact bank or vet that information;
sometimes take steps to vet cosigners as well; would restrictions prohibit us from doing that
Everdell: for purposes of meeting, want to describe potential co-signers and what security of bond would look like
and discuss certain financial information (most financial information are things already in discovery itself, so some
of materials already marked confidential); understand will need to vet co-signers
Cohen: keep confidential for Monday's purposes and then to extent team needs to vet people, we can work through
that
:
in terms of conditions of confinement, still trying to understand everything that has happened in last 24
hours;
0 Understand that one of staff members on detail who works in area where client is housed tested positive for
COVID; understand that everyone who works in that area was sent home to quarantine; rapid test came
back negative; sending lab test out; will need to stay in quarantine for 14 days, will test out; during that
time she needs to stay in isolation cell; was not aware that searching her the way you described while in
quarantine; will reach out to MDC and discuss balancing need for security with disease
0 Understanding is she will still have 3 hours a day to make legal calls; have made request to MDC legal that is
going up to warden that she be able to review laptop for 13 hours that she was supposed to be in the day
room; will inquire about a writing surface, whether possible to put something into her cell to make review
of discovery more practical or move her to somewhere with that kind of furniture; understand that
temperate is ; understand no issues with moistness
Sternheim: anytime anything is given to her, open hatch; every time it is opened and closed it is sprayed; chemical of
spray goes into the room where there is no other ventilation; she also has no hot water, soap; not able to self-
protect under the conditions
:
will focus on the conditions while she will be in quarantine
Sternheim: legal calls being done in close proximity to people who are watching her; I could hear people when I was
on call with them; was told notetaking was occurring; she is in between 1 to 4 feet distance from these people
: will follow up
Everdell: CD that sent with most recent production, can't review that on laptop
:
if want us to load hard drive with just that, can do that; or wait until have hard drive loaded
Everdell: will get back to you
: concerns that expressed before quarantine are mostly on level of searches and surveillance
Sternheim: she is practically in solitary confinement; when I visit her, there are at least 3 people watching us with a
camera; I have asked what camera is for; they say it is not recording; then why is it always set up and moved when
they moved us; degree of invasiveness of attorney-client relationship which have not experienced before; she
doesn't even have a regular toothbrush; it's one inch
Cohen: have had same experience with camera; when allowed to see her, not allowed to pass her documents
: have had multiple conversations with MDC about that
Sternheim: in most recent visit, was able to hand her something to look at; have put us in a room that's very tight;
never seen anything like this
: client has more access to discovery and more time to review discovery than any other inmate; more time for
calls as well
Sternheim: that may be true; however, whatever is being done to her to prevent what had happened to Epstein, she
is being worn down; mentally healthy person; her hair is falling out
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00011143

=== Page 3 ===
Te
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=== Page 1 ===
From:
To:
Subject: FW: Aircraft info
Date: Mon, 04 Oct 2021 19:56:46 +0000
Attachments: SIMPLE_FLIGHT_PLANS_N331JE_(2010-2020).xlsx;
SIMPLE_FLIGHT_PLANS_N491GM_(2000-2009).xlsx;
SIMPLE_FLIGHT_PLANS_N491GM_(2010-2020).xlsx;
SIMPLE_FLIGHT_PLANS_N722JE_(2010-2014).xlsx;
SIMPLE_FLIGHT_PLANS_N722JE_(2015-2020).xlsx
From:
(FAA)
Sent: Tuesday, January 28, 2020 12:05 PM
To:
(NY) (FBI)
Cc:
;
(NY) (FBI)
Subject: RE: Aircraft info
I am sending some of the Flight Plan information that you requested. This information pertains to the helicopters that we
discussed, including N491GM (for which we are still uncertain on the exact dates of ownership.) I hope that there is some
useful information in here. Hopefully, you have someone who is good with Excel. That's the best way to be able to analyze
or quickly find the information you might be looking for.
I have included a few notes here to help you understand the information, but if you have questions, you can give me a
call.
The first thing you are probably going to wonder about are the dates which are part of the Dept Time, Dest Time columns,
but also system tracking dates (more easily understandable) all the way to the right. You'll eventually notice that the
earliest information on this batch of information is from 2007. It was around that time that we started keeping these
records.
The Airport Codes are the ICAO codes. The easiest way to figure out the departure and destination is to either google the
airport identifier or use the list at this site: https://en.wikipedia.org/wiki/ICAO_airport_code
All airports in the continental US begin with the ICAO code K. So if you see a three letter code, it is likely in the US, and
would be prefaced with "K" in the ICAO code. For example, BOS (Boston Logan International Airport is KBOS). JFK is KJFK.
All times (DEPT TIME, DEST TIME, ETA) are in Universal Coordinated Time (UTC) which we use in aviation. The format in
these columns is: CDDTTTT. "C" is an internal code, "DD" is the day, and "TTTT" is the time, UTC, in 24-hour format.
DEPT DOM and DEST DOM reflect whether the Departure or Destination locations are Domestic. This should provide
some context for the airport codes, but I left that in, since international flights should have (are required to file) eAPIS
information, and these columns might make it easier for you to find those flights.
The FIX column isn't likely to be very helpful, but it refers to navigational fixes. It could provide additional clues to
understanding where the flight went, but your best bet is to focus on the Dept and Dest. FIX has some very specific
scenarios where it may be useful, but generally speaking it isn't worth a lot of time and energy, since the dept./dest. and
times and dates are more relevant. The same is true with the ROUTE column.
EFTA00010702

=== Page 2 ===
The MSG TYPE corresponds to the following Codes:
ARR - Arrival
AM
Amendment
CHG Change
CNL Cancel
DEP Departure
DFP Defense Flight Plan (DVFR)
DM
Departure
FP
Flight Plan
FPL
Flight Plan
LCM Lockheed Message (normally that a callsign received a verbal briefing)
UZ
Border crossing
Hopefully you will all be able to find some decent leads or solidify some of your timelines of interest based on the
information provided.
V/r,
Special Agent
Law Enforcement Assistance Program (LEAP)
Federal Aviation Administration,
Office:
Cell:
From:
(FAA)
Sent: Tuesday, January 14, 2020 11:26 AM
To:
(NY) (FBI)
Cc:
;
(NY) (FBI)
Subject: RE: Aircraft info
Please call when you get this information.
I have attached Registration information for N331JE and N722JE. N722JE is the entire aircraft registration file. N331JE is
just the section that appeared to contain all relevant information to your case. I can give you the entire file if you think
there is more that might be applicable, and certified copies of the entire files can be obtained if they need to be used in
court. In my experience, sending the entire aircraft registration file from the start usually is daunting for the investigators,
and leads to tons of questions just trying to figure out what might be relevant. Sometimes aircraft files are 300 pages or
more, and that can be frustrating when maybe only 20 were relevant to the SUBJECT.
I have also attached the LLC Documents for Hyperion Air LLC which is the registered owner for both N331JE and N722JE.
I have attached the Airman File for the SUBJECT, which is encrypted due to PII. I will send the password in a follow-on e-
mail. I looked at the medical file, but I believe the information contained therein has limited value to your investigation. I
have created a separate encrypted document with only the information that may be helpful, so that you can evaluate
potentially relevant information while maintaining medical privacy. If the information in the airman file or the document I
created turns out to be critical evidence for your case, then certified copies of the airman and/or medical file can be
obtained at a later date.
As I mentioned previously, I want to clarify some details regarding the helicopters. What I found appeared to be slightly
different from what was included in the original e-mail to me below.
EFTA00010703

=== Page 3 ===
N722JE
nicknamed Air Ghislaine 2
Helicopter
Sikorsky S-76C
Aircraft Serial Number: 760750
Date Current Registration issued: 17 July 2019
Current Registered Owner: Hyperion Air LLC
Current Registration Signed By:
Aircraft Purchased from: ASI Wings LLC
Date of Purchase: 13 June 2019
Seller Signature: James D. Clark
Special Registration Number Issued on: Paperwork not properly submitted by requestor
Requested Special Registration Number: N162AE
Date Requested Special Registration Number: 16 September 2011 (one year authorization)
Bill of Sale: 18 July 2011
Aircraft Purchased by ASI Wings, LLC from: Freedom Air International, Inc
Aircraft Registered by: Freedom Air International, Inc
Registration of Aircraft on 02 August 2010 Signed By: Darren K. Indyke
Name Change To: Shmitka Air Inc
Name Change From: Air Ghislaine Inc
Date of Registered Owner Name Change: 11 February 2010
Requested Special Registration Number: N722JE
Special Registration Number Issued on: 10 March 2010
Date Requested Special Registration Number: 11 February 2010
Aircraft Registered by: Air Ghislaine, Inc.
Registration of Aircraft on 29 December 2008 Signed By:
Aircraft Purchased from Sikorsky on: 30 December 2008
Aircraft Assigned Registration Number: N750A
N331JE
Helicopter
Bell 430
Aircraft Serial Number: 49078
Date Current Registration issued: 19 November 2019
Current Registered Owner: Hyperion Air, LLC
Current Registration Signed By:
Aircraft Purchased from: Hyperion Air, Inc.
Date of Purchase: 12 August 2013
Seller Signature: Darren K. Indyke
Special Registration Number Placed on Aircraft: 25 June 2012
Requested Special Registration Number: N331JE
EFTA00010704

=== Page 4 ===
Special Registration Number Issued on: 04 June 2012
Date Requested Special Registration Number: 22 May 2012
Aircraft Purchased from: Bovale Developments, Inc.
Date of Purchase: 06 March 2012
Seller Signature: William P. Merriam Jr
Aircraft Registration Number: N901RL
N491GM
Helicopter
Bell 407
I have not yet been able to identify the serial number for N491GM which should lead to the registration documents. If you
know who the aircraft was sold to, or what registration number it currently uses, I would be able to obtain those
documents.
Finally, does this surname have any relevance to your case (potential pilot of one of the aircraft)? VAN HEURCK
V/r,
Law Enforcement Assistance Program (LEAP)
Federal Aviation Administration,
Office:
Cell:
From:
(NY) (FBI)
Sent: Friday, December 6, 2019 1:18 PM
To:
(FAA)
Cc:
(
is
(NY) (FBI)
Subject: Aircraft info
Hi
It was nice talking with you yesterday. Thanks for your assistance with this. Please see the below email of aircraft
information.
Below are the aircrafts we believe Maxwell has/had been using. The helicopter we know that she personally piloted, while
the jets we know her to be a passenger. You'll notice some of the aircrafts will be associated with Jeffrey Epstein, as she
traveled with him frequently. Any information you are able to provide would be helpful. If there is additional passenger
manifests for each of these aircrafts we'd like to know that as well. I know we discussed that sometimes that's not
available. As you can imagine, this case is high profile, so I appreciate any discretion you can make on your part.
Please let me know if I left something out that would be able to assist you in any way.
Thanks again,
Special Agent
FBI New York
Child Exploitation/Human Trafficking
C:
O:
EFTA00010705

