# docs_fts_content

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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From:
Date: August 2, 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: August 17, 2021
Time: 2 PM
Witness Needed to Appear for:
Trial ( )
Date:
Grand Jury ( )
Date:
Trial Prep (X)
Date: August 17, 2021 at 2 PM, and August 18, 2021 at 10 AM
Estimated Dates Witness will Arrive:
August 16, 2021 (evening)
Depart:
August 18, 2021 (evening)
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
kennel fees for pets
rev. 2019.11.19
EFTA00027392

=== Page 2 ===
necessary travel companion
extra baggage (more than one bag)
Please describe the unusual expense:
For Victim-Witness Coordinator:
1. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW
is apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should
be used.
For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to
court/GJ testimony.
Witnesses may only be brought in under the FEWS appropriation for grand jury testimony that
has been scheduled and where the witness is expected to testify before the grand jury; court
testimony; or preparation for same. Any other witness travel, e.g., for investigative interviews,
must be covered by the investigating component from litigative funds. See Ed Tyrrell.
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
EFTA00027393


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=== Page 1 ===
From:
)"
To:
)"
"
,
(USANYS)"
Subject: 2020-10-07 GM letter to Judge Nathan re discovery from other agencies (FINAL). pdf
Date: Mon, 04 Oct 2021 03:17:41 +0000
Attachments: 020-10-07_GM_letter_to_Judge_Nathan_re_discovery_ffom_other_agencies_(FINAL).pdf
EFTA00029199


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=== Page 1 ===
From:
=
)"
To:
(USANYS)"
Subject: Accepted: Pre-Meeting US V Noel/Epstein FOIA
Date: Sun, 27 Jun 2021 23:21:58 +0000
Importance: Normal
Attachments: unnamed
EFTA00029529


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=== Page 1 ===
From: "NYSReportServer@usa.doj.gov" <NYSReportServer@usa.doj.gov>
To:
Subject: Child Exploitation & Porn Update Report III
Date: Thu, 25 Feb 2021 16:43:36 +0000
Attachments: Child_Exploitation_&_Porn_Update_Report_II.pdf
Attached is the Child Exploitation & Porn Update Report III for Project Safe Childhood.
Chiefs and Project Safe Childhood Coordinator, please remind the assigned AUSA to make updates in their
cases. Thanks!
EFTA00028708


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=== Page 1 ===
From:
"
)"
To:
(CRM)"
Subject: RE: DC USAO Directory
Date: Fri, 11 May 2018 16:12:09 +0000
Importance: Normal
Attachments: USAODC_phone_directory_as_of_11.17.pdf
Safe travels! And thanks very much anyway.
From:
(CRM)
Sent: Friday, May 11, 2018 11:06 AM
To:
Subject: RE: DC USAO Directory
From:
) [mailto:
Sent: Friday, May 11, 2018 10:58 AM
To:
(CRM)
Subject: DC USAO Directory
Do you by any chance have a directory for the DC USAO? I have no idea why but a colleague up here was asking for it.
U.S. Attorney's Office for the Southern District of New York
1 St. Andrew's Plaza, New York, New York 10007
Desk:
EFTA00028002


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=== Page 1 ===
Case 1:19-cr-00373-PGG Document 176 Filed 01/20/20 Page 1 of 3
LAW OFFICES
SCOTT A. SREBNICK, P.A.
SCOTT A. SREBNICK
201 S. Biscayne Boulevard
* ALSO ADMITTED IN NEW YORK
Suite 1210
Miami, Florida 33131
January 20, 2020
Tel: 305-285-9019
Fax: 305-377-9937
E-mail: scott@srebnicklaw.com
www.srebnicklaw.com
Via ECF
Honorable Paul G. Gardephe
United States District Judge
Thurgood Marshall U.S. Courthouse
40 Foley Square
New York, NY 10007
Re: United States V. Avenatti, No. S1 19 Cr. 373 (PGG)
Letter Concerning Mr. Avenatti's Prison Conditions
Dear Judge Gardephe:
We write to inform the Court of Mr. Avenatti's conditions as a pretrial detainee and to
request that the Court inquire into his custody status and direct the Bureau of Prisons to
consider his immediate removal to general population. Under Mr. Avenatti's current
conditions of confinement, we cannot effectively prepare for trial and Mr. Avenatti cannot
meaningfully assist in his defense.
As the Court is aware, Mr. Avenatti was remanded into custody last week, at the request
of the United States Attorney for the Central District of California, on the theory that Mr.
Avenatti violated his bail conditions in the CDCA because of financial transactions that
prompted the prosecutors there to claim that he was an "economic danger." There was no
allegation that Mr. Avenatti was a risk of flight or that he posed a physical danger to anyone
or to himself.
On Friday, January 17, 2020, after spending three nights in the Santa Ana jail, under
solitary confinement conditions, Mr. Avenatti was flown from California to New York. Since
then, he has been housed in the Special Housing Unit on the notorious 10-South of the MCC-
New York. It is the most secure floor in the entire facility. He is in a cell reportedly once
occupied by El Chapo, on a floor that houses individuals charged with terrorism offenses. He
is apparently under special administrative measures (SAMs), which almost completely
restricts his communications with the outside world. He has been locked down for 24 hours a
day, in solitary confinement, except for attorney visits and two medical exams. There is an
officer outside his cell 24 hours a day and two cameras focused on him. Mr. Avenatti was
permitted two social calls upon arriving at the facility, but none since. He was told that his
classification entitles him to one pre-scheduled social call per month. The temperature in his
cell feels like it is in the mid-40s. He is forced to sleep with three blankets. Not surprisingly,
he has been having great difficulty functioning. He has not been permitted to shave. We do
not know the reason why he has been confined in the SHU, under SAMs.
EFTA00029584

=== Page 2 ===
Case 1:19-cr-00373-PGG Document 176 Filed 01/20/20 Page 2 of 3
Upon learning that Mr. Avenatti had been moved to MCC-New York, undersigned
counsel (Scott Srebnick) traveled to New York early Saturday morning (January 18). That
afternoon, Ms. Perry and I visited Mr. Avenatti at the facility. We arrived at 2pm and left just
before 7pm. We were required to visit with him in the SHU, not in the legal visiting room on
the third floor. The visit was a non-contact legal visit, which means we communicated with
Mr. Avenatti through a partition that was part screen / part glass. We were told that such was
the protocol of the Special Housing Unit. There was no opening in the glass/screen partition
for us to hand Mr. Avenatti documents to review, or for him to make notes on a document, and
we were not authorized to do so in any event. Although the officers allowed Mr. Avenatti to
review a document at our request at the beginning of our visit, if we wanted him to review any
additional documents, it would have required us to disturb the busy officers and have them
repeatedly transfer documents back and forth. That was untenable.¹ While we were told that
certain accommodations can be made for inmates in the SHU - at the discretion of legal staff
- we were told that legal staff would not return until Tuesday, January 21 (after the holiday),
so that no meaningful changes could be made until then (at the earliest).
On Saturday night, I communicated with government counsel regarding Mr. Avenatti's
situation and have been in regular communication with government counsel throughout the
weekend and today. While government counsel have made several inquiries at my request to
determine whether any accommodations could be made in the interim, the bottom line is that
his conditions have not changed.² I visited with Mr. Avenatti on Sunday and again today, both
times for several hours. Reviewing documents together through the partition is challenging to
say the least. It takes many times longer to review documents and make decisions. Needless
to say, Mr. Avenatti wants to have an active role in his own defense. That is simply not feasible
under these conditions. And, inasmuch as I cannot prepare responses to the various
government filings while I am visiting with Mr. Avenatti, the additional time that it takes to
visit with him has made it inordinately difficult to deal with the multiple issues in the case.
In the meantime, the government has made four additional productions of discovery
since Mr. Avenatti was remanded last week. The new discovery apparently includes
recordings of Mr. Avenatti's testimony at bar proceedings. Mr. Avenatti has not reviewed any
of the new discovery, much less the new recordings, and we have no idea how, when, or under
what conditions he will be able to review the new materials. Moreover, we have exchanged
with the government drafts of transcripts of the recordings that are at the center of this case -
the telephone call and meeting between Mr. Avenatti and the Nike lawyers. We have not yet
1 To be clear, all of the officers at MCC-New York with whom we, and Mr. Avenatti, have
interacted have been professional, respectful and courteous. The circumstances we describe herein
are not at all a criticism of the corrections officers, but rather a reflection of the reality of his
placement in the SHU.
2 The one accommodation is that today I was permitted to leave a small amount (some three inches
worth) of the recent discovery with the officers in SHU for them to determine later whether to
allow Mr. Avenatti to have the documents in his cell. As I write this letter, I do not know whether
he was allowed to review the documents.
EFTA00029585

=== Page 3 ===
Case 1:19-cr-00373-PGG Document 176 Filed 01/20/20 Page 3 of 3
been able to meaningfully review the government's version of the transcripts with Mr. Avenatti
and we do not know when he will be able to review those transcripts while simultaneously
listening to the recordings. Perhaps we will know more tomorrow, when the legal staff returns.
Although, as mentioned earlier, we have been in communication with government
counsel to help address these difficult conditions (and counsel has been as helpful as they can
be), we bring this matter to the Court's attention today to seek the Court's assistance given the
Court's desire - and ours -- to commence the trial of this matter as soon as possible. Our
principal ask is that Mr. Avenatti be moved to general population, where he has the same
ability to confer with counsel as other pretrial detainees. While we understand that there may
be hypersensitivity about Mr. Avenatti given the profile of the case, and recent issues at the
institution, this situation is truly hampering our ability to prepare for trial. We ask that
accommodations be made consistent with his right to a fair trial and to be "afforded reasonable
opportunity for private consultation with counsel." 18 U.S.C. §3142(i)(3). Specifically, we
ask at a minimum that Mr. Avenatti: 1) be allowed to keep legal materials in his cell; 2) have
access to a computer, like other pretrial detainees, to review discovery similar to other pretrial
detainees; 3) have contact legal visits in the regular attorney visiting room, where we can
review documents and freely communicate with him; and 4) have the same social call
privileges as detainees in general population so that he can communicate with his family to
help make arrangements with third parties to fund his defense.
Respectfully,
/s/ Scott A. Srebnick
Scott A. Srebnick
Jose M. Quinon
E. Danya Perry
EFTA00029586


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=== Page 1 ===
From:
To:
Cc:
Subject: GM -
Date: Mon, 04 Oct 2021 20:19:49 +0000
Attachments: 3501.116-007.pdf; 3501.116-012.pdf
I'm attaching the 302 for
from an interview on August 22, 2006. Do we have the notes? The last paragraph
refers to her providing a copy of the hours she worked at Epstein's residence as well as some notes she made at her time
of employment. Do we have those documents? I can also check with
- let me know please. 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
EFTA00029223


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=== Page 1 ===
90A-NY-3151227 Serial 41
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Derivative
Date: 08/16/2019
Evidence NYC027714
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) CART-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Derivative Evidence NYC027714: One (1) Seagate
Barracuda 1000GB HDD, ST1000DM003, S/N S1D9DETC, containing the Clone
Copy of 1B17 hard drive (Seagate Constellation ES 500GB HDD, ST500NM0011,
S/N Z1M1L0YG), collected via Tableau TD3-B, S/N 11D350F0-1525. Request ID
112048. Derivative Copy.
Item Type
Description
1B Digital
(U) NYC027714: One (1) Seagate Barracuda 1000GB HDD,
ST1000DM003, S/N S1D9DETC, containing the Clone Copy of
1B17 hard drive (Seagate Constellation ES 500GB HDD,
ST500NM0011, S/N Z1M1L0YG), collected via Tableau TD3-B,
S/N 11D350F0-1525. Request ID 112048. Derivative Copy.
Collected On: 08/12/2019 07:00 PM EDT
Seizing Individual:
Located By:
Device Type: Hard Drive
Designation: Derivative
Number of Devices Collected: 1
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00027963

=== Page 2 ===
90A-NY-3151227 Serial 41
UNCLASSIFIED
Title: (U) Submission of CART Derivative Evidence NYC027714
Re: 90A-NY-3151227, 08/16/2019
UNCLASSIFIED
2
EFTA00027964


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 198 Filed 04/08/21 Page 1 of 1
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 4/8/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
The Defendant's request to adjourn the arraignment on the S2 Superseding Indictment is
GRANTED. Dkt. No. 194. The arraignment is RE-SCHEDULED to occur on April 23, 2021 at
2:30 p.m. It will take place at the Daniel Patrick Moynihan Courthouse, 500 Pearl Street,
Courtroom 24B, New York, NY 10007.
It is ORDERED that the parties ensure that all participants comply with the Southern
District of New York's COVID-19-related orders that govern entry into and behavior within
SDNY courthouses. These materials may be found at: https://www.nysd.uscourts.gov/covid-19-
coronavirus.
Court staff are working on the logistical arrangements related to public access (including
a public dial-in number), and as soon as that information is available it will be provided in a
public order.
so ORDERED.
Alim D. Netto
Dated: April 8, 2021
New York, New York
ALISON J. NATHAN
United States District Judge
EFTA00027267


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=== Page 1 ===
From:
To:
Subject: Re: Potential Victim
Date: Tue, 09 Jul 2019 13:18:28 +0000
Importance: Normal
What are the issues? I won't be in for about 20 min.
Sent from my iPhone
> On Jul 9, 2019, at 9:14 AM,
wrote:
>
> I just got a call from
on this and other issues. Can we circle up in about 15 or 20 minutes?
V
V
Sent from my iPhone
V
>>
On Jul 8, 2019, at 8:54 PM
wrote:
Thanks,
We'll follow up.
>>
Sent from my iPhone
On Jul 8, 2019, at 8:38 PM
wrote:
The CSOs received a telephone call from a female who identified herself as
who
allegedly has information about Epstein.
gave a return number of
EFTA00028315


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Cc:
(USANYS) [Contractor]"
Subject: Maxwell VW Page
Date: Thu, 16 Jul 2020 01:48:57 +0000
Should we be updating to the page to reflect yesterday's hearing and order? Let me know if this works:
July 14, 2019 update:
On July 14, 2019, the initial conference, arraignment, and bail hearing were held in the case of United States v.
Ghislaine Maxwell, 20 Cr. 330 (AJN). The defendant entered a plea of not guilty to the Superseding Indictment. The
court announced its ruling that the defendant will be incarcerated pending trial. The Court scheduled discovery and
motion deadlines for counsel as well as trial date for July 12, 2021, before the Honorable Alison J. Nathan, United
States District Judge for the Southern District of New York, Thurgood Marshall United States Courthouse, 40 Foley
Square, New York, New York, in Courtroom 906.
Sent from my iPad
EFTA00028774


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=== Page 1 ===
From:
(USANYS)"
To:
Cc:
)"
)"
Subject: FW: U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Thu, 29 Apr 2021 19:27:37 +0000
Attachments: Letter_re-_Sleep_Deprivation-4-29-21.pdf
Hi all,
Attached please find a letter just filed by Maxwell's counsel regarding sleep deprivation. She asks "the Court to address
Ms. Maxwell's sleeping conditions by directing the MDC to cease 15-minute light surveillance of Ms. Maxwell or justify the
need for the disruptive flashlight surveillance." Judge Nathan has not yet ordered any response but we wanted to send
this along to you. Please let us know if a call would be useful.
Thanks,
From: BOBBI C STERNHEIM
Sent: Thursday, April 29, 2021 3:01 PM
To:
is
>;
(USANYS)
is
Cc: Christian Everdell
>; Laura Menninger
>; Jeff Pagliuca
Subject: U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Good afternoon-
Attached is a courtesy copy of today's ECF fling.
Regards-
Bobbi
BOBBI C. STERNHEIM, ESQ.
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
EFTA00029134

=== Page 2 ===
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.
EFTA00029135


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=== Page 1 ===
From: "
)"
To: Jill Greenfield
Cc:
"
)"
Bcc:
"
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Date: Tue, 06 Oct 2020 19:20:42 +0000
Embedded: RE:_Epstein_[FFW-DOCS.FID6003375].msg
Sender:
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Message-Id:
<CY1P110MB04862712D9BD8EC4E16154D0840D0@CY1P110MB0486.NAMP110.PROD.OUTLOOK.CO
M>
Cc:
EFTA00028128


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=== Page 1 ===
From:
"
To:
Subject: sars
Date: Thu, 12 Sep 2019 03:41:19 +0000
Attachments: epstein_transcripts.pdf
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00029309


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=== Page 1 ===
Case 1:19-cr-00490-RMB Document 48 Filed 08/21/19 Page 1 of 1
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
X
DATE FILED: 8/21/19
UNITED STATES OF AMERICA,
Government.
ORDER
-against-
19 Cr 490
JEFFREY EPSTEIN,
Defendant.
x
The Court will conduct a brief hearing on Tuesday, August 27, 2019 at 10:30 a.m. in
connection with the nolle prosequi order proposed to the Court on August 19, 2019 by the United
States Attorney.
The Court believes that where, as here, a defendant has died before any judgment has
been entered against him, the public may still have an informational interest in the process by
which the prosecutor seeks dismissal of an indictment.
At the hearing, Counsel for the Government and for the deceased Defendant, Jeffrey
Epstein, will be heard. Counsel for the victims and the victims will also be heard, if they wish to
be.
The hearing will be held in Courtroom 17B.
Dated: New York, New York
August 21, 2019
RMB
RICHARD M. BERMAN, U.S.D.J.
EFTA00028549


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=== Page 1 ===
From:
To:
Bcc:
Subject:
Date:
Monday, December 16, 2019 7:02:00 PM
Dear
Please excuse the informality but I am an old experienced civil trial attorney. Luckily,
I never have represented any client in criminal matters.
just contacted my office and said that you dropped by her apartment. She was a former
client. She would like to cooperate but I have my professional responsibility to make some inquiry
about events that were so long ago.
Regarding the Epstein matter she is definitely a victim and I hope that you are aware of this fact.
That being said is she a target in any ongoing investigation?
Let me know and we can figure a good time to meet and potentially whether or not I am competent
to represent her.
Thank you,
9150 Wilshire Blvd., Suite 241
Beverly Hills, California 90212-3429
CONFIDENTIALITY
This e-mail is for the personal and exclusive use of the recipient(s) named above. It contains confidential information from
Its contents are not only to remain absolutely confidential, but may also be subject to the attorney-client privilege or coverage under the work-product
doctrine. If you have received this transmission and are not the intended recipient(s) or his/her agent, please be advised that any disclosure, use,
review, copying, selling, dissemination, publication, or distribution of this transmission is strictly unauthorized and prohibited. If you have received this
transmission in error, please notify the sender at the number above, return the original e-mail by mail, and delete the e-mail file from your computer.
EFTA00029197