=== Page 5 ===
From:
(NY) (FBI)
Sent: Friday, December 06, 2019 1:02 PM
To:
(NY) (FBI)
is
Subject: Aircraft info
Hello!
Below is the info for the helicopters and the private jet.
Name: Ghislaine Noelle Maxwell
Certificate: Private Pilot
Date of Issue: 10/2/2007
Helicopter: Rotorcraft
Sikorsky S-76C; nicknamed Air Ghislaine 2
Likely Serial Number: 760750
States certificate was issued on 7/17/2019
Helicopter Info:
Tail Number: N722JE
Type: 2008 Keystone Helicopter S-76C
Prior Registration: Freedom Air International Inc,
Wilmington, DE
Old Tail Number: N331JE
Serial Number: 49078
States certificate was issued on 9/6/2013
2nd Helicopter:
Bell Jet Ranger
Tail Number: N491GM
Nicknamed: Air Ghislaine 1
Private Jet:
Tail Number: N212JE
Serial Number: 5173
Type: GV SP (G550) Fixed Wing Multi Engine
Certificate Issued: 3/31/2017
Tail Number: N120JE
Serial Number: 1085
Type: G-IV Fixed Wing Multi Engine
Certificate Issued: 5/30/2013
Tail Number: N909JE
Serial Number: 151
Type: G1159B
Certificate Issued: 11/18/2013
Tail Number: N908JE
Serial Number: 20115
Type: Boeing 727-31
Certificate Issued: 1/25/2001
Let me know if you need anything else,
EFTA00010706


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Date: Thu, 31 Dec 2020 15:33:39 +0000
Attachments: 2020.12.31_Best_Decl_re_Rivera_and_Maxwell_(v.3).docx;
2020.12.31_Letter_on_Rivera_and_Maxwell_discovery_and_counsel_access_(v.2).
I didn't line edit this but I did catch a few typos and had one substantive question.
From:
(USANYS)
Sent: Wednesday, December 30, 2020 5:29 PM
To:
(USANYS)
is
(USANYS)
is
)
>;
(USANYS)
is
)
Cc:
(USANYS)
is
(USANYS)
^
is
(USANYS) 1
is
(USANYS)
is
(USANYS)
Subject: FW: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Hey everyone: Here's the latest draft of our letter and declaration on this issue. We are still
confirming a few things, but they shouldn't impact the substance of the Maxwell discussion. There is
also a chance that there's a separate declaration from the MDC; if there is, it should contain the same
substance re: Maxwell that's in the attached draft.
Our response is due tomorrow. I'm generally around later this evening or tomorrow if there's
anything you'd like to discuss.
Thanks very much.
From:
(USANYS)
Sent: Wednesday, December 30, 2020 2:40 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
)
is
)
i
(USANYS)
^
Cc:
(USANYS)
is
(USANYS)
^
is
(USANYS)
is
(USANYS)
^
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
:
We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to
explain that the discovery and counsel access accommodations that have been provided to Maxwell
and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of
their lawyers, and their individual housing circumstances. On all of these factors, there are several
important differences, including:
EFTA00013329

=== Page 2 ===
-
The Maxwell case has multiple times more discovery than the Rivera case. Hence, the need for
such expanded discovery access is greater in the Maxwell case.
-
At the MDC, Maxwell has a unique housing situation, as she is in protective custody outside the
general population. She therefore has sole access to a room to use a computer and phone for
approximately 13 hours a day. Rivera, by contrast, is housed in the general population.
-
There are approximately 80 other inmates at the MCC in Rivera's unit that use the same VTC
room for court appearances, probation interviews, and attorney meetings. By contrast, Maxwell
shares access to the MDC VTC room with substantially fewer inmates. The MDC can therefore
provide 15 hours of VTC meetings with her attorneys without compromising access for other
MDC inmates. The same is not true for Rivera at the MCC.
Going forward, even though Rivera's counsel have asked (and the Court has ordered) that Rivera
receive three hours of laptop access each day, the MCC is now leaving the laptop with him all day long,
and only takes it back at night to charge it. Therefore, the MCC is now providing the same amount of
electronic discovery access to Rivera that Maxwell receives at the MDC.
As for providing Rivera with up to 15 hours of VTC access, we will explain that doing so will
compromise access for other inmates. If defense counsel expresses a need for additional time, the
MCC will continue to find ways to accommodate those requests as best as they can.
Please let me know if you have any questions or would like to discuss this further.
Best,
From:
(USANYS)
Sent: Monday, December 21, 2020 4:42 PM
To:
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS)
is
)
is
)
is
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
V.
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Thanks,
Can you keep me posted on what we think will be the substance of the draft declaration when you know
(that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences between MCC
and MDC, as well as specific differences in their housing situations?
From:
(USANYS)
Sent: Monday, December 21, 2020 4:35 PM
To:
(USANYS)
i
(USANYS)
is
(USANYS)
is
(USANYS)
is
)
is
)
is
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
All:
EFTA00013330

=== Page 3 ===
I wanted to bring to your attention a recent issue that's surfaced in United States v. Rivera et al., a sex
trafficking case pending before Judge Engelmayer. As I'll describe in more detail below, Judge
Engelmayer has asked us to submit a declaration from the BOP explaining why the discovery and
counsel access accommodations provided to Ghislaine Maxwell (detained at the MDC outside the
general population) cannot be extended to Justin Rivera (detained at the MCC in the general
population).
Justin Rivera was charged in February 2019 with sex trafficking conspiracy. He's been detained at the
MCC since April 2019 on consent (he's also serving a state sentence). His trial, which was originally
scheduled for April 2019, is expected to start on February 16, 2020. In July 2020, he had new counsel
appointed, citing an irreconcilable breakdown with his former counsel.
Since this fall, Judge Engelmayer has become increasingly frustrated with the MCC's treatment of
Rivera. In particular, he's cited their failure to provide Rivera with adequate accommodations to
review discovery and meet with his lawyers, who refuse to visit Rivera at the MCC for personal health
concerns. We have two court orders in place to address these issues: (1) a laptop order, which requires
the MCC to provide Rivera access to a laptop for three hours per day; and (2) a videoconference order,
which requires the MCC to make available four hours of videoconferencing each week, in addition to
any telephone or videoconference calls obtained through the Federal Defenders.
At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time Rivera
has for videoconferences and electronic discovery review is insufficient for trial preparation, although
defense counsel has stated that they may request more time in the future. However, in a letter last
night and during a court conference this morning (transcript attached), defense counsel cited the
accommodations that the MDC has provided to Maxwell, describing them as "strikingly different and
far superior" to those afforded to Rivera. Defense counsel further suggested that Rivera was being
treated differently on account of his race, gender and class. Judge Engelmayer stated that the
disparity in access "jumped off the page" and that the optics were "terrible," and asked us to explain
the rationale for the differing treatment. After conferring with
and
before
our conference, we explained our understanding that the disparity comes down to the fact that
Maxwell and Rivera have very different housing situations, with Maxwell's situation being more
amenable to greater access to electronic discovery review and legal visits.
Judge Engelmayer asked us to submit a declaration, from an appropriate person at the BOP,
explaining in more detail why the accommodations provided to Maxwell cannot be extended to Rivera.
Based on the recent bail opposition in the Maxwell case, I believe the differences in counsel/discovery
access are as follows:
Accommodation
Maxwell
Rivera
Review of electronic
13 hours per day/7 days per
3 hours per day/7 days per
discovery (NB: each
week (91 hours total)
week (21 hours total)
defendant has laptop access)
Counsel visits (by video)
3 hours per day/5 days per
Four hours per week (plus an
week (15 hours total)
additional two hours
scheduled through the
Federal Defenders) (6 hours
total)
Weekend legal calls
As needed
Not available
EFTA00013331

=== Page 4 ===
The declaration is due by December 31. Because Judge Engelmayer's request implicates at least two
criminal cases, and potentially the ongoing civil litigation with the MCC, we wanted to make sure that
you were all aware of this issue. We are also happy to set up a call to discuss this further. In the
meantime, we are working with
to identify the appropriate declarant and draft an
explanation for the Court.
Best,
Bhaskaran
Assistant United States Attorney
United States Attorney's Office for the Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Tel:
EFTA00013332


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=== Page 1 ===
From:
(USAFLS)"
To: Jay Lefkowitz
Bcc:
(USAFLS)"
Subject: RE: Jeffrey Epstein
Date: Wed, 03 Dec 2008 21:50:12 +0000
Importance: Normal
Yes, thanks.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
From: Jay Lefkowitz [mailto:
Sent: Wednesday, December 03, 2008 4:50 PM
To:
(USAFLS)
Subject: RE: Jeffrey Epstein
sure - can call you in 10 min. office?
(USAFLS)"
To "Jay Lefkowitz"
CC
12/03/2008 04:49 PM
Subject RE: Jeffrey Epstein
Do you have a minute to talk?
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
From: Jay Lefkowitz [mailto:
Sent: Wednesday, December 03, 2008 4:48 PM
To:
(USAFLS)
Cc:
Subject: Re: Jeffrey Epstein
- Sorry for not responding earlier. I am not planning on coming down for the meeting.
Jay
(USAFLS)"
EFTA00014035

=== Page 2 ===
12/01/2008 12:34 PM
To
cc
Subject Jeffrey Epstein
Hi Jay - Are you going to be at the meeting on Thursday with Roy?
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to
, and
destroy this communication and all copies thereof,
including all attachments.
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to
, and
destroy this communication and all copies thereof,
including all attachments.
EFTA00014036


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=== Page 1 ===
From:
To:
Subject: epstein
Date: Thu, 26 Jun 2008 13:58:53 +0000
Importance: Normal
Attachments: Summary_Of_Misconduct.pdf
EFTA00013799


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=== Page 1 ===
From:
To:
Cc:
Christian Everdell
"Mark S. Cohen"
,
>, BOBBI C STERNHEIM
"Laura Menninger"
, Jeff Pagliuca
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Letter Regarding Redactions to Defense Reply Briefs and
Exhibits
Date: Tue, 20 Apr 2021 23:46:58 +0000
Attachments: 2021-04-20_GM_Government_leter_re_Reply_Brief_Redactions.pdf;
Ex._M_Sealed_(Proposed_Redactions) pdf; Ex._N_Sealed_(Proposed_Redactions).pdf
Good evening,
Attached please find a letter regarding the redactions to the defense's reply briefs, which has been filed on ECF in the
above-referenced case. Also attached please find two exhibits setting forth the Government's proposed redactions.
Respectfully submitted,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00009895


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=== Page 1 ===
From:
To:
Bcc:
Subject: Epstein
Date: Thu, 03 Jul 2008 15:36:42 +0000
Importance: Normal
Hi
- I just got an earful from the last of the victims' lawyers. He is a former Broward County ASA and he
represents three victims. He says that his clients can name many more victims and wanted to know if we can get
out of the deal. I told him that, at this time, assuming that Epstein performs the last piece of the agreement, we
are bound. He asked that, if there is the slightest hesitation on Epstein's part of completing his performance, that
he and his clients be allowed to consult with our office before making a decision.
I also couldn't remember if I told you about our meeting with the Sheriff's Office about the jail. Epstein is out at
the stockade, not the jail. Goldberger and some psychiatrist have already met with him and have told him that, if
he receives any less favorable treatment than others, Ken Starr and the whole crew will sue. He also told me that
Epstein was "brilliant" and that he has already offered to teach GED classes. I sort of cocked my head at the
"brilliant" comment and said, you know he only has a high school diploma, right? (I used my best, "don't
believe the hype" voice. He was clearly shocked, and I explained that Epstein usually claims to have at least a
master's degree, but other than a few college courses, he had no education above a high school diploma, which I
think makes him ineligible to teach a GED course.) He also told us that Epstein is eligible for work release and
will be placed on work release - in direct contradiction to what he told the agents a few months ago.
Assistant U.S. Attorney
Phone
Fax
EFTA00013975


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=== Page 1 ===
From:
To:
Subject: RE: Ghislaine Maxwell custody
Date: Fri, 03 Jul 2020 15:39:21 +0000
is on it. Can I please have name of law firm and best contact number for each lawyer?
Thanks.
From:
Sent: Friday, July 3, 2020 11:32 AM
To:
Subject: RE: Ghislaine Maxwell custody
Appreciate it, thank you.
From
Sent: Friday, July 3, 2020 11:21 AM
To:
Subject: Re: Ghislaine Maxwell custody
I will call
and advise - he can be a little touchy.
Sent from my iPhone
On Jul 3, 2020, at 11:13 AM,
wrote:
Thanks. I think it's fine to speak with
about it, but my sense is that we would also need USMS approval, based on
the email from
If you think it would be ok, I'm happy to reach out to
directly to discuss.
From:
Sent: Friday, July 3, 2020 11:05 AM
To:
Subject: Re: Ghislaine Maxwell custody
I will try. Can I start with
he may be in the best position to get it done?
Sent from my iPhone
On Jul 3, 2020, at 10:23 AM,
wrote:
EFTA00010364

=== Page 2 ===
Thanks very much for passing this along. The permitted attorney contact on the list below only includes Vogelman
without reference to her New York counsel. Would it be possible to add her two New York attorneys-Chris Everdell
and Mark Cohen-to the list of people Maxwell can speak with on the phone, please?
Ideally, we would like to get them added today so that they can speak with their client over the weekend to facilitate
our discussions with them about next steps in the case.
Thanks,
From:
Sent: Thursday, July 2, 2020 3:47 PM
To:
Subject: Fwd: Ghislaine Maxwell custody
FYI
Sent from my iPhone
Begin forwarded message:
From:
Date: July 2, 2020 at 3:43:43 PM EDT
To: "NHD-SUPERVISORS (USMS)"
Cc:
Subject: Ghislaine Maxwell custody
To all:
Below are the restrictions we have put in place regarding Ms. Maxwell during her stay at Merrimack DOC. I. If you
have any questions please feel free to call or email me.
Due to the high profile status of this case Inmate Maxwell will be closely monitored. The following
directives apply and shall not be deviated from without express permission from
, myself or
1.
Inmate Maxwell will be housed in M1
2.
SRT personnel will be posted in medical and will only be relieved only by SRT personnel
3.
Staff will not converse with the inmate outside of the standard communication required related to the
inmate's health and safety
4.
Inmate Maxwell will remain on a 15 minute observation watch
5.
All rounds, and touch probe rounds will be conducted and documented in XJail
6.
Third Shift Supervisors will download the touch probe rounds and camera footage from the previous
day at 0000 hours each day. The video from the medical cell DVR will be downloaded onto a USB drive
EFTA00010365

=== Page 3 ===
and will be tracked via the designated tracking form provided. Supervisors are directed to deliver this
documentation and video to
Monday July 6th
7.
Inmate Maxwell will be authorized to communicate with her legal counsel, Lawrence Vogelman. This
contact is only authorized after Atty Vogelman provides the appropriate PIN
8.
Any and all requests from Inmate Maxwell are to be directed to
only
At no time are staff authorized to make statements to the press regarding this matter or our SOP regarding
this inmate.
Supervisory Deputy United States Marshal
District of New Hampshire
Concord, New Hampshire
office
This e-mail is property of U.S. Marshals Service. It is intended only for the person or entity to which it is addressed
and may contain information that is privileged, confidential, or otherwise protected from disclosure. Distribution or
copying of this e-mail or the information contained herein by anyone other than the intended recipient is prohibited.
If you have received this e-mail in error, please notify me immediately and destroy all electronic and paper copies of
this e-mail.
EFTA00010366


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
)"
Subject: Epstein FOIA Atty Visit Logs and Count Slips
Date: Sat, 09 Jan 2021 14:12:33 +0000
Attachments: 127124560313.pdf
Hi
Defense counsel in Tartaglione has requested to see the attorney visit logs and count slips that have Tartaglione's name on
them. Those documents may be covered by the attached protective order, and so we have asked
who is
firewall counsel in Tartaglione, to receive the documents from you for potential production to defense counsel (so that
and I do not see them).
is going to review the protective order first and determine whether she needs
Judge Karas to modify the order to allow her to receive the documents, so please don't send them to
until she
reaches out. Thanks for helping with this - we know it is a pain.
Deputy Chief, White Plains Division
United States Attorney's Office
Southern District of New York
300 Quarropas Street
White Plains, New York 10601
Tel:
Cell:
EFTA00013271


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: Press Conference at Epstein's
Date: Mon, 27 Jan 2020 21:14:27 +0000
From FBI
Team unhappy also getting calls. I guess Geoff did mention the location to some people but need to figure out how to
keep everyone in loop for anything like this going forward.
From:
Sent: Monday, January 27, 2020 4:11 PM
To:
(USANYS)
is
(USANYS)
Cc:
>;
Subject: Fwd: Press Conference at Epstein's
Please see the below email from
Could somebody above the line level connect with
to discuss? We
also do not know what the office would like us to convey to the victims. Thanks.
Sent from my iPhone
Begin forwarded message:
From:
"
(NY) (FBI)"
Date: January 27, 2020 at 3:27:49 PM EST
To:
)"
)"
,
)"
Cc:
(NY) (FBI)"
i
Subject: Press Conference at Epstein's
All,
I have been getting some questions about the press conference that occurred today at Epstein's mansion, do any
of you know that was about? Our media affairs department has been getting questions. In addition, our Victim
Specialists have been fielding calls from irate victims who weren't notified.
https://twitter.com/AaronKatersky/status/1221833096686903299/photo/1
thanks,
SSA
Squad C-20
Crimes Against Children/Human Trafficking
FBI New York
office
mobile
EFTA00011145


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=== Page 1 ===
From:
To:
Subject: FW: jeffrey epstein
Date: Fri, 21 Sep 2007 15:18:35 +0000
Importance: Normal
Do you know what she's talking about?
Sent from my GoodLink synchronized handheld (www.good.com)
Original Message
From: Lilly Ann Sanchez [mailto
Sent:
Friday, September 21, 2007 10:24 AM Eastern Standard Time
To:
Subject:
jeffrey epstein
i know you are on vacation in a different time zone, however, i want to finalize the plea deal and there is only one issue
outstanding and i do not believe that alex has read all the defense submissions that would assist in his determination on
this point. upon resolution, we will be prepared to sign as soon as today.
you are only one left in chain of command on this case
with
gone.
please call me if you have a moment i would like your thoughts on this.
Lilly Ann Sanchez, Esq.
FOWLER WHITE BURNETT P.A.
Espirito Santo Plaza, 14th Floor
1395 Brickell Avenue
Miami, Florida 33131-3302
**TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance
with requirements imposed by the IRS, we inform you that any tax
advice contained in this communication (including attachments) was
not intended or written to be used, and cannot be used, for the
purpose of (i) avoiding penalties under the Internal Revenue Code
or (ii) promoting, marketing or recommending to another party any
transaction or matter addressed herein. If you would like such advice,
please contact us.
***Attention: The information contained in this E-mail message
is attorney privileged and confidential information intended only
for the use of the individual(s) named above. If the reader of this
message is not the intended recipient, you are hereby notified that any
EFTA00013610

=== Page 2 ===
dissemination, distribution or copy of this communication is strictly
prohibited. If you have received this communication in error, please
contact the sender by reply E-mail and destroy all copies of the original
message. Thank you.
EFTA00013611


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=== Page 1 ===
From: Jack Scarola
To:
Cc:
Subject: [EXTERNAL] Re: EXTERNAL Rule 17(c) subpoena
Date: Tue, 16 Nov 2021 09:58:14 +0000
Attachments: 2021.11.14 Mtn for_Order_Auth_a_Sub_Pursnt_to_F.R.Crim.P_17(c)
(3)_re.
Redacted_for_Scarola.pdf;2021.11.14_Ex._1_Redacted_for_Scarola.pdf
While our preference is to minimize the invasion of
privacy, there is unlikely to be anything in those
files that will be of concern to you. Obviously, the disclosures to the Fund were made under assurances of
confidentiality.
On Nov 15, 2021, at 9:29 PM,
wrote:
Jack,
Attached is a motion that Maxwell's has counsel filed seeking to subpoena information from the Epstein Victim
Compensation Fund, including information about
We intend to file a motion to quash the subpoena later this
week. Happy to have a call if you would like to discuss or have any questions.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
CAUTION: This email originated from outside the organization. Do not click links or open attachments
unless you recognize the sender and know the content is safe.
| Privileged and Confidential | Electronic communication is not a secure mode of communication and may be
accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola
Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-
2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin.
2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is
not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this
communication is strictly prohibited. Personal messages express views solely of the sender and shall not be
attributed to the law firm. If you received this communication in error, please notify the sender immediately by
e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank you.
EFTA00010240


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=== Page 1 ===
From:
To: Jack Goldberger
Roy BLACK
Cc:
Bcc:
Subject: Notice of Non-Compliance
Date: Fri, 27 Jun 2008 21:43:23 +0000
Importance: Normal
Attachments: 080627_Goldberger_Black_notification_ltr.pdf
Dear Messrs. Goldberger and Black:
Please see the attached Notification Letter.
<<080627 Goldberger Black notification Itr.pdf>>
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
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=== Page 1 ===
From: USDOJ-Office of Public Affairs <USDOJ-OfficeofPublicAffairs@public.govdelivery.com>
To:
Subject: STATEMENT ON DOJ OFFICE OF PROFESSIONAL RESPONSIBILITY REPORT ON JEFFREY
EPSTEIN 2006-2008 INVESTIGATION
Date: Thu, 12 Nov 2020 18:56:09 +0000
seal - centered header for gov delivery
The United States Department of Justice
FOR IMMEDIATE RELEASE
THURSDAY, NOVEMBER 12, 2020
WWW.JUSTICE.GOV/NEWS
NOTE: The executive report summary can be found here.
STATEMENT ON DOJ OFFICE OF PROFESSIONAL
RESPONSIBILITY REPORT ON JEFFREY EPSTEIN 2006-
EFTA00013355