=== Page 2 ===
Postage is guaranteed. Your cooperation is appreciated. Thank you.
EFTA00029198


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=== Page 1 ===
Date:
08/13/2019
Location: DC
Time:
07:22 AM
Federal Bureau of Prisons
TRUVIEW
Inmate Detail Report
Sensitive But Unclassified
Reg #: 76318054
2M
INCHES
78
Inmate Last Name: EPSTEIN
Inmate First Name: JEFFREY
90
75
DOB: 1/20/1953
80
72
Sex:
Race:
70
Ethnicity:
Alpha Code: NYM
60
3
Unit: NYM-Z-A
50
Quarters: Z04-206LAD
Status: Inactive
40
Location Code: NYM
Account Creation Date: 7/6/2019
TRUFACS Balance: $566.27
TRUFONE Balance: $0.00
TRULINCS Balance: $0.00
User ID: GOV0100
Page 1 of 2
EFTA00027102

=== Page 2 ===
Date: 08/13/2019
Location: DC
Time:
07:22 AM
Federal Bureau of Prisons
TRUVIEW
Inmate Detail Report
Sensitive But Unclassified
AKAs/Nicknames
Security Threat Groups
Name Type
Last Name
First Name
Assignment
Description
No Data
No Data
Current Charges
Charge
No Data
ARS History
Facility
Assignment
Assignment Description
Start Date
Stop Date
No Data
User ID: GOV0100
Page 2 of 2
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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: NYTimes.com: Jeffrey Epstein, Blackmail and a Lucrative 'Hot List'
Date: Sun, 01 Dec 2019 02:49:28 +0000
From The New York Times:
Jeffrey Epstein, Blackmail and a Lucrative 'Hot List'
A shadowy hacker claimed to have the financier's sex tapes. Two top lawyers wondered: What would the men in
those videos pay to keep them secret?
https://www.nytimes.com/2019/11/30/business/david-boies-pottinger-jeffrey-epstein-videos.html
EFTA00029251


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=== Page 1 ===
From:
To:
Subject: 21-58 United States of America V. Maxwell "Certificate of Service FILED"
Date: Thu, 15 Apr 2021 22:20:15 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 04/15/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Document(s): Document(s)
Docket Text:
CERTIFICATE OF SERVICE, for Notice of Motion to Withdraw As Appellate Counsel and Affirmation of
In Support Of Motion To Be Relieved As Counsel, on behalf of Appellant Ghislaine
Maxwell in 21-58, 21-770, FILED. Service date 04/15/2021 by CM/ECF.[3079010] [21-58, 21-770]
Notice will be electronically mailed to:
Mr.
, Assistant U.S. Attorney:
,
Ms. Bobbi C. Sternheim, -:
Assistant U.S. Attorney:
Assistant U.S. Attorney:
Ms.
-:
, Deputy Clerk:
Notice will be stored in the notice cart for:
,
Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Certificate of Service FILED
Original Filename: Certificate of Service_Affirmation in Support of Motion to Be Relieved As Appellate
Counsel.pdf
Electronic Document Stamp:
EFTA00027563

=== Page 2 ===
[STAMP acecfStamp ID=1161632333 [Date=04/15/2021] [FileNumber=3079010-0]
315af86c26651c73e495afdfdd1141511b]]
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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: Re:
- Epstein
Date: Mon, 08 Jul 2019 02:13:20 +0000
Importance: Normal
Morning is wide open for me.
On Jul 7, 2019, at 10:11 PM,
)
wrote:
I'm free, but if possible can we do it a bit earlier, so we have time to brief the Florida approach agents? I think they fly
out Tuesday afternoon (but I could be wrong about that).
From:
Sent: Sunday, July 7, 2019 10:10 PM
To:
is
)
Subject: FW:
- Epstein
10:30 okay for you guys on Tuesday?
From: Joe Nascimento
Sent: Sunday, July 07, 2019 18:51
To:
Cc:
is
)
Subject: Re:
)
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you. Let's set a time for Tuesday
morning (the earlier the better for me). Let me know what works for you.
Thanks,
Joe
Sent from my iPhone
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
EFTA00028367

=== Page 2 ===
On Jul 7, 2019, at 4:04 PM,
)
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak with you. I expect our schedules may
be somewhat unpredictable tomorrow; would it work to set a time to talk on Tuesday? We can schedule it for before
you meet with
if that's helpful. Or if you'd like to talk sooner, we could schedule a time later today, or check
in tomorrow about a possible afternoon discussion. Please let us know what you prefer, and we look forward to being
in touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
Sent: Saturday, July 06, 2019 22:55
To:
)
Subject:
- Epstein
Begin forwarded message:
From:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
Cc:
Subject:
)
- Epstein
My former partner, Alan Ross, represented
prior to his passing in
2018. Agent
served
with a grand jury subpoena earlier today, and as Alan's former
partner and FL Bar appointed inventory attorney, she has contacted me. Unfortunately, I am unable to meet
with her until Tuesday, but I would appreciate a few minutes of your time at your convenience as I am
getting up to speed. Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza
|
4th Floor
Miami Florida 33129
t.
EFTA00028368

=== Page 3 ===
f.
e.
www.crimlawfirm.com
EFTA00028369


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c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
i
Cc:
(NY) (OGA)"
Subject: Video Status
Date: Wed, 27 Nov 2019 17:32:56 +0000
Just FYI regarding the video status as a whole You can see the questions I asked our tech people at the bottom.
We can discuss this next week after the holiday.
Hope everyone has a safe and happy Thanksgiving!
Classification: UNCLASSIFIED/FOUO
I got looped into the discussion below and you can see the responses that floated around. You are correct in your
assumption of DVR2, we have not done anything with it since the dates are outside your dates of interest and
manual rebuilding of DVR2 was not going to be a simple task.
To that end, the data on DVR2 might(major emphasis on might) be recoverable, but this will be a long term
project, likely 6 or more months, requiring research and testing, in order to potentially obtain useable video from
the DVR. There is no guarantee of success and that must be weighed with how much time and resource we want
to throw at It vs what you MIGHT be able recover.
If this is something you want OTD/DFAS/DFAU to move forward with, let's discuss it further via conference
call and then we'll ask you to follow up with a EC request to address this specifically.
Thanks,
Subject: RE: DVR1 Exports --- UNCLASSIFIED/FOUO
Classification: UNCLASSIFIED//FOUO
I worked on DVR1, and helped
export part of the day of interest.
EFTA00029280

=== Page 2 ===
has the paperwork; and list of cameras that were available for DVR1
I have not worked on DVR2 at all.
If there is a Data Recovery need for DVR2, then please write an EC requesting what you want recovered.
I am CC'ing
(My Supervisor) to keep him in the loop.
Regards,
Subject: RE: DVR1 Exports --- UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
Can you answer the questions about DVR
Subject: RE: DVR1 Exports --- UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
Hi - I'm just circling back around to see if you guys have had a chance to check into the below questions.... just
trying to get things done before the holidays!
Thanks!
From:
Sent: Thursday, November 21, 2019 11:31 AM
Subject: RE: DVR1 Exports --- UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED/FOUO
Good Morning
EFTA00029281

=== Page 3 ===
I know you guys have had a nice break from everything Epstein
However, I'm back
We are preparing for
discovery now and I have to get exact answers regarding all the video that we have available. I apologize in
advance for all of these questions!
We are going to turn over all available footage for the SHU area at MCC - which is on CH0082, CH0080, and
CH0062. To download all of this footage, what size hard drive will be needed (or how many should I request)?
What is the total number of cameras that are available on DVR1?
We don't have a camera list that actually correctly names the location of the cameras, correct? Lists that I have
seen were wrong but I'm not sure if one exists that is correct
As far as DVR 2, there was a system failure that caused that DVR to stop recording. I know that there would be
no available footage beyond July 29 for that DVR. I also know that QT was going to have to try and rebuild it
manually. Did they ever recover any footage or did they discontinue efforts once we told them that dates prior to
July 29th weren't of interest? I'm not sure where they left off with that part
Thanks!
Special Agent
FBI New York Field Office
Violent Crimes Task Force
EFTA00029282