=== Page 2 ===
2008 INVESTIGATION
WASHINGTON -- The executive summary of a report by the Department of
Justice's Office of Professional Responsibility (OPR) was released today to
affected victims. The summary, which is available on the Justice Department
website, provides the essential details about the findings of OPR's 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.
While OPR did not find that Department attorneys engaged in professional
misconduct, OPR concluded that the victims were not treated with the
forthrightness and sensitivity expected by the Department. OPR also concluded
that former U.S. Attorney Acosta exercised poor judgment by deciding to resolve
the federal investigation through the non-prosecution agreement and when he
failed to make certain that the state of Florida intended to and would notify
victims identified through the federal investigation about the state plea hearing.
In order to fully respect the rights and dignity of Jeffrey Epstein's many victims,
the Department first invited victims and their legal representatives to be briefed
this morning on the report's contents. The Privacy Act prohibits the Department
from releasing the full report publicly, but permits the report to be disclosed upon
request to a congressional committee with jurisdiction over the matter, and this
has been done.
We salute the courage of survivors as they again are confronted with these
horrible crimes and their aftermath. The Department will thoroughly review the
report, which will inform our implementation of the Crime Victims Rights' Act
and the Attorney General's Guidelines on Victim and Witness Assistance.
###
The year 2020 marks the 150th anniversary of the Department of Justice. Learn
more about the history of our agency at www.Justice.gov/Celebrating150Years.
OPR
20-1227
Do not reply to this message. If you have questions, please use the contacts in the
message or call the Office of Public Affairs at 202-514-2007.
EFTA00013356

=== Page 3 ===
Twi Fac You Ins
Follow us:
the
oR
Tub
tax
This email was sent to
using GovDelivery, on behalf of U.S. Department of Justice Office of Public Affairs - 950 Pennsylvania Ave., NW
Washington, DC 20530 202-514-2007 TTY (866) 544-5309. GovDelivery may not use your subscription information for any other purposes. Click here to
unsubscribe.
Department of Justice Privacy Policy I GovDelivery Privacy Policy
EFTA00013357


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein-related docs released by Second Circuit
Date: Fri, 09 Aug 2019 15:43:03 +0000
Just FYI for everybody, today the Second Circuit has unsealed (and posted) a ton of documents from the
V.
Ghislaine Maxwell libel lawsuit, so there likely will be a ton of reporting on that. Any reference to those newly-unsealed
documents are separate from-and do not include-any filings we've made, and are independent of our case.
(We have been aware of the litigation and generally aware of the filings, though it also won't hurt to have a bunch of
journalists combing through them and reporting out interesting elements.)
Anyway just wanted to note that there's likely to be a flood of attention to this development but that it's not anything new
specifically from our investigation.
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From: Ted Leopold
To:
(USAFLS)"
Cc: Spencer Kuvin
Subject: RE: Epstein Investigation
Date: Wed, 02 Jul 2008 21:21:27 +0000
Importance: Normal
I will get you the names tomorrow. Thanks
Spencer, please see me.
Original Message
From:
(USAFLS) [mailto:
]
Sent: Monday, June 30, 2008 5:00 PM
To: Ted Leopold
Subject: Epstein Investigation
Dear Ted: Here is my e-mail address and contact information.
Thank you for your assistance.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
EFTA00014098


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=== Page 1 ===
From:
To: Jack Scarola
Cc:
Subject: RE: EXTERNAL Rule 17(c) subpoena
Date: Tue, 16 Nov 2021 12:51:12 +0000
Thanks very much, Jack. We expect the Fund will file an opposition to the subpoena emphasizing the expectations of
confidentiality that you highlight.
From: Jack Scarola
Sent: Tuesday, November 16, 2021 4:58 AM
To:
Cc:
Subject: [EXTERNAL] Re: EXTERNAL Rule 17(c) subpoena
While our preference is to minimize the invasion of
privacy, there is unlikely to be anything in those files that will
be of concern to you. Obviously, the disclosures to the Fund were made under assurances of confidentiality.
On Nov 15, 2021, at 9:29 PM,
wrote:
Jack,
Attached is a motion that Maxwell's has counsel filed seeking to subpoena information from the Epstein Victim
Compensation Fund, including information about
We intend to file a motion to quash the subpoena later this
week. Happy to have a call if you would like to discuss or have any questions.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
CAUTION: This email originated from outside the organization. Do not click links or open
attachments unless you recognize the sender and know the content is safe.
Privileged and Confidential I Electronic communication is not a secure mode of communication and may be accessed by
unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola Barnhart & Shipley, P.A.
and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-2521. The information contained in this
E-mail message is privileged and confidential under Fla. R. Jud. Admin. 2.420 and information intended only for the use of
the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that
any dissemination, distribution, or copy of this communication is strictly prohibited. Personal messages express views
solely of the sender and shall not be attributed to the law firm. If you received this communication in error, please notify
EFTA00010157

=== Page 2 ===
the sender immediately by e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank
you.
EFTA00010158


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=== Page 1 ===
From:
To:
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: RE: Jeffrey Epstein devices - privilege review
Date: Mon, 05 Oct 2020 16:18:19 +0000
Embedded: RE:_Jeffrey_Epstein_devices_-_privilege_review.msg
Subject: RE: Jeffrey Epstein devices - privilege review
Message-Id:
<SN5P110MB0542B0B7E1EEB15DD1BC191F920C0@SN5P110MB0542.NAMP110.PROD.OUTLOOK.CO
M>
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=== Page 1 ===
From:
"
(USAFLS)"
To:
(USAFLS)"
(USAFLS)"
Bcc:
"
(USAFLS)"
Subject: 080627 Goldberger Black ltr.pdf
Date: Fri, 27 Jun 2008 19:40:21 +0000
Importance: Normal
Attachments: 080627_Goldberger_Black_Itr.pdf
Here is the letter that I just faxed over.
Police checked the docket and it is on at 8:30 for a "status conference." It also looks like the required
procurement of minors charge has been filed. Will keep you posted.
<<080627 Goldberger Black Itr.pdf>
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=== Page 1 ===
BOBBI C. STERNHEIM, ESQ.
New York, NY 10007
Main:
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.
EFTA00011139


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=== Page 1 ===
Event: Hearing on Epstein Motion to Quash
Start Date: 2007-09-18 13:00:00 +0000
End Date: 2007-09-18 16:00:00 +0000
Organizer:
C. (USAFLS) /O=USA/OU=FLS/CN=RECIPIENTS/CN=AVILLAFANA>
Location: Judge Marra
Class: X-PERSONAL
Date Created: 2015-04-04 00:21:49 +0000
Date Modified: 2015-07-22 20:34:55 +0000
Priority: 5
DTSTAMP: 2007-09-11 16:13:46 +0000
Attendee:
(USAFLS)
i
(USAFLS)
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=== Page 1 ===
From:
(FBI)"
To:
(USAFLS)"
Subject: Re: Epstein Investigation
Date: Fri, 04 Jul 2008 15:39:28 +0000
Importance: Normal
Yeah, I'm at Sanibel Island right now. Just finished watching the 4th parade. I do believe there was a
possibly in the message
pads but she was never fully identified. There were only a couple of other names in the message pads that we didn't get Id'd, including
and
(girls I believe
brought). I have a feeling we'll be hearing about many other victims since his conviction.
Hope you have a Happy 4th of July!
Original Message
From:
(USAFLS)
To:
Sent: Fri Jul 04 11:29:08 2008
Subject: RE: Epstein Investigation
Strange, huh? Did you get to go away? Have a great weekend.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
Original Message
From:
(FBI)
Sent: Friday, July 04, 2008 11:26 AM
To:
(USAFLS)
Subject: Re: Epstein Investigation
No
Original Message
From:
(USAFLS)
To:
;
Sent: Fri Jul 04 11:24:41 2008
Subject: FW: Epstein Investigation
Hi guys - Have we ever heard of
(below)?
Assistant U.S. Attorney
West Palm Beach, FL 33401
EFTA00014096

=== Page 2 ===
Phone
Fax
From: Ted Leopold [mailto:
Sent: Thursday, July 03, 2008 4:25 PM
To:
(USAFLS)
Cc: Spencer Kuvin
Subject: RE: Epstein Investigation
Our two client names are:
1.
if you need any other information please let me know.
Ted
Original Message
From:
(USAFLS) [mailto:
Sent: Monday, June 30, 2008 5:00 PM
To: Ted Leopold
Subject: Epstein Investigation
Dear Ted: Here is my e-mail address and contact information.
Thank you for your assistance.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
EFTA00014097


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=== Page 1 ===
From:
(USANYS)"
To: Christian Everdell
, BOBBI C STERNHEIM
>, , Laura Menninger
, Jeff Pagliuca
Cc:
)"
)"
)"
,
"
(USANYS) [Contractor
i
(USANYS) [Contractor]"
Subject: US V. Maxwell, 20 Cr. 330 (AJN)
Date: Tue, 16 Nov 2021 13:07:56 +0000
Attachments:2021.11.16_Maxwell_Discovery_Letterpdf;2021.11.16_Maxwell_3500_Cover_Leterpdf.
2021.11.16_U.S._v_Maxwell_3500_Index_(Defense_Copy).pdf;
2021.11.16_U.S._v_Maxwell_Non-
Testifying_Witness_Material_Index_(Defense_Copy).pdf;
2021.11.16_US_v._Maxwell_Government_Exhibit_Index_(Defense).pdf
Counsel,
We have an additional discovery production ready to send to you. Attached please find the accompanying cover letter. In
addition, a supplemental production of testifying witness and non-testifying witness material and exhibits are also ready
to send to you. Attached please find the accompanying cover letter and indices.
The production will be made via USAfx. We will send one of the hard drives you provided to the MDC for Ms. Maxwell.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00010159


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=== Page 1 ===
From:
"
(USAFLS)"
To:
(FBI)"
(FBI)"
Bcc:
"
(USAFLS)"
Subject: Keep an eye on Epstein's planes!!! Will call in a few minutes
Date: Tue, 24 Jun 2008 19:53:43 +0000
Importance: Normal
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
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=== Page 1 ===
From: "Kate L. Doniger"
To:
(USANYS)"
Cc:
)"
N
Alexandra Conlon
, Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Date: Tue, 14 Apr 2020 19:00:51 +0000
We hope that you are keeping well in this very challenging time.
We completely understand that all things are in flux these days, but we just wanted to check in with you about our
request and whether there is any other information you need from us. If it would be helpful to set up a call to discuss, we
are available at your convenience.
Best,
Kate
Kate L. Doniger Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Thursday, February 27, 2020 7:23 PM
To: Alexandra Conlon
>; Roberta Kaplan
Cc: Kate L. Doniger
Subject: RE: Request for Information Relating to Jeffrey Epstein
Alexandra and Robbie,
Thank you for this. I will contact you regarding the request.
Thanks,
From: Alexandra Conlon
Sent: Tuesday, February 25, 2020 7:54 PM
To:
(USANYS)
>; Roberta Kaplan
Cc: Kate L. Doniger
is
Subject: RE: Request for Information Relating to Jeffrey Epstein
SENT ON BEHALF OF ROBERTA KAPLAN
AUSA
Thank you for contacting us. Attached please find a Touhy letter and supporting exhibit requesting documents from the
Department of Justice in connection with our pending litigation against Jeffrey Epstein's estate.
EFTA00010460

=== Page 2 ===
We are happy to schedule a time to talk if it would be helpful to discuss our request.
Best Regards,
Robbie
Alexandra Conlon I Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Monday, January 6, 2020 6:59 PM
To: Roberta Kaplan
Cc: Kate L. Doniger
>; Alex Conlon
Subject: Request for Information Relating to Jeffrey Epstein
Dear Ms. Kaplan,
Please find attached a letter regarding the request you discussed with AUSA
for certain information
relating to Jeffrey Epstein. As stated in the letter, please contact me once you have had a chance to review the letter if you
would like to discuss the issues therein further.
Thanks,
Assistant United States Attorney
Southern District of New York
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.
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.
EFTA00010461


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 344 Filed 10/14/21 Page 1 of 2
UNITED STATES DISTRICT COURT
USDC SDNY
SOUTHERN DISTRICT OF NEW YORK
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 10/14/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
The Court received a letter via email from a lawyer for an alleged victim regarding victim
attendance at the upcoming trial. The Court will file the letter under seal and forward a copy to
counsel for both sides.
Consistent with the District's COVID-19 protocols, the Court will ensure public access
for pre-trial proceedings and trial, including several overflow rooms at the courthouse with live
feeds of the proceedings. Additional information will be provided as soon as it is available.
Access for alleged victims will be coordinated between the Victim Witness Unit and the
District Executive's Office. The contact information for each office is provided below.
Furthermore, Defense counsel may coordinate access for the Defendant's family members with
the District Executive's Office.
Wendy Olson, Coordinator
Joseph Pecorino
Victim Witness Unit
District Executive's Office
United States Attorney's Office
United States District Court
(212) 637-1028
Southern District of New York
Wendy.Olson@usdoj.gov
(212) 805-0504
Joseph_Pecorino@nysd.uscourts.gov
so ORDERED.
1
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=== Page 2 ===
Case 1:20-cr-00330-AJN Document 344 Filed 10/14/21 Page 2 of 2
Dated: October 14, 2021
Alim D.Netto
New York, New York
ALISON J. NATHAN
United States District Judge
2
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=== Page 1 ===
From:
"
(USAFLS)"
To:
(USAFLS)"
(USAFLS)"
,
(USAFLS)"
Cc:
(FBI)"
"
(FBI)"
Bec:
(USAFLS)"
Subject: Epstein Plea
Date: Fri, 27 Jun 2008 19:47:54 +0000
Importance: Normal
Attachments: Epstein_Plea001.pdf
Wow, am I good. Here it is already. I think our faxes crossed in cyber-space. Sorry for the poor quality, that is
how it came to me.
<<Epstein Plea001.pdf>>
Assistant U.S. Attorney
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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: RE: Call re Epstein responsiveness review
Date: Tue, 13 Oct 2020 14:35:36 +0000
H
No problem at all-thank you so much for taking care of this hard drive issue. If there is anything at all I can do to help get
a drive out the door, please let me know. We can catch up once that is done.
Thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, October 13, 2020 10:30 AM
To:
Subject: RE: Call re Epstein responsiveness review
Hello
Please do not think I forgot about you as I am working on getting this hard drive out the door today. I will give you a call
back as soon as I can.
Thank you.
From:
Sent: Tuesday, October 13, 2020 9:35 AM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: Re: Call re Epstein responsiveness review
Thanks very much,
I'll call you at 10am.
On Oct 13, 2020, at 8:53 AM,
(USANYS) [Contractor]
wrote:
Good Morning
I am available for a call between 9 - 11 am this morning and between 12:30 and 2 PM today. Please let me know what
time works for you.
Thank you.
From:
Sent: Sunday, October 11, 2020 7:54 PM
EFTA00011409

=== Page 2 ===
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: Call re Epstein responsiveness review
Hi
Hope you're having a nice weekend. Is there a time on Tuesday when you would be available for a call to discuss the
responsiveness review of the Epstein SW returns on Relativity, please?
I'm available the entire morning if there's a time that would work for you.
Thanks,
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From:
Subject: Epstein Ducks Modeling Agency Suit Over Improper Service - Law360
Date: Thu, 25 Apr 2019 10:38:11 +0000
Importance: Normal
Epstein Ducks Modeling Agency Suit Over Improper Service
By Carolina Bolado
Share us on:
https://www.law360.com/articles/1153140/epstein-
ducks-modeling-agency-suit-over-improper-service
Law360 (April 24, 2019, 6:45 PM EDT) --
Billionaire sex offender Jeffrey Epstein ducked a
modeling agency's lawsuit Wednesday when a
Florida appeals court ruled the business had failed to
properly serve him with the complaint at his primary
residence on a private island in the Caribbean.
Florida's Third District Court of Appeal said service
of the complaint by Miami-based MC2 Model &
Talent LLC and its owner, Jean-Luc Brunel, on an
office supervisor at Epstein's U.S. Virgin Islands
business address did not comply with the
requirements under Florida law and that the suit
should be dismissed without prejudice, meaning it
could be refiled.
The appeals court agreed with Epstein, who had
argued that Brunel and MC2 never attempted to serve
him at his primary residence, a private island called
Little St. James in the U.S. Virgin Islands.
"Brunel and MC2 attempt to excuse strict compliance
by arguing that the legislature could not have
contemplated a lifestyle like Epstein's," the Third
District said. "But Brunel and MC2 never tried to
serve Epstein at his place of abode."
Epstein argued that service of process takes place
routinely on private property and that his private
EFTA00010249

=== Page 2 ===
island is accessible by boat, has a large dock and is
easily located on any map. Nothing would have
prevented a process server from tying up to the dock
and asking for him, Epstein said.
Brunel and MC2 sued Epstein in January 2015 in
Miami, claiming the notoriety and bad publicity
stemming from sexual assault and prostitution
charges against Epstein cost the agency business.
Brunel has been linked to Epstein and has been
accused by at least one victim of supplying Epstein
with underage girls.
Epstein pled guilty in 2007 to felony charges
involving solicitation of prostitution and procurement
of minors for prostitution. He served 13 months in
prison and is a registered sex offender.
Brunel tried to serve Epstein at his residential address
in New York, but Epstein successfully moved to
quash service, according to the opinion. Brunel then
tried the Virgin Islands business address, which the
trial court deemed acceptable in September 2018.
But the Third District said that in order for substitute
service to be acceptable under Florida law, it must be
made on an individual doing business as a sole
proprietorship. The Virgin Islands business is not a
sole proprietorship owned by Epstein, according to
the appeals court.
In February, a Florida federal judge ruled that
prosecutors, including then-U.S. Attorney and current
Labor Secretary Alexander Acosta, violated the
Crime Victims' Rights Act when they signed a
nonprosecution agreement with Epstein without
notifying his victims.
The Miami Herald, in an investigative report
published late last year, printed emails showing that
EFTA00010250

=== Page 3 ===
the alleged victims were deliberately excluded from
the deal cut between Acosta, who was then the U.S.
attorney for the Southern District of Florida, and
Epstein's defense team.
Epstein's alleged victims - numbering in the dozens
- claim he lured teenage girls to his Palm Beach,
Florida, mansion to engage in sexual acts. They have
not had the opportunity to testify in court in any
proceeding thus far, according to the Herald report.
An attorney for Brunel declined to comment
Wednesday. Attorneys for Epstein did not
immediately respond to a request for comment.
Judges Kevin Emas, Edwin A. Scales III and Norma
S. Lindsey sat for the Third District.
Epstein is represented by Scott J. Link and Kara
Berard Rockenbach of Link & Rockenbach PA.
Brunel and MC2 are represented by Joe Titone.
The case is Epstein V. Brunel et al., case number
3D18-1997, in the Third District Court of Appeal of
Florida.
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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc: Christian Everdell
Subject: Ghislaine Maxwell
Date: Tue, 13 Apr 2021 23:37:33 +0000
Good evening-
Might you have any sway in persuading the Marshal permit Ms. Maxwell
to have her legal materials while in the cell block?
She arrived today at - 5:15 am and remained idle in the cell block
until ~ 8:30 am when she was brought to the fifth floor.
Otherwise, any opposition to me contacting the Court for an order
(per the Marshal)?
Enjoy the evening. See you tomorrow.
Best-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
**Covid-19 Notice: The
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.
EFTA00009831


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=== Page 1 ===
Event: Accepted: Call w/ SDNY re: discovery, Epstein investigation
Start Date: 2020-10-23 15:00:00 +0000
End Date: 2020-10-23 15:30:00 +0000
Location: 844-215-6902,, 133318
Class: X-PERSONAL
Comment:
Date Created: 2020-10-22 16:58:40 +0000
Date Modified: 2020-10-22 16:58:40 +0000
Priority: 5
DTSTAMP: 2020-10-22 16:36:53 +0000
Attendee:
EFTA00010298


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=== Page 1 ===
BLACK
ROY BLACK
HOWARD M. SREBNICK
SREBNICK
JESSICA FONSECA-NADER
SCOTT A. KORNSPAN
KATHLEEN P. PHILLIPS
LARRY A. STUMPF
KORNSPAN
AARON ANTHON
MARIA NEYRA
JACKIE PERCZEK
STUMPF
MARCOS BEATON, JR.
MATTHEW P. O'BRIEN
MARK A.J. SHAPIRO
P.A.
JENIFER J. SOULIKIAS
JARED LOPEZ
NOAH Fox
E-Mail:
September 1, 2009
, Esq.
Assistant U.S. Attorney
United States Attorney's Office
99 N.E. 4th Street
Miami, Florida 33132
RE: Jeffrey Epstein
Dear
Once again I need to send you a note about Jeffrey Epstein, mainly to keep
you in the loop so we don't inadvertently violate any provision of his agreement
with your office. As I am sure you are aware, Mr. Epstein has finished the
incarceration portion of his sentence and is now serving the one year of
community control as mandated by both his state plea and the terms of the non-
prosecution agreement with the United States Attorney's Office for the Southern
District of Florida.
Mr. Epstein is in compliance with all terms of his community control and
is applying for transfer of his supervision from the State of Florida to his primary
residence, the Virgin Islands. This transfer is being requested through the
Intrastate Compact for Transfer of Adult Supervision (ICAOS). The ICAOS is the
mechanism for which transfers of probation and community control are
effectuated. The process requires the offender to seek the approval of the sending
state (in this case Florida) and, if they agree, the receiving state (in this case the
United States Virgin Islands) and the United States Virgin Islands after
investigation has pre-approved the transfer under the same exact conditions of
supervision as imposed in Mr. Epstein's community control sentence in the State
of Florida.
Even though Mr. Epstein is requesting the transfer he is still at the home
201 S. Biscayne Boulevard, Suite 1300
Miami, Florida 33131
Phone:
. Fax:
www.RoyBlack.com
EFTA00013858