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: RE: CACI document scanning 15JA5421F00000068 US V. Maxwell Epstein Scanning
Date: Thu, 24 Jun 2021 19:57:25 +0000
Inline-Images: image001.jpg; image003.jpg
Great. We will proceed with closing the contract, once CACI confirms whether there are any invoices we need to pay first.
From:
Sent: Thursday, June 24, 2021 3:55 PM
To:
(USANYS)
Subject: RE: CACI document scanning 15JA5421F00000068 US V. Maxwell Epstein Scanning
Hi
No, this is no longer needed.
Thanks very much,
From:
(USANYS)
Sent: Thursday, June 24, 2021 5:48 AM
To:
Subject: CACI document scanning 15JA5421F00000068 US V. Maxwell Epstein Scanning
Good morning
Is this document scanning service for the Maxwell/Epstein case still needed?
We haven't received any invoices from CACI, so I will also check with them.
Thanks,
From:
(USANYS)
Sent: Wednesday, March 24, 2021 2:24 PM
To:
Cc:
Subject: Delivery/Task order no. 15JA5421F00000068
Hi
Attached is a task order for CACI - Commercial services (scanning/document management) under GS-25F-
0131M; please retain for your records.
The period of performance of this contract is from 3/24/2021 - 5/31/2021. The total estimated value of this
contract is
EFTA00029527

=== Page 2 ===
If you have any contract related questions, please don't hesitate to contact me.
Please email all invoices and payment related questions to
Remember to include
the following information on your invoice correspondence:
Task order# 15JA5421F00000068
Reference# R21NYS18013
OF JUSTICE
Contract Specialist (FAC-C/COR III)
U.S. Attorney's Office, Southern District of New York
86 Chambers St. /New York, N.Y. 10007
T:
I F:
I
E-Mail:
EFTA00029528


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=== Page 1 ===
From
To
Subject: GPS for apprehension
Date: Fri, 23 Oct 2020 21:39:11 +0000
Attachments: Maxwell_GPS_Combo_v3.docx; 2018-05-10,_PAC,_GPS_for_2_Target_Phones.docx
The most recent one I have is for Maxwell, attached - you may want to just check the forms library to see if there has
been any update since this version (2019.07.24), but I assume it's up to date since it's just from the summer.
From a little further back, but possibly simpler, also attached is one I got for a PAC case to make arrests.
Good luck!!
Assistant U.S. Attorney
Southern District of New York
EFTA00029146


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 297 Filed 06/02/21 Page 1 of 2
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 6/2/21
United States of America,
-V-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
Having considered the parties' respective proposals, Dkt. No. 291, the Court hereby sets
the following disclosure schedule:
- September 13, 2021: Disclosure of alleged victims' identities (Government's proposal)
-
October 11, 2021: Government's disclosure of Jencks Act and Giglio material, Rule
404(b) evidence and notice, co-conspirator statements, and Government witness list
(Government's proposal)
- October 11, 2021: Government's disclosure of its proposed exhibit list (Defendant's
proposal)
-
October 18, 2021: Simultaneous filing of motions in limine (agreement of the parties)
- October 25, 2021: Simultaneous filing of proposed jury questionnaire and voir dire
(agreement of the parties)
- November 1, 2021: Defense expert disclosures (Defendant's proposal)
- November 1, 2021: Responses to motions in limine (agreement of the parties)
-
November 8, 2021: Simultaneous filing of requests to charge and verdict sheet
(agreement of the parties)
1
EFTA00028706

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 297 Filed 06/02/21 Page 2 of 2
- November 8, 2021: Defense disclosures pursuant to Rules 16(b)(1)(A) and 16(b)(1)(B)
materials (The Government proposed November 1, 2021; the Defendant proposed the
close of the Government's case-in-chief)
-
Close of the Government's case-in-chief: Defense witness list and 26.2 statements
(Defendant's proposal)
These dates establish a baseline for when the parties must disclose certain materials.
Each of the parties has a continuing obligation to update all disclosures if they become aware of
additional responsive materials. In addition, and as requested by the parties, the parties may
bring issues to the Court's attention that arise after the deadline for motions in limine if the issues
could not have been raised within the deadline set for in limine motions.
so ORDERED.
Alim D.Netto
Dated: June 2, 2021
New York, New York
ALISON J. NATHAN
United States District Judge
2
EFTA00028707


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: Daughter of former FBI director Comey revealed to be part of prosecution team in sex
trafficking case against billionaire Jeffrey Epstein: Shimon Prokupecz, Reporter via Twitter.
Date: Mon, 08 Jul 2019 00:17:15 +0000
Importance: Normal
They may be with the body - do you have someone who could walk with them at least over to the courthouse?
Sent from my iPhone
On Jul 7, 2019, at 7:50 PM,
wrote:
FYI - can we please make sure the case agents accompany
and other AUSAs to/from court.
URGENT UPDATE
10:37pm July 06, 2019 EDT REPORTER
Daughter of former FBI director Comey revealed to be
part of prosecution team in sex trafficking case
against billionaire Jeffrey Epstein: Shimon
Prokupecz, Reporter via Twitter.
ORIGINAL PUBLIC TWEET (10:37pm July 06, 2019 EDT)
the daughter of former FBI director James Comey, is one of
the prosecutors, according to a source with knowledge of the case.
Shimon Prokupecz @ShimonPro
ESTIMATED EVENT LOCATION:
EFTA00028292

=== Page 2 ===
New York, NY, USA
ALERT VERIFICATION :
REPORTER @SHIMONPRO
Account Created: 08.13.2009
Public Tweets 16,247 I Followers 80,826
Journalist insta: @shimonpro
Track Story
Open in First Alert
EVENT TIMELINE CAPTIONS
Billionaire Jeffrey Epstein expected to be charged in a sex trafficking
scheme allegedly involving "dozens" of victims after being arrested in
Teterboro, New Jersey: News Outlet via NBC News.
Billionaire Jeffrey Epstein arrested for allegedly sex trafficking dozens
of minors and will appear in court in New York: News Outlet via The
Daily Beast.
EFTA00028293

=== Page 3 ===
EVENT TIMELINE DETAIL
New York, NY, USA
10:27pm July 06, 2019 EDT
Billionaire Jeffrey Epstein expected to be charged in a sex trafficking scheme
allegedly involving "dozens" of victims after being arrested in Teterboro, New Jersey:
News Outlet via NBC News.
OPEN IN First Alert I VIEW POST VIA NBC NEWS
New York, NY, USA
07:57pm July 06, 2019 EDT
Billionaire Jeffrey Epstein arrested for allegedly sex trafficking dozens of minors and
will appear in court in New York: News Outlet via The Daily Beast.
OPEN IN First Alert I VIEW POST VIA THE DAILY BEAST
Lists: NYC AOR
Topics: Public Safety - Legal Action
Adjust your settings by clicking here
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reproduction, modification, distribution or publication, without the prior written consent of Dataminr, is strictly
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EFTA00028294


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c3: VOL00008
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=== Page 1 ===
From:
To:
Subject: RE: pros memo
Date: Thu, 08 Aug 2019 15:38:02 +0000
Attachments: 2019-06-17,_JE,_prosecution_memo.docx
Sure! I'm honestly not sure exactly where it is on the share at this point, but it's the one that got emailed around a bunch
of times so whenever I need it I just pull it from those messages. Attached.
From:
Sent: Thursday, August 08, 2019 10:41
To:
Subject: pros memo
Could you please send me whatever the final version was? Thanks.
Assistant United States Attorney
Southern District of New York
EFTA00028535


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Bcc:
(USANYS)"
Subject: Re: Epstein search warrant documents
Date: Thu, 02 Jul 2020 23:15:54 +0000
I understand.
On Jul 2, 2020, at 7:13 PM,
(USANYS)
wrote:
Let's discuss. I just don't have a lot of confidence that is going to get this done.
Sent from my iPhone
On Jul 2, 2020, at 6:35 PM,
(USANYS)
wrote:
Ok.
is also prepared to call
about pushing this issue if need be.
On Jul 2, 2020, at 6:32 PM,
(USANYS)
wrote:
On this issue of the Epstein devices, the team got an estimate from BRG that seems reasonable in terms of both cost
and time line. At this point, I would be inclined to do this, but let's find some time to chat more about it tomorrow if
you're around or early next week if that's better. Thanks
From:
Sent: Thursday, July 2, 2020 5:11 PM
To:
(USANYS)
Cc:
(USANYS)
is
is
Subject: RE: Epstein search warrant documents
Following up on the below, I think we've given this our absolute best efforts with FBI - they are now well over a
month later than their estimate from April on when we would get the New York materials, they're also past their
estimate of getting us the New York materials from just this Monday, and we don't have anything close to an
estimate on the USVI materials, which constitute the overwhelming majority of the data and are vastly more
voluminous than the New York devices. We have kept pushing the timeline back for this option, hoping that CART
will finalize, but I think at this point we should have a vendor do it.
Attached is an estimate we got from BRG, which would get everything to us in under a month, and in Relativity-
friendly format, in a range of $85-135K. BRG has done this for our office multiple times in the past and are very
effective and efficient, and they get the materials we need. And most importantly, they estimate they can do it all in
less than a month. May we have approval to seek funding for this? The estimate is attached. Thanks very much.
EFTA00027491