=== Page 2 ===
Jeffrey Sloman, Esq.
September 1, 2009
Page 2
in Palm Beach following the rules of state community control. As Mr. Epstein's
lawyers, we believe that his request to administratively transfer his community
control is in full compliance with both his state plea agreement and the non-
prosecution agreement with the United States Attorney's Office. Nonetheless we
have taken to heart your previous suggestion of erring on the side of caution and
thus we are advising you of this request.
I am happy to discuss this with you at any time. I did not want to set an
appointment to see you on this issue since I imagine you have more pressing
matters to deal with than a transfer of a state community control matter.
Very 1980ad
Roy Black
RB/wg
Black. Srebnick, Kornspan & Stumpf, P.A.
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=== Page 1 ===
From:
(USAFLS)"
To:
Cc:
Subject: RE: State V. Jeffrey Epstein
Date: Wed, 17 Sep 2008 15:25:14 +0000
Importance: Normal
Given the non-disclosure agreement, aren't we left with telling the SAO that we have agreed to not disclose so it wouldn't
be proper for us to now agree that unsealing is appropriate. Ultimately, it's the SAO's call because they will get the Florida
Public Records Act request and they were not a signatory to the agreement. We should also notify defense counsel so
that they can take whatever actions they believe are appropriate. Wait till others have had a chance to weigh in on this
issue.
From:
(USAFLS)
Sent: Wednesday, September 17, 2008 10:50 AM
To:
(USAFLS)
Cc:
(USAFLS)
Subject: FW: State V. Jeffrey Epstein
Will it never end? Barry Krisher sent the e-mail below to Rolando this morning. How would you like to handle
this issue?
Assistant U.S. Attorney
From:
(USAFLS)
Sent: Wednesday, September 17, 2008 10:48 AM
To:
(USAFLS)
Subject: FW: State V. Jeffrey Epstein
From: Barry Krischer
Sent: Wednesday, September 17, 2008 10:46 AM
To:
(USAFLS)
Subject: FW: State V. Jeffrey Epstein
Please advise how you would like us to proceed. The agreement referred to is the Federal Non-Prosecution agreement
sealed in the file by the judge at the time of the Epstein plea.
From: Lanna Belohlavek
Sent: Tuesday, September 16, 2008 4:21 PM
To: Barry Krischer
Subject: FW: State V. Jeffrey Epstein
EFTA00014118

=== Page 2 ===
How to proceed? Lanna
From: Bryce Albu
Sent: Tuesday, September 16, 2008 3:52 PM
To: Lanna Belohlavek
Cc: Martin Reeder
Subject: State V. Jeffrey Epstein
Ms. Belohlavek,
We represent The Palm Beach Daily News. The newspaper recently discovered that a non-prosecution agreement (and
an addendum thereto) was filed under seal pursuant to an agreed order entered in the above-referenced case. Because
the records are sealed, we cannot assess the propriety of the decision to seal them or even whether the newspaper is
interested in the information contained therein. I was hoping you would discuss with me the nature of the agreement and
the basis for sealing it so that we can advise our client on whether it should pursue an order unsealing the agreement.
Please call me at your earliest convenience.
Very truly yours,
C. Bryce Albu
Reeder & Reeder P.A.
EFTA00014119


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
)"
=
,
)"
Cc:
"
(USANYS)"
Subject: RE: Epstein draft press materials
Date: Wed, 03 Jul 2019 16:08:28 +0000
Importance: Normal
Yes, go for it. Thanks.
From:
Sent: Wednesday, July 3, 2019 12:05 PM
To:
(USANYS)
is
is
)
Cc:
(USANYS)
Subject: RE: Epstein draft press materials
EFTA00010467

=== Page 2 ===
EFTA00010468

=== Page 3 ===
EFTA00010469


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=== Page 1 ===
From:
To:
Subject: Re: Epstein Related
Date: Sun, 15 Sep 2019 13:15:25 +0000
Let's chat tomorrow! I'm generally around and will look for you.
Sent from my iPhone
On Sep 14, 2019, at 7:09 PM,
wrote:
Hey I stopped by your office a couple times Thursday and Friday but didn't catch you, sorry about that -- I'm happy to
chat on Monday if you're around. My guess is that some combination of the press office and brass would make the call,
but I'm totally happy to touch base with you if that's useful in the first instance.
From:
Sent: Thursday, September 12, 2019 10:51
To:
Subject: Epstein Related
Do you have a few minutes today or tomorrow to discuss something? Specifically, a good friend of mine is the executive
producer on a 4-part Netflix series that will come out in a few months on Epstein (they had been working on the story
for 18 months before we charged). He had spoken to
at one point (not sure how that worked!) and wants
to see if anyone from the office would give an interview, all backward looking. I imagine the answer is no but they are
going with this regardless, so thought I would at least make you and potentially chiefs aware of it. Wanted to start with
you. I'm free between now and noon or after 6pm tonight, or tomorrow morning or after lunch. Thanks!
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=== Page 1 ===
From:
=
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To:
(USAFLS)"
Cc:
(USAFLS)"
>,
(USAFLS)"
Subject: RE: New York Post
Date: Mon, 21 Jul 2008 14:02:15 +0000
Importance: Normal
Attachments: 080717_Tein_Goldberger_Ltr.pdf
Yes. Sorry, I forgot to scan it in. It went to Tein and Goldberger on Friday.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
From:
(USAFLS)
Sent: Monday, July 21, 2008 9:41 AM
To:
(USAFLS)
Subject: RE: New York Post
Thanks. Did you finish the letter to Tein?
From:
(USAFLS)
Sent: Monday, July 21, 2008 9:37 AM
To:
(USAFLS);
(USAFLS)
Subject: New York Post
FYI. This came out this morning.
http://www.nypost.com/seven/07212008/gossip/pagesix/bid_to burn epstein plea 120770.htm
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
EFTA00013665


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=== Page 1 ===
Exhibit B
EFTA00011475

=== Page 2 ===
DEPARTMENT OF JUSTICE
AMOUNT DEPA OFFICE OF OFFICE * OF PROFESSIONAL OF WASHINGTON JUSTICE *
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
EFTA00011476

=== Page 3 ===
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.
EFTA00011477

=== 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
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=== 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.
iii
EFTA00011479

=== Page 6 ===
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).
iv
EFTA00011480

=== 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
V
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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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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.
vii
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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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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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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.
xi
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=== Page 14 ===
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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=== Page 1 ===
Event: Epstein Case Meeting with Defense Attorneys
Start Date: 2007-06-26 14:00:00 +0000
End Date: 2007-06-26 16:00:00 +0000
Organizer:
Location: Executive Conference Room
Class: X-PERSONAL
Date Created: 2015-04-04 00:21:57 +0000
Date Modified: 2015-07-22 20:34:54 +0000
Priority: 5
DTSTAMP: 2007-06-05 16:51:25 +0000
Attendee:
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=== Page 1 ===
Event: FW: Epstein Estate
Start Date: 2020-11-09 21:30:00 +0000
End Date: 2020-11-09 22:00:00 +0000
Organizer: Weinstein, Marc A.
Location: Skype Meeting; Conference ID: 570 579 045;
Class: X-PERSONAL
Date Created: 2020-11-09 21:58:35 +0000
Date Modified: 2020-11-09 21:58:35 +0000
Priority: 5
DTSTAMP: 2020-11-09 15:30:14 +0000
Attendee:
Original Appointment
From: Weinstein, Marc A.
Sent: Monday, November 9, 2020 10:35 AM
To: Weinstein, Marc A.;
Andrew Tomback
Subject: Epstein Estate
When: Monday, November 9, 2020 4:30 PM-5:00 PM (UTC-05:00) Eastern Time (US & Canada).
Where: Skype Meeting; Conference ID: 570 579 045;
Dial-In Information (for meetings with no presentations or video)
Dial-In Number:
+1 (201) 630-0824
Conference ID:
570579045
One touch dial-in from mobile phone (via cellular service)
Additional Dial-In Numbers
Brazil
+55 11 3181-5692
Canada
+1 647-749-1240
China
+86 400 842 8305
France
+33 1 73 24 04 53
Germany
+49 69 667737017
India
+91 22 6001 6148
Ireland
+353 1 566 1143
Israel
+972 3 3762055
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Japan
+81 3-4510-7259
Korea (Seoul)
+82 70-7488-2208
Singapore
+65 3157 0147
United Kingdom
+44 20 3443 6288
United States
+1 (201) 630-0824
Full list of dial-in numbers
Meetings with a presentation or video
Connect from computer or mobile device (via network/internet connection)
Help
Try Skype Web App if you are having trouble joining
Joining from a computer using the "Connect from computer or mobile device" link provides
additional capabilities, however you can simply call in from your telephone using the number
provided above if your meeting will not include video or a presentation. Click the "Help" link for
additional information if you are a guest joining a Skype for Business meeting from your
computer or mobile device for the first time.
For meeting organizers: Reset your dial-in PIN?
+1 201-630-0824
[!OC([CUSTOMINVITE])!]
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=== Page 1 ===
From: "
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=JSLOMAN>
To:
(USAFLS)"
>, "Acosta, Alex (USAFLS)"
Subject: Fw: Epstein
Date: Mon, 22 Oct 2007 21:26:08 +0000
Importance: Normal
Fyi
Sent from my BlackBerry Wireless Handheld
Original Message
From:
(USAFLS)
To:
Sent: Mon Oct 22 17:23:30 2007
Subject: Re: Epstein
I have not spoken to him but it was our intention to assign the decision to select a lawyer to Judge Davis not for him to
represent the girls. We do not want to select the lawyer who represents the girls. I don't know who said he'd do it but it
wasn't us.
Sent from my BlackBerry Wireless Handheld
Original Message
From: Jay Lefkowitz
To:
(USAFLS)
Cc: Acosta, Alex (USAFLS);
(USAFLS)
Sent: Mon Oct 22 17:10:00 2007
Subject: Re: Epstein
-- I will review these materials this evening and be in touch with you tomorrow with the expectation of wrapping this up
by the end of the day. One question I have, however, is why you say that Judge Davis is a non-starter. I understood that
he was ready, willing and able to serve as the attorney representative. If you have had conversations with him and that is
not the case, please let me know.
I will go over the other issues you raise in your email and will look forward to speaking tomorrow.
Thanks -- Jay
(USAFLS)"
10/22/2007 04:40 PM
To
"Jay Lefkowitz"
CC
"Acosta, Alex (USAFLS)"
i
(USAFLS)"
Subject
Epstein
EFTA00013619