=== Page 2 ===
From:
Sent: Tuesday, June 30, 2020 16:23
To:
(NY) (FBI)'
i
(USANYS) [Contractor]
Cc:
(USANYS)
i
(NY) (FBI)
is
is
i
(NY)
(FBI)
V.
(USANYS)
Subject: RE: Epstein search warrant documents
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
From:
)
Sent: Monday, June 29, 2020 13:00
To:
(NY) (FBI)
>;
(USANYS) [Contractor]
Cc:
(USANYS)
i
(NY) (FBI)
V.
is
>;
(NY)
(FBI)
V.
(USANYS)
Subject: RE: Epstein search warrant documents
Okay thanks - good luck with the cardiologist! And if you can let us know tomorrow that would be great. Thanks
again.
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:59
To:
(USANYS) [Contractor]
>;
Cc:
(USANYS)
i
(NY) (FBI)
>;
is
>;
(NY)
(FBI)
V.
(USANYS)
Subject: RE: Epstein search warrant documents
When I'm in the office tomorrow, I will be better able to estimate. I'm at my cardiologist right now.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:56 PM,
)"
wrote:
Great, thanks. Is there even a rough estimate of when we will get the USVI materials? Or an estimate of when you'll
be able to see how many items to export, so we'll have a better sense of when we'll get those?
EFTA00027492

=== Page 3 ===
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:55
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
>;
(NY) (FBI)
is
is
i
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Yep
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:52 PM,
)"
wrote:
Okay, and I'm sorry to ask again, but to make sure, in this production, you're sending us new versions of what you
previously sent?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:50
To:
(USANYS) [Contractor]
is
)
Cc:
(USANYS)
is
(NY) (FBI)
is
is
is
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
You are getting both NY and USVI. The biggest stumbling block are the newer Mac items that are in APFS
(there are a bunch from the Island,) so it is difficult to estimate how long those will take until I see how
many items I have to export.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:40 PM,
)"
wrote:
Okay thanks, and just to clarify, a few days to finalize the New York materials, and then what about the USVI
materials? I think that is quite a bit more. Just looking for an estimated completion date for everything.
And on my other question - does this mean you're giving us a new, complete copy of everything from both NY and
USVI?
thanks,
EFTA00027493

=== Page 4 ===
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:34
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
>;
(NY) (FBI)
V.
is
i
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
I am in the process of exporting the materials (documents, spreadsheets, emails, etc) for your review as per
my discussions with
Most of the NY stuff is done, just Mac items left. This might take a few days as
1 item in particular has over 500,000 emails. We will be able to provide discovery once Defense Council
has provided drives for us to copy items over to. This goes quicker as there is no processing involved. I'll let
you know when everything is complete.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 11:03 AM,
)"
wrote:
Following up on this, I understand from
that she was able to provide you with a 12 TB drive last week - could
you please let us know when we will be able to get the materials? I expect a judge will ask us about discovery as
early as this week.
Also, the related critical question that I don't think we have clarity on is whether you're giving us a copy of everything
that was collected (including reproducing the materials that you previously gave us, but which are not searchable), or
have you and
figured out a way to categorize the prior productions so they're useful for us? We would strongly
prefer to just get everything at once in a usable format, but please let us know if you expect to produce materials
differently than that.
thanks,
From:
(NY) (FBI)
Sent: Friday, June 19, 2020 13:14
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
is
(NY) (FBI)
is
is
is
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
,
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK
when I can expect the drives. Thanks.
NY CART Coordinator
EFTA00027494

=== Page 5 ===
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
)
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(NY) (FBI)
i
)
is
>;
(NY) (FBI)
is
(USANYS)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July
and September searches before moving forward with possible additional charges in the case. I know you had
mentioned you needed to push back your prior estimate of complete production by early June, by a couple weeks, so
wanted to see what the current estimate is? I don't think we've started to get anything yet but please correct me if
I'm wrong.
thanks,
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
)
is
)
>;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go
from there.
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
EFTA00027495

=== Page 6 ===
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
)
is
)
>;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If
we can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our
staffing levels will be steadily increasing over the next few weeks, but I'm going to have to push back my
estimate by a week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can
easily identify what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
Thanks for this update - we'll take a look and circle back if any questions.
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in
searchable format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to
specific devices - so if we're able to match them up by Bates number now, that might work, but otherwise I think it
makes sense for us to get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think
we've gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial
numbers. Any questions, let me know.
FBI NY CART Coordinator
EFTA00027496

=== Page 7 ===
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
in
(USANYS) [Contractor]
Cc:
in
>;
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of
information we need is the serial number, or some other specific identifier, ideally for each device but at least for any
device that there is more than one of the same thing. So for example, we need to be able to somehow differentiate
the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the
USVI spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the
USVI list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to
reproduce all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we
aren't able to match any of the prior productions to specific devices - so if we're able to match them up by Bates
number now, that might work, but otherwise I think it makes sense for us to get everything. But let us know if any
issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
EFTA00027497

=== Page 8 ===
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I
could to convey the information. If you are confused by anything, please let me know. In the column for
approximate size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column,
I put what load file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight)
If there is no entry in that column, that data has yet to be transferred. There are 2 Macs and a DVR you
don't have as well as an iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what
I can to beef them up. I will get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a
format such that we can view them using a system we have access to. We're not able to get web-enabled access
through any FBI tool, so we asked for the materials to be transferred in a loadable format so we could put them on
Relativity, which both we and the agents can access. We're required to have the files in a format that we can
produce them to defense counsel. I've done that in many other cases and it hasn't previously been an issue. My
understanding from
is that the best way to do it now is just for us (the U.S. Attorney's Office) to get the original
files, which our vendor will process-by which I just mean converting into file formats that are loadable onto
Relativity. It doesn't really have anything to do with the taint review-we have to have access to the docs in our
systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents
earlier this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9.
Again, I understand from
that the best way forward is to just get copies of the materials in their original
formats, which I understand will be segregated and designated by device. That should work for us! I was just trying
to understand the approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
is
(USANYS) [Contractor]
Cc:
is
is
EFTA00027498

=== Page 9 ===
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking
files that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity)
to do a taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you
insisted you do the taint review in Relativity, I warned you that it was adding months worth of work on top
of what was already done, and that Relativity was incapable of viewing everything. You insisted we do it
this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get
it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it
piece by piece as things are processed, I was unaware that you didn't want to review as things were
processed, that you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a
differentiation of methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a
while back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
)
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just
basically sending us copies of everything? I don't totally understand why we couldn't have done that eight months
ago, but regardless of the passage of time, I want to make sure we understand so we can report to our supervisors.
I
assume that means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the
processing ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
is
Cc:
is
-
Subject: RE: Epstein search warrant documents
EFTA00027499

=== Page 10 ===
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it
to a particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
>;
Cc:
is
)
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so
we make sure we get all the info we need. I think you had previously sent us a list of certain information that
unfortunately wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload
it on our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already
been processed. I think what we talked about on the phone a month ago was getting, for example, data from one
device to make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
EFTA00027500

=== Page 11 ===
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data
and where the data was collected. I will work to send some hard drives to
so he can begin to copy the data
and send it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
in
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to
review the returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
V.
)
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave
you. If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for
complete transmission of the search warrant returns is no longer likely? If so could you please let us know what the
current estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
i
)
>;
EFTA00027501

=== Page 12 ===
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
y.
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I
will be back in the office on Thursday and will be able to get you the list then as I have to access some of
our systems to do so.
Also,
,
please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're
waiting on that list to be able to do an updated search warrant on all of those devices. Please let us know the
current timeline - and also the current timeline on producing the results from those August and September
searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it
a couple months from our call, which would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
) [mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
i
is
EFTA00027502

=== Page 13 ===
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us
know, otherwise I'd propose we do:
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
>;
(NY) (FBI)
is
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago,
but are you at all able to assist while working remotely? This has been pending for almost two months and we still
don't have a very basic list of each device or item that was seized and searched, or for which of those we've received
materials. We're happy to have a call if that would be useful, but as a first step the most basic thing we're looking for
is the info in the template spreadsheet we sent earlier (that's also attached).
thanks,
From:
)
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
EFTA00027503

=== Page 14 ===
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24?
The excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we
sent on 2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you
mean by "loose media" without a specific comparison to what was seized, we don't know which items you're
referring to as "Windows machines," and we can't tell whether the entirety of any particular item has been
transferred, or just partial. For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
The data we've received has no way to put any emails and attachments together. So if an email says, "see
the attached flight records," for example, we have no way of linking that up with the records themselves.
Not only is that a big problem for us in review, it's going to be a huge problem for producing the documents
to defense counsel.
-
The load file has no link to the native file, so when we load the data to the database, there's no way to have
the native files show up in the database. Because many of the files are too large to open in the viewer, it
effectively means that there are many files that are completely invisible to us.
-
Related, the control numbers in the load file don't match up to the native files. So we have two sets of
numbers and no way to match up anything-that is, even if we were to try to go hunt down every individual
large file in the native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need
to get a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more
than a million documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary
record-keeping, and we need that info at the very least, as well as anything else you think would be useful. Also
attaching the SW returns for reference. And again, we're happy to meet up anytime and hash all this out in person if
that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some
points of clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3
copies of 3 drives (9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were
all copies). All the loose media from the NY apartment is included. All the Windows machines from the NY apartment
are included. Only 2 Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the
tool they have to be processed with does not easily re-name the load files.
EFTA00027504

=== Page 15 ===
Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From:
) [mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
i
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so
we can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
i
)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
)
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
is
(USANYS)
i
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
EFTA00027505