=== Page 2 ===
Jay,
The Judge Davis issue is a non-starter. We've beaten that horse to death. Regarding your contention that "the attorney
representative be told clearly that Mr. Epstein has agreed to pay the lawyer's hourly rate only for the time he or she spends
working to effectuate settlements for the identified women," Alex and I agree that paragraph 7C is sufficient, Regarding the
other points, we have made the following concessions:
1.
Regarding the language concerning a lawyer whose firm is sizeable enough to litigate multiple trials
simultaneously, I have removed paragraph 4 on page 3 of the letter.
2.
Regarding the 150k statutory limit language, I have included a footnote which should satisfy your concern.
3.
Regarding language there may be discovery to test the claims of alleged "victims", please see new paragraph
4 on page 3 which now states as criteria that the firm should have "Experience litigating against large law firms and high
profile attorneys who may test the veracity of the victims' claims."
I have attached the Addendum and the revised letter to Judge Davis. Jay, this needs to be concluded. Alex and I believe
that this is as far as we can go. Therefore, please advise me whether we have a deal no later than COB tomorrow,
Tuesday, October 23, 2007. Thanks,
Original Message
From: Jay Lefkowitz [mailto:
Sent: Friday, October 19, 2007 4:05 PM
To:
(USAFLS)
Subject: Re:
-
I have reviewed your proposed language and wanted to raise a few areas of concern.
First, I am not sure why we are not just asking Judge Davis to represent these women. If he is available, that would save
us a whole additional layer of process. I had thought that was initially the idea. I am not sure why you seem to be moving
in another direction.
I also cannot understand why the draft affirmatively requests that J Davis select a lawyer whose firm is sizeable enough to
litigate multiple trials simultaneously. That seems to be directly at odds with the purpose of the agreement, which is to
facilitate out of court settlements. Indeed, to the extent any woman were to elect to bring an action against Mr. Epstein,
she would not only be free to select any lawyer of her choice, but would be restricted from using the lawyer representative
in this capacity due to the conflicts of interests that would cause. This part of your proposed language is of signficiant
concern to me.
Your letter also indicates the 150k statutory limit without reference to the pre-existing 50G limit. To be sure, any of the
women are free to seek whatever settlement they want, but given the question that exists about the statutory amount, the
letter should not state definitely that it will be 150k.
In addition, you have omitted a few important items from your proposal. Given that Judge Davis or any other potential
attorney representative should understand the scope of the work, the language should make clear that there may be
discovery to test the claims of alleged "victims."
Finally, I think it is important that the attorney representative be told clearly that Mr. Epstein has agreed to pay the lawyer's
hourly rate only for the time he or she spends working to effectuate settlements for the identified women.
Jay
Original Message
From:
(USAFLS)"
Sent: 10/17/2007 01:58 PM AST
To: Jay Lefkowitz
Subject: RE:
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=== Page 3 ===
<<071015 Special Master Letter2.wpd>> Jay,
Here's our proposed letter to the special master.
Original Message
From: Jay Lefkowitz [mailto:
Sent: Tuesday, October 16, 2007 9:26 AM
To:
(USAFLS)
Subject:
- is there a time today we can speak?
How about 430 pm?
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
EFTA00013621


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=== Page 1 ===
From:
To:
Subject: RE: Question
Date: Thu, 01 Oct 2020 19:53:37 +0000
Attachments: Maxwell_Opposition_v3
docx
From:
Sent: Thursday, October 01, 2020 2:47 PM
To:
Subject: RE: Question
Yes, I have a brief call at 3, but if you call me whenever is best for you after 3:15?
Thanks
From:
Sent: Thursday, October 1, 2020 2:17 PM
To:
Subject: Re: Question
Of course. After 3:00 okay?
On Oct 1, 2020, at 2:08 PM,
wrote:
- Do you have 5 minutes later today to discuss an appeals question? Thanks Tom
Assistant United States Attorney
Southern District of New York
Office:
Cell:
Email:
EFTA00013215


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=== Page 1 ===
Event: Accepted: Call w/ SDNY re: discovery, Epstein investigation
Start Date: 2020-10-23 15:00:00 +0000
End Date: 2020-10-23 15:30:00 +0000
Location: 844-215-6902,, 133318
Class: X-PERSONAL
Comment:
Date Created: 2020-10-22 17:11:58 +0000
Date Modified: 2020-10-22 17:11:58 +0000
Priority: 5
DTSTAMP: 2020-10-22 17:02:26 +0000
Attendee:
EFTA00010300


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=== Page 1 ===
From: "Acosta, Alex (USAFLS)" <AAcosta@usa.doj.gov>
To:
Subject: Read: Tein's Reply Brief in the Epstein civil litigation
Date: Tue, 12 Aug 2008 20:57:27 +0000
Importance: Normal
EFTA00013674


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=== Page 1 ===
From:
"
(USAFLS)"
To:
(USAFLS)"
Bcc:
"
(USAFLS)"
Subject: RE: Jeffrey Epstein Agreement
Date: Wed, 25 Jun 2008 12:39:31 +0000
Importance: Normal
Hi
-- I think I have designed a solution to the 2255 issue and I will call you to discuss the plea. I am still finishing up these search
warrants. As soon as they are done, I will give you a call.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
Original Message
From:
(USAFLS)
Sent: Tuesday, June 24, 2008 9:14 PM
To:
(USAFLS)
Subject: Re: Jeffrey Epstein Agreement
Let's talk about going to the COP
Original Message
From:
(USAFLS)
To: Roy BLACK
>; ; Jack Goldberger
Cc:
(USAFLS)
Sent: Tue Jun 24 16:04:55 2008
Subject: Jeffrey Epstein Agreement
Dear Roy and Jack:
I am just writing to re-state that it is the Government's position that we have a signed, binding agreement and that there is no need for
further modification.
Please keep us informed of the date and time of the change of plea and sentencing.
Thank you.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
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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
November 9, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These materials are
stamped with control numbers SDNY_GM_02767074 through SDNY_GM_02771980.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. The Department of Justice directed this office to cease the dissemination of materials
marked with the word "confidential" in order to avoid potential confusion with markings reserved
for classified documents. Accordingly, in order to note the appropriate designation of this
production under the operative Protective Order in this case, the materials being produced today
are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,
8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective
Order that govern today's production.
An index of the materials contained in this production is below:
EFTA00010017

=== Page 2 ===
Page 2
Bates Start
Bates End
Summary Description
Confidential Designation
SDNY GM 02767074
SDNY GM 02771980
Business Records from SDFL Files1
Confidential
Although the Government believes that all of these materials are also located in the Florida
FBI file and were previously produced to from that file in the fall of 2020, out of an abundance of
caution, the Government is producing these records to you in the form in which they were stored
in the files maintained by the U.S. Attorney's Office for the Southern District of Florida. The
Government recognizes that its discovery obligations are ongoing and will promptly produce any
additional discoverable material of which it becomes aware. Please do not hesitate to reach out if
you have any difficulty accessing these materials.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
1 These materials appear to be largely duplicative of materials previously produced to you in
discovery.
EFTA00010018


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=== Page 1 ===
Case 9:08-cv-80119-KAM Document 65-2 Entered on FLSD Docket 03/25/2009 Page 1 of 1
INDICTMENT
A TRUE BILL 06-9454CF A12
IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA
GLOWED
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT OF THE STATE OF FLORIDA
For Palm Beach County, at the Spring Term thereof, in the year of our Lord Two Thousand and Six, to-wit:
The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their
oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in the Circuit and State
aforesaid,
COUNT ONE
FELONY SOLICITATION OF PROSTITUTION
on or about or between the 1st day of August in the year of our Lord Two Thousand and Four and October 31,
2005, did solicit, induce, entice, or procure another to commit prostitution lewdness, or assignation, contrary to
Florida Statute 796.07(1) on three or more occasions between August 01, 2004 and October 31, 2005,
contrary to Florida Statute 796.07(2)(f) and (4)(c). (3 DEG FEL)(LEVEL 1)
against the form of the statute, to the evil example of all others, and against the peace and dignity of the State
of Florida.
I hereby certify that I have advised the Grand Jury returning this indictment as authorized and required by law.
Assistant State Attorney of the
Fifteenth Judicial Circuit of the State
of Florida, prosecuting for the said
State
GRAND JURY FOREPERSON
DATE
EXHIBIT "A"
Jeffrey E. Epstein, Race: White, Sex: Male, DOB: January 20, 1953, SS#: 090-44-3348; Issue Warrant
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=== Page 1 ===
From:
)"
To: "Singer, Linda"
Subject: Accepted: Call w/ DOJ re. Epstein SDNY Investigation
Date: Fri, 02 Oct 2020 16:17:58 +0000
Importance: Normal
Attachments: unnamed
EFTA00010289


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=== Page 1 ===
CG
800 Third Avenue
COHEN & GRESSER LLP
New York, NY 10022
+1 212 7600 phone
www.cohengresser.com
Christian R. Everdell
October 13, 2020
BY EMAIL
United States Attorney's Office
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear
We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and
Brady material. Based on our review of the government's productions of August 5, 2019, August
13, 2019, and August 21, 2020, we make the following requests for discovery, inspection, and
copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16
of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws
and rules as may be applicable. We are still reviewing these productions, as well as the
government's most recent production of October 2, 2020, and reserve the right to supplement
these requests as necessary.
1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside from
the statements made in prior civil case proceedings that you produced on August 13,
2020 and the statements made at the time of arrest, which you produced on August 21,
2020. Fed. R. Crim. P. 16(a)(1)(A), (B).
2. We request that the government disclose and identify any statements of alleged co-
conspirators that it intends to introduce at trial.
3. We request any prior criminal records of Ms. Maxwell. Fed R. Crim. P. 16(a)(1)(D).
4. We request any books, papers, documents, data, photographs, tangible objects,
buildings or places, or copies or portions of any of these items. Fed R. Crim. P.
16(a)(1)(E).
EFTA00011418

=== Page 2 ===
October 13, 2020
Page 2
a. Based on our review of the discovery, it does not appear that any documents or
tangible objects were obtained from Ms. Maxwell through a search warrant or a
search incident to arrest. Please confirm this.
b. We will schedule a time in the near future to inspect the originals of
photographs and any other evidence (including documents and tangible objects)
that have already been disclosed.
5. We request the results or reports of any physical or mental examination and of any
scientific test or experiment. Fed R. Crim. P. 16(a)(1)(F).
6. We request a written summary of any testimony that the government intends to
introduce at trial under Federal Rules of Evidence 702, 703 or 705, which summary
must describe the witness's opinions, the bases and reasons for those opinions, and the
witness's qualifications. Fed R. Crim. P. 16(a)(1)(G).
7. We request that the government disclose the identities of the individuals identified in
the indictment as Minor Victims 1-3.
8. We request that the government disclose the complete birthdays of the individuals
identified in the indictment as Minor Victims 1-3.
9. We request all written and oral communications concerning the negotiations relating to
the Non-Prosecution Agreement ("NPA") signed by Jeffrey Epstein on September 24,
2007. Such communications include:
a. All communications between the government - including, but not limited to,
attorneys and staff at the U.S. Attorney's Office for the Southern District of
Florida, the United States Attorney's Office for Southern District of New York,
the Department of Justice, state prosecutor's offices, the FBI, and any other
federal and state investigative agencies - and Mr. Epstein's attorneys.
b. All communications between and among any government employees including,
but not limited to, attorneys and staff at the U.S. Attorney's Office for the
Southern District of Florida, the United States Attorney's Office for Southern
District of New York, the Department of Justice, state prosecutor's offices, the
FBI, and any other federal and state investigative agencies.
c. Unredacted copies of all emails and other correspondence between the
government and Mr. Epstein's attorneys concerning the negotiation of the NPA,
which you previously produced on August 13, 2020. See, e.g.,
SDNY_GM_00134069 et seq.
EFTA00011419