=== Page 16 ===
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together
to have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next
week? And what I think would be most helpful to facilitate that would be a spreadsheet of each separate device
referenced in the two search warrant returns, with columns for whether we've dumped the contents, whether
they've been reviewed and/or transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the
attached is mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed,
transferred, and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I
think FBI was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get
those to be able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
i
>;
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they
mandated we delete old stuff (about 400 TB worth). Now that they are working on replacing the network,
we can do only local work. I should be able to give you an accounting of what is what. I can say, off the top
of my head, that all windows based items from the NY search have been handed over as well as all loose
media. The CDs from NY only contained pictures, no documents. There are still some Apple items from NY
that need to be produced. As far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac
has been produced. Still working on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e.,
EFTA00027506

=== Page 17 ===
which devices the materials came from, whether it's full or partial results, how many more devices we have coming,
etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are
approximately 40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even
counting at least 60+ CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices,
including multiple servers / server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of
moving pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming
week from Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be
plenty of time to schedule a productive meeting.
thanks all,
From:
)
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
is
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have
the hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also
old materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's
new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of
what we're getting, and what has been completed, without some kind of identification or labeling system, along with
a list of which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a
modified date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we
haven't gotten any info on which folders match up to which devices, etc. And then there's another folder titled
"NYC024362" that has a modified date of 1/27/20, so I think that may be the materials we hadn't previously
received? That folder by itself has more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the
folder or file names whether everything on the drive is new, or whether just additional materials were saved onto it
in addition to what we already have.
are you able to give us some guidance on this? Ultimately what we
really need is a spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying
that same info - which device, and what materials from it - are being given to us with each data transfer. Otherwise
I think organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
EFTA00027507

=== Page 18 ===
Southern District of New York
<mime-attachment>
EFTA00027508


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=== Page 1 ===
From:
To:
Cc:
Subject: Return of Property Epstein
Date: Fri, 02 Aug 2019 13:19:23 +0000
Good Morning
and Team,
Just wanted to give everyone notice that Epstein's suitcases and property was returned this morning as of
9:00am. The items were returned to a private investigator on behalf of Epstein's legal counsel that consulted with
last night on 08/01/2019
Frank Senerchia
Orion Investigations Inc.
New York, New York 10017
I went through item by item on our receipt for property with Mr. Senerchia which he verified. I have a photo of
his ID as well as photos of him signing our receipt for property forms.
and
,
I'll knock out a 302 for you on Monday for today's task.
Have a good weekend
SA
FBI-New York
C-20 Child Exploitation/Human Trafficking Task Force
Desk
Cell
EFTA00028532


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=== Page 1 ===
From:
To:
Cc:
Subject: latest memo and redline
Date: Mon, 08 Jul 2019 13:49:53 +0000
Importance: Normal
Attachments: 2019-07-08,_JE,_detention_memo_draft.docx; detention_memo_redline.pdf
I'm proofing it now (and will add Judge Berman and defense counsel as cc) and plan to submit it to Judge Pitman, Judge
Berman, and defense counsel at 10:30 (but let me know if anybody prefers otherwise).
Assistant U.S. Attorney
Southern District of New York
EFTA00028295


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=== Page 1 ===
From:
To:
Subject: FW: victim notification
Date: Wed, 09 Dec 2020 00:00:15 +0000
This looks good to me, with one suggestion below.
From:
Sent: Tuesday, December 8, 2020 6:46 PM
To:
(USANYS) ;
(USANYS)
Cc:
;
(USANYS)
Subject: victim notification
Below is the text we would propose for a victim notification letter. We would plan to use VNS, and the letter is styled
accordingly. One note: the letter does not expressly reference the CVRA, because other DOJ components are currently
litigating whether the CVRA applies in the context of a pre-indictment plea (the issue is currently before the Eleventh
Circuit, en banc). Since we're giving notice here regardless of whether it's required, because that's the right thing to do,
there's no need to include language that touches on the CVRA issue.
Thanks,
Dear [Name]:
Re: [Epstein case name auto generated from the VNS system]
The enclosed information is provided by the United States Department of Justice Victim Notification System (VNS). As a
victim witness professional, my role is to assist you with information and services during this case. I am contacting you
because you were identified by law enforcement as a victim or potential victim during the investigation of the above
criminal case.
In connection with the above-referenced investigation, the United States Attorney's Office for the Southern District of
New York intends to issue a felony plea offer to an individual named
who is also known as
,
is currently not charged with any criminal offenses, and this office has not yet extended any plea offer to her.
If you have any questions about the felony plea offer, or if you wish to inform the prosecutor of your views regarding a
potential plea agreement, please contact the prosecutors in this case by [date]. This office will not issue a plea offer
before [date], in order to provide time for victims to confer with the prosecutors in this case.
The prosecutors for this case are
and
If you would like to arrange a time to
speak with the prosecutors in this case, please either ask your attorney to contact the prosecutors directly, or if you are
not represented by counsel, please contact
Victim / Witness Coordinator, at
If a plea hearing is scheduled in this case, we will notify you of available information as soon as practicable.
Sincerely,
Acting United States Attorney
Victim Witness Coordinator
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00027440


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=== Page 1 ===
Timeline 8/9/2019 8/10/2019
MCC
2019R01059
30 Minute
Internet/Computer Activity
Rounds
Counts
Counts
Internet/Computer Activity
12:36 AM 5:14 AM
Video
ZA
ZB
11:40 PM 10:31 AM
6:03 AM 8:55 AM
Date
Time
Activity
8/9/2019
7:59 PM
White board observe
9:10 PM
Slight move
9:19 PM
Move up stairs
2 people upstairs, 2 people
9:22 PM
downstairs
9:23 PM
White board obstruction
10:31PM
male leave break room
10:49 PM
2 upstairs, 2 downstairs
11:15 PM
far stairwell
11:42 PM
2 upstairs, 2 downstairs
1 upstairs
8/10/2019
12:00AM
male black
12:01AM
12 AM Count
12 AM Count
12:00 Check
12:12 AM
12:33AM
Check sheet
opened never filled out may be
12:39AM
12:30 Check
printed
12:43AM
30 minute check form last modified
12:44 AM
12:50AM
1 person walk
Search Google & Bing for Suzuki
1:00 AM
motorcycle for sale
1:01AM
1 person Walk
1:03 AM
1:00 Check
1:14 AM
1:31AM
1:30 Check
1:38 AM
2:00 AM
no movement
2:01AM
2:00 Check
2:12 AM
2:35 AM
2:30 Check
2:46 AM
3:00 AM
AM Count
3 AM Count
3:01AM
3:00 Check
3:12 AM
3:14 AM
black female 772
3:17 AM
black female walk
3:18AM
black female at desk
3:33AM
3:42 AM
black female door 46
3:30 Check
3:44 AM
3:51AM
Black female out of 46
4:00 AM
2 people at desk
4:05 AM
light skin female door 46
4:06 AM
4:10 AM
light skin female ??? 46
4:00 Check
4:15 AM
light skin female ??? Desk
4:17 AM
4:30 AM
4:31AM
Google searches vary
4:36 AM
4:30 Check
EMPTY
4:39AM
EMPTY
4:41AM
4:48 AM
???
4:52 AM
??? Fur
5:00AM
5 AM Count
5 AM Count
5:01AM
5:00 Check
5:08 AM
777
5:11AM
5:26AM
1 female move
5:27AM
out
5:33AM
5:38 AM
female in, male out
???
5:30 Check
5:42 AM
Epstein jail search
5:44 AM
??? Out
5:48AM
7777
5:52 AM
Epstein jail search
5:53AM
Omar Ominott
5:57 AM
5:58AM
in/out movement
6:02 AM
6:04 AM
6:00 Check
Resume internet
6:13AM
6:15 AM
ESPN
6:17 AM
Leo Discouts
6:22AM
2 movement
6:23AM
movement
6:30 AM
6:31AM
to desk/back
EFTA00027179


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
)"
)"
Subject: Re: JE FOIA review in SDNY (?)
Date: Wed, 12 Jun 2019 12:02:20 +0000
Importance: Normal
How did we find out about this?
Sent from my iPhone
On Jun 11, 2019, at 10:27 PM,
(USANYS)
wrote:
Checking
Sent from my iPhone
On Jun 11, 2019, at 10:14 PM,
)
wrote:
We heard second-hand from a colleague that our civil division is processing a FOIA request relating to the Epstein
investigation (but unclear on specifics). Obviously this is the first we've heard of it, and understandable that there
wouldn't be cross-communication since the criminal investigation is still covert (and not widely known even among
assistants), but it still is a little puzzling in terms of why such a review would be venued here. Do you who the right
person would be in civil to ask about FOIA processes there? We're happy to reach out if that's appropriate, or if you
prefer to do it at the supervisor level certainly no objection from us.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00029019


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=== Page 1 ===
From: "
(USANYS)"
To:
(USANYS)"
"
(USANYS)"
Subject: RE: Phone Call Follow-Up
Date: Fri, 30 Oct 2020 18:42:13 +0000
Inline-Images: image001.png
Understood
From:
(USANYS)
Sent: Friday, October 30, 2020 2:41 PM
To:
(USANYS) ;
(USANYS)
Subject: RE: Phone Call Follow-Up
Thanks,
The problem is the stuff that is coming today is stuff the team asked PAE to process in early September. I
realize that this is a big project and that there's only so much that can be done, but it poses almost insurmountable timing
hurdles for our team if it is taking 1-2 months for PAE to get us stuff we ask for out of Relativity. In most of our cases, this
one included, that eats up a huge chunk of the time we have available to produce discovery.
We'll follow up early next week to see if there is a more concrete update, but I think this may require a broader or higher
level explanation to the Court. I am concerned about requiring our team to take the hit with Judge Nathan for missing this
deadline.
From:
(USANYS)
Sent: Friday, October 30, 2020 12:51 PM
To:
(USANYS)
is
(USANYS)
Subject: FW: Phone Call Follow-Up
Some of the data is being sent to use today by FedEX. However, there is a ton of stuff still being processed. That stuff is
still being imaged. Then it gets marked. Then copied to us. I have spoken to
He thinks it is not possible to
meet the November 9 date. He thinks the next step might be done on Tuesday, and then a better estimate of completion
might be possible.
From:
[US]
Sent: Friday, October 30, 2020 12:25 PM
To:
(USANYS)
Cc:
(USANYS) [Contractor]
Subject: Phone Call Follow-Up
Good Afternoon Ed:
Following up on our earlier phone conversation, a hard drive with the following productions is being sent to SDNY via
FedEx with the following productions in the US V. Epstein workspace:
1) SDNYPROD008
2) SDNYPROD009
3) SDNYPROD010
4) SDNYPROD011 (Note: this is a six-part production)
5) SDNYPROD012
6) SDNYPROD013
7) SDNYPROD014
There are approximately 1.2 million records currently being imaged. The images will be available on Monday, November 2,
2020 at the earliest. The production of the records will begin as soon as the images are available in the workspace.
Please feel free to contact me if you have any questions.
Thanks,
EFTA00028688

=== Page 2 ===
Lead E-Discovery Analyst
e.
7799 Leesburg Pike, Suite 300N
Falls Church, Virginia 22043
PAE
IMPORTANT: The information contained in this message may be privileged, business sensitive, proprietary,
copyrighted, protected from disclosure and/or subject to US export controls. If you are not the intended
recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify me immediately by replying
to the message and deleting it from your computer. #-SEC-#
EFTA00028689


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=== Page 1 ===
From:
To:
Subject: Charges for Jeffrey Epstein's Jail Guards Coming as Soon as Next Week - WSJ
Date: Sun, 17 Nov 2019 05:18:32 +0000
https://www.wsj.com/articles/charges-for-jeffrey-epsteins-jail-guards-coming-as-soon-as-next-wek-
11573873853
EFTA00029190


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=== Page 1 ===
From: "ROBERT C. JOSEFSBERG"
To:
Cc: Scarola Jack
Subject: Epstein
Date: Tue, 06 Aug 2019 22:01:07 +0000
As we know, Epstein's Lawyers are going to claim that the NPR agreement prohibits your prosecution. I want to
share some information with you regarding that issue. You are probably already aware of this, but I'd prefer that
you learn about it twice instead of never being aware of this proof. At the state court plea hearing, Epstein's
counsel told the court that the NPR covered only the So Dist Of Fla. On the next page of the transcript the Judge
messes it up a bit, but we know that when she said "they", she meant the USAO of the So Dist of Fla, NOT the
DOJ. I am forwarding to you the cover sheet and two relevant pages of the transcript. along with info re when
and where his occurEd. If you have any questions about this, or any other way I can assist,
you please call me PS - two of my clients have advised me that they have contacted the FBI.
Robert C. Josefsberg, Esq.
Sent from my iPhone
EFTA00028077


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: draft response to Epstein defense preservation requests
Date: Thu, 08 Aug 2019 16:08:06 +0000
No worries - there's been a ton of stuff going on in the meantime!!
From:
(USANYS)
Sent: Thursday, August 08, 2019 11:57
To:
y.
(USANYS)
Cc:
is
Subject: RE: draft response to Epstein defense preservation requests
Sorry - back to you shortly.
From:
Sent: Thursday, August 08, 2019 11:44 AM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: draft response to Epstein defense preservation requests
Wanted to bump this from Tuesday, especially since I know you guys are out tomorrow - hopefully we can send it out
today? Happy to incorporate any edits etc. Thanks.
From:
)
Sent: Tuesday, August 06, 2019 15:01
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: draft response to Epstein defense preservation requests
This has been in the works for a little while, due to various other things that have come up in the interim, but we didn't
want it to get lost given the discovery motion schedule. The attached is based on our conversations with
including
his email with suggested language for the prefatory language, and responds to the two attached defense letters. Happy to
discuss anytime and to incorporate comments and suggestions.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00027916


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
Subject: Epstein FOIA - OCME Report of Autopsy
Date: Mon, 28 Jun 2021 21:01:44 +0000
Attachments: Epstein_-OCME_Report_of_Autopsy.pdf
Please find attached the OCME Report of Autopsy. The boxes show where there will be redactions.
Thanks,
Assistant United States Attorney
White Plains, NY 10601
EFTA00029520


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: [EXTERNAL] US V. Maxwell S2 20 Cr 330 (AJN)
Date: Tue, 02 Nov 2021 12:57:42 +0000
Attachments: 2021-11-01_GM_letter_re_MDC_legal_mail_v3.docx
- attached is an updated draft this still needs to be reviewed by my supervisors. Please review closely.
This is due at 12 PM. If you can check your email around 11 that would be great.
Original Message
From:
Sent: Tuesday, November 2, 2021 8:31 AM
To:
Cc:
)
Subject: Re: [EXTERNAL] US V. Maxwell S2 20 Cr 330 (AJN)
Sure
11/2/2021
8:10 AM
Thanks, are you free for a call now?
> On Nov 2, 2021, at 7:53 AM,
wrote:
>
> See mail records attached!
V
> Pg 3 - - Statement in quotes is correct.
> Pg. 3 - They give inmates jackets while they wait, but they are not
> allowed to bring other clothes down there (in R&D). No utensils
needed
> for sandwiches or an apple or milk, etc..
>
V
11/2/2021
> 12:31 AM
V
,
V
> My last email sent before I had a chance to write an email. Thanks
> very much for speaking today. We have incorporated our discussion
into
> the attached draft letter to Judge Nathan. Would you please review
the
> draft very closely and let us know if there are any inaccuracies in
it?
EFTA00029287

=== Page 2 ===
> I highlighted several sentences where we need additional information
> from you. As we mentioned earlier, our letter is due today, November
2,
> at 12 PM. Can you please send us any comments no later than 9:30 am?
I
> will call you early tomorrow morning.
V
> Thanks very much,
>
V
> From:
)
> Sent: Tuesday, November 2, 2021 12:28 AM
> To:
> Cc:
i
> Subject: RE: [EXTERNAL] US V. Maxwell S2 20 Cr 330 (AJN)
V
>
>
> From:
> Sent: Monday, November 1, 2021 5:15 PM
> To:
> Cc:
> Subject: RE: [EXTERNAL] US V. Maxwell S2 20 Cr 330 (AJN)
You can call now!
V V V V V V V V V V V V
Staff Attorney
MDC Brooklyn
Original message
> From:
<mailto:
> Date: 11/1/21 5:04 PM (GMT-05:00)
> To:
> Cc:
EFTA00029288

=== Page 3 ===
> Subject: RE: [EXTERNAL] US V. Maxwell S2 20 Cr 330 (AJN)
>
>
>>>>
"
)" 11/01/2021 17:04
> Yes. What number should I call?
>
> From:
> Sent: Monday, November 1, 2021 5:03 PM
> To:
> Cc:
> Subject: RE: [EXTERNAL] US V. Maxwell S2 20 Cr 330 (AJN)
>
>
I'm sorry. Does 530 work?
>
>
V
>
>
Staff Attorney
> MDC Brooklyn
>
V
V
>
Original message
> From:
<mailto:
> Date: 11/1/21 4:48 PM (GMT-05:00)
> To:
> Cc:
> Subject: Re: [EXTERNAL] US V. Maxwell S2 20 Cr 330 (AJN)
V
V
)" 11/01/2021 16:48
»
> We are available. How about 5?
V
EFTA00029289

=== Page 4 ===
On Nov 1, 2021, at 4:16 PM,
wrote:
She will have it delivered tomorrow. I will hand deliver it to
her.
> I
can call you in a little bit. What time are you available this
afternoon?
<mailto:
>
11/1/2021
2:54 PM
Thanks, when can you speak today? Our letter is due tomorrow at 12
> PM.
Also, we need to update the court in that letter about the hard
drive
> we
sent to you on Friday. Can you please let us know the status of
>
whether
that has been picked up? I can provide a tracking number if
helpful.
Thanks again.
On Nov 1, 2021, at 10:53 AM,
wrote:
FYI - she has received mail from USPS on the 29th. The USPS
> website
is
not always up to date so theres not much more we can do. Also,
staff
does not pick up mail form the post office on Saturday's, only
Monday
through Friday.
)"
V
<mailto:
10/29/2021
> 6:08 PM
and
Please see the attached letter, which was filed this evening. Are
you
available for a call on Monday? We anticipate that this issue will
be
addressed at our final pretrial conference at 11 a.m. on Monday.
Thanks,
From: BOBBI C STERNHEIM
EFTA00029290