=== Page 3 ===
October 13, 2020
Page 3
10. We request that the government produce a complete copy of the diary, only seven
pages of which were produced by the government on August 21, 2020. See
I
11. We request a complete, unredacted copy of the FBI 302 produced by the government
on August 13, 2020, bearing Bates numbers SDNY_GM_00114982-00114993.
12. We request that the government produce all versions and drafts of the book/memoir
"The Billionaires Playboy Club" produced by the government on August 13, 2020, and
identify the dates of each version/draft. See, e.g., SDNY_GM_00117607-608,
00117626-635, 00117637-640, 00117726-727, 00117761-762, 00117836-837 (sample
list).
13. We request the following documents and materials related to the individuals identified
in the indictment as Minor Victims 1-3 and for any other witness who has alleged that
Ms. Maxwell engaged in or facilitated improper sexual conduct at any time up to the
present:
a. All diaries, notes, journals, e-mails, text messages, letters, or other writings by
these individuals, including but not limited to, all written communications
between these individuals and Mr. Epstein or Ms. Maxwell;
b. All travel and immigration records, as well as copies of any passports and travel
documents;
c. All school records or other educational records;
d. All phone records;
e. All photographs;
f. All financial records, including all records reflecting any payments or money
transfers from Mr. Epstein or his associated businesses to these individuals or
their family members or their counsel;
g. All police reports or complaints to law enforcement authorities filed by these
individuals;
h. Any submissions to the Epstein Victims' Compensation Program made by any
of these individuals;
i. All communications between or among these individuals, or between these
individuals and counsel for any other such individual, including but not limited
to, emails, text messages, social media posts, and other correspondence;
j. All public statements made by these individuals concerning Mr. Epstein or Ms.
Maxwell;
k. Any record or report of any physical, medical, mental, or psychological
examination of these individuals;
I We also make this request, as well as Requests 11-16, pursuant to the government's Brady obligations.
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=== Page 4 ===
October 13, 2020
Page 4
1. Any record, report or other document reflecting the use or abuse of alcohol or
any legal or illegal drug, including marijuana;
m. All written and oral communications between the government and the attorneys
for these individuals - including but not limited to,
, David
Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell,
Spencer Kuvin, and
(the "Attorneys") - concerning or relating to
Mr. Epstein and/or Ms. Maxwell.
14. We request all written and oral communications and other documents concerning any
meetings between the Attorneys and prosecutors and staff from the United States
Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey
Epstein and/or Ghislaine Maxwell.
a. This request includes all communications and documents related to any
meetings that took place in or about 2016 in which certain of the Attorneys met
with SDNY prosecutors to ask SDNY to initiate a criminal investigation into
Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal
Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in
2016: Sources" (Oct. 13, 2020), https://www.nydailynews.com/new-york/ny-
jeffrey-epstein-maxwell-case-20201013-jmzhl7zdrzdgrbbs7yc6bfnszu-
story.html ; see also
Relentless Pursuit: My Fight for the
Victims of Jeffrey Epstein, at 281.
b. This request also includes all communications and documents related to any
meetings between any of the Attorneys and SDNY prosecutors and staff
concerning or relating to Mr. Epstein and/or Ms. Maxwell that took place in or
about 2018, when the government asserts that it began the SDNY investigation
into this case (see Dkt. 63), or at any time thereafter.
15. We request the complete FBI's case file regarding the investigation of
for obstruction of justice, referenced in the government's production cover
letter of August 21, 2020.
16. We request copies of the "82-page pros memo and 53-page indictment" drafted as part
of the investigation conducted by the Southern District of Florida. See
SDNY_GM_00131226.
17. We request all e-mails, text messages, letters, or other written communications to or
from Ms. Maxwell.
18. We request all medical records or reports concerning Mr. Epstein.
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=== Page 5 ===
October 13, 2020
Page 5
19. We request all subpoenas and voluntary request for production of documents issued in
connection with or related to this case, and all evidence obtained by the government by
subpoena or from voluntary production (to the extent it has not already been produced),
including information to identify where and how the evidence was obtained.
20. We request that the government disclose and identify any evidence it intends to
introduce under Federal Rule of Evidence 404(b) or as background of the conspiracies
charged in the Indictment.
21. We request information about the composition of the grand jury that indicted this case,
including a list of grand jurors, their attendance dates, the reasons for any absence, and
whether attendance was in person or virtual.
22. We request that the government disclose whether any persons were present during
grand jury proceedings other than the grand jurors, witnesses under examination, court
reporters, and attorneys from the United States Department of Justice.
Consistent with the requirements of Brady V. Maryland, 373 U.S. 83 (1963) and Kyles V.
Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that
the government conduct an affirmative search for, locate, identify, and produce, all documents,
books, papers, photographs, scientific tests or experiments, tangible objects, written or recorded
statements, grand jury transcripts and oral statements, reports, memoranda, names, and addresses
or persons or other evidence or information favorable to the defense as to either guilt or
punishment, or tends to affect the weight or credibility of the evidence to be presented against Ms.
Maxwell, or which will lead to evidence favorable to or exculpatory of Ms. Maxwell, including
but not limited to information which is within the possession, custody, or control of the
government. Impeachment evidence, as well as exculpatory evidence, falls within Brady's
definition of evidence favorable to the accused. See United States V. Bagley, 473 U.S. 667 (1985);
United States V. Agurs, 427 U.S. 97 (1976). We also make the following specific Brady requests:
1. Exculpatory Evidence: We request all such evidence requested above and evidence
known to the government which tends to exculpate Ms. Maxwell of the offense
alleged, including exculpatory statements. This request includes, but is not limited to:
a. Any statements or written communications made by any witness who has
alleged that she was sexually abused or assaulted by Mr. Epstein, but has not
alleged that Ms. Maxwell participated in, was involved in, or facilitated the
alleged sexual abuse. These include, but are not limited, to, all diaries, notes,
journals, e-mails, text messages, letters, or other writings by these individuals.
b. Any evidence suggesting that Ms. Maxwell was not involved in or aware of the
conduct alleged in the indictment.
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=== Page 6 ===
October 13, 2020
Page 6
c. Any evidence concerning witnesses who have contacted the government or law
enforcement authorities about alleged sexual abuse by Mr. Epstein or Ms.
Maxwell who were determined not to be credible.
d. Any evidence suggesting that any witness who has alleged that she was
sexually abused or assaulted by Mr. Epstein, with or without the involvement of
Ms. Maxwell, was not a minor at the time the alleged sexual abuse took place.
e. All investigative efforts to verify any information provided by any and all
witnesses, where such efforts were negative.
f. All discussions with any witness, including law enforcement, that reveal Brady
information.
2. Favorable Statements and Witnesses: We request that the government produce any
witness statements favorable to Ms. Maxwell, and identify the names of any witnesses
who have information favorable to Ms. Maxwell. This includes any witness who the
government does not intend to call at trial, but who made a favorable statement
concerning Ms. Maxwell.
3. Evidence of Criminal Investigation of Any Government Witness: We request any
evidence that any prospective witness is under investigation by federal, state or local
authorities for any criminal conduct. This includes their entire criminal record (both
arrests and convictions, whether adult or juvenile) and probation reports, supervised
release, pre-sentence reports, violation reports, intelligence reports and all
supplementals.
4. Evidence of Misconduct of Government Agents: We request information about any
allegation of misconduct of any government agents or attorneys involved in any
investigation into Mr. Epstein and Ms. Maxwell.
5. Impeachment Evidence: We request any evidence that may be used to impeach a
prospective government witness. This request includes, but is not limited to:
a. Any evidence that any prospective government witness has engaged in any
criminal act, whether or not resulting in a conviction, and whether any witness
has made a statement favorable to Ms. Maxwell.
b. Any information tending to establish that the witness is or was a user of any
drug or alcohol and any other information which tends to discredit the witness's
ability to perceive, recollect and/or narrate events.
EFTA00011423

=== Page 7 ===
October 13, 2020
Page 7
c. Any information concerning any government witnesses' history of emotional
disorders and psychiatric or psychological counseling, which may bear on a
witness's ability to perceive or relate events accurately and truthfully.
d. Any evidence suggesting that any witness who has alleged that she was
sexually abused or assaulted by Mr. Epstein, with or without the involvement of
Ms. Maxwell, had a financial motive or incentive to accuse Mr. Epstein or Ms.
Maxwell.
6. Giglio Information: Pursuant to Giglio V. United States, 405 U.S. 150 (1972), we
request dates and descriptions of any and all considerations or promises (express or
implied) of consideration given during the course of the investigation by any law
enforcement officials to or on behalf of any witness the government intends to call at
trial, or any such consideration or promises expected by any such witness in the future.
This includes but is not limited to the following:
a. Rewards, monetary or otherwise;
b. Employment;
c. Protection and relocation;
d. The rejection, dismissal, immunization from prosecution or reduction of any
federal, state or local offenses charged in the past or present or that might be
charged in the future;
e. Reduction of sentence, improvement of custody status or leniency at sentencing
by making the witnesses' cooperation known to the prosecution, Court,
probation or parole officer, or other federal, state or local agency or jurisdiction;
f. Other incidents of cooperation.
7. Evidence of Bias or Motive to Lie: We request any evidence that any prospective
government witness is biased or prejudiced against Ms. Maxwell or has a motive to
falsify or distort his or her testimony. Pennsylvania V. Ritchie, 480 U.S. 39 (1987);
United States V. Strifler, 851 F.2d 1197 (9th Cir. 1988).
8. Contradictory Statements: We request all prior contradictory statements of any
prospective government witness. Giles V. Maryland, 386 U.S. 66 (1967).
9. Statements Relevant to the Defense: We request disclosure of any statement that may
be "relevant to any possible defense or contention" that Ms. Maxwell might assert.
10. We request any other materials or documents not otherwise accounted for in other
requests herein that arguably reflect the (i) motivation of any government witness to
cooperate with the prosecution team, (ii) the competency or credibility of the witness,
or (iii) the witness's bias or hostility against Mr. Epstein or Ms. Maxwell.
EFTA00011424

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October 13, 2020
Page 8
Please note that under both Federal Rule of Criminal Procedure 16(c) and Brady, the duty
to disclose is a continuing one, and you must disclose promptly any additional discovery evidence,
information, or material of which you or any member of the prosecution team become aware.
In the event that you are unable or unwilling to provide the information and documents
requested in this letter, please advise us by October 21, 2020, so that we may file any necessary
motions with the Court.
Thank you in advance for your attention to these matters.
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
cc:
Mark S. Cohen, Esq.
Jeff Pagliuca, Esq.
Laura Menninger, Esq.
Bobbi C. Sternheim, Esq.
EFTA00011425