=== Page 5 ===
>
<bcsternheim@mac.com<mailto:bcsternheim@mac.com>>
Sent: Friday, October 29, 2021 5:57 PM
To:
>
<mailto:
<mailto:
>;
Cc: Christian Everdell
>
<CEverdell@CohenGresser.com<mailto:CEverdell@CohenGresser.com>>;
>
Laura Menninger
<lmenninger@hmflaw.com<mailtoImenninger@hmflaw.com>>;. Jeff
Pagliuca
>
<jpagliuca@hmflaw.com<mailto:jpagliuca@hmflaw.com>>
Subject: [EXTERNAL] US V. Maxwell S2 20 Cr 330 (AJN)
Courtesy copy of today's ECF filing.
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Main:
>
bcsternheim@mac.com<mailto:bcsternheim@mac.com-mailto:bcsternheim@mac.com43cmailto:bcsternhein
@mac.com>
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.
V
2021_11_02_07_41_06.pdf>
EFTA00029291


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Subject: Fwd: 21-58 United States of America V. Maxwell "Motion Order FILED denying for bail"
Date: Wed, 02 Jun 2021 14:59:01 +0000
Awesome work!
Begin forwarded message:
From: cmecf@ca2.uscourts.gov
Date: June 2, 2021 at 10:16:05 AM EDT
To:
(USANYS)"
Subject: 21-58 United States of America V. Maxwell "Motion Order FILED denying for bail"
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 06/02/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Document(s): Document(s)
Docket Text:
MOTION ORDER, denying Appellant's renewed motion for bail or to remand to the district court [89] filed by
Appellant Ghislaine Maxwell, by PNL, RJL, RJS, FILED. [3112207][96] [21-58, 21-770]
Notice will be electronically mailed to:
David Oscar Markus, -:
Ms. Bobbi C. Sternheim, -:
EFTA00028701

=== Page 2 ===
Notice will be stored in the notice cart for:
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Motion Order FILED
Original Filename: 21-58 order.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=06/02/2021] [FileNumber=3112207-0]
[52d31235cf3d1b60840eb63086304a0001dbf6513b864286b5968c6da08e7f743075721c60149cd5d750abb8a8
79d5333573674bb433cf500b81f15a67dfb6c]]
EFTA00028702


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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 16:55:57 +0000
Date Modified: 2020-10-22 16:55:57 +0000
Priority: 5
DTSTAMP: 2020-10-22 16:36:53 +0000
Attendee:
EFTA00029141


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Testifying witness notes
Date: Tue, 10 Aug 2021 02:12:46 +0000
Thank you! Yes, we have those deadlines, will forward the calendar invites to you.
From:
Sent: Monday, August 9, 2021 9:21 PM
To:
Cc:
Subject: RE: Testifying witness notes
All set, it's been added to both folders. On a related note, do we have a set deadline for producing testifying witness 3500
and GX to defense/the court yet, or is it still too early?
From:
Sent: Monday, August 9, 2021 9:18 PM
Subject: Testifying witness notes
Hi
Would one of you please save the attached in the testifying witness 3500 folder and the witness folder for Larry Visoski on
the Epstein share?
Thanks,
EFTA00027303


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=== Page 1 ===
From:
To:
Subject: RE: Maxwell
Date: Thu, 02 Jul 2020 18:50:47 +0000
Thanks so much!
From:
Sent: Thursday, July 2, 2020 10:45 AM
To:
Subject: FW: Maxwell
Congrats guys! Great work on such an important case.
From:
Sent: Thursday, July 2, 2020 10:43 AM
To:
Subject: Maxwell
PCU - Please join me in congratulating
on the arrest this morning of Ghislaine Maxwell.
spoke a bit about the case on our call on Tuesday and the truly remarkable job the team has done in bringing it. I won't
repeat all of that, buy you should know, as you read press coverage today that already is making it seem like these charges
were inevitable, that they were anything but, and that they are instead the result of an extraordinary amount of work and
perseverance and creativity by
in building a case based on conduct that I'm pretty sure is older
than all of our paralegals.
will be holding a press conference at 12, and while it is sadly not possible for all of us to be there to join her given
current conditions, I hope we can all take a moment to remotely congratulate the team on a terrific accomplishment in
bringing an extremely important case against a woman very worthy of criminal prosecution.
EFTA00028748


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=== Page 1 ===
From:
To:
Subject: RE: 2020-06-27 GM press release draft.rc.docx
Date: Mon, 29 Jun 2020 20:50:54 +0000
Attachments: 2020-06-27_GM_press_release_draft.rc+ebd.docx
My comments on top of yours.
From:
Sent: Monday, June 29, 2020 1:45 PM
To:
Subject: 2020-06-27 GM press release draft.rc.docx
Edits to PR - want to layer yours on top?
EFTA00028329


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher
)
prepared by a travel arranger is pending your review
Date: Wed, 06 Nov 2019 17:58:24 +0000
Importance: Normal
Dear
Final voucher
) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID:
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose:
- U.S. V. Epstein - Witness Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-11-04 - 2019-11-04
Current status: Pending Voucher Approval
Voucher total expenses: 421.70
Estimated trip cost: 836.70
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0012
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00028799


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=== Page 1 ===
Lisa M. Rocchio, Ph.D.
Johnston, RI
Phone:
Fax:
Disclosure of testimony as of 2/1/2021
Deposition testimony on 12/11/2020 in the matter of C.C V. County of Warren et. al.
Superior Court of NJ, Warren NJ. Docket # WRN-L-000017-15
Deposition testimony on 12/11/2020 in the matter of R.M. V County of Warren, et. al.
Superior Court of NJ, Warren, NJ. Docket # WRN-L-000328-16
Deposition testimony on 8/23/2019 in the matter of: State of NH V. Hugh MacDonald
Rockingham Superior Court, Rockingham, NH Docket # 2182018CR00717
Trial testimony on 6/12/2019 in the matter of: Commonwealth of MA V.. Erika Murray
Worcester Superior Court, Worcester, MA. Docket # WOCR2014-01393
Deposition Testimony in 2011 in the matter of Donna MacAuliffe, Plaintiff, V. Leanard
Pompasello, JR. and Alexander Rubino, Sued Individually, Defendants
United States District Court, Southern District of New York, Docket # 10-cv-8721 (JSR)
Trial testimony in 2002 in the matter of State of RI V. Joy Carter
Washington County District Court, South Kingstown, RI
*Docket number for this case is not available, and stenographer was not present
3502-002
Page 1 of 1
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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From: AUSA
Date: November 9, 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:
FL
Witness TelNos (mobile):
Witness e-mail:
Witness Needed to Appear in SDNY on
Date: November 28, 2021
Time: 11 AM
Witness Needed to Appear for:
Trial (X)
Date: November 29, 2021 all day
Grand Jury ( )
Date:
Trial Prep (X)
Date: November 28, 2021 at 11 AM
Estimated Dates Witness will Arrive:
November 27, 2021 (any time)
Depart:
November 30, 2021 (evening)
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
kennel fees for pets
rev. 2019.11.19
EFTA00027646

=== Page 2 ===
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
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Scanned black book & yellow pages of notes
Date: Thu, 28 Oct 2021 23:45:57 +0000
Attachments: 2021.10.28_Maxwell_Discovery_Letter.pdf
These have been added to the production (here).
Updated cover letter is attached.
From:
>
Sent: Thursday, October 28, 2021 7:34 PM
To:
is
Cc:
is
Subject: FW: Scanned black book & yellow pages of notes
Can we please add these to the pending production to send out tonight? They should marked confidential. The black
book should be described in the index as "Scan of 1 bound black address book marked Government Exhibit 52, as referred
to in SDNY_GM_02753612"; "Scan of 2 stapled handwritten set of documents on yellow legal pad paper, as referred to in
SDNY_GM_02753612"
Can you resend me the updated cover letter once that is ready?
Thanks!
From:
Sent: Thursday, October 28, 2021 7:19 PM
To:
is
is
Subject: [EXTERNAL] Scanned black book & yellow pages of notes
See attached.
NYPD/FBI
Child Exploitation Human Trafficking Task Force
Office:
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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein Brass Meet
Date: Fri, 05 Apr 2019 22:53:35 +0000
Importance: Normal
Attachments: unnamed
EFTA00029174


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=== Page 1 ===
From:
To:
Subject: RE: US V. Epstein - Status Hearing Notification
Date: Thu, 01 Aug 2019 21:24:47 +0000
Attachments: JBAGOYO_20190726095441587_DRAFT.pdf;
JBAGOYO_20190719165055822_DRAFT.pdf
Hi
,
so, I was the one editing the letters...
Attached are the 2 previous notifications for this case that were sent to the Victims and they both don't those edits you
requested.
From:
Sent: Thursday, August 01, 2019 5:01 PM
To:
is
>;
Subject: RE: US V. Epstein - Status Hearing Notification
Hi
Thanks.
has been able to edit the previous letters, so it might be worth checking with her to see how she was able
to do that.
Thanks,
From:
Sent: Thursday, August 1, 2019 4:45 PM
To:
is
V.
Subject: RE: US V. Epstein Status Hearing Notification
Thanks
Attached is the updated version. I'm sorry but I could only update the hearing information. The other edits
can't be done due to the template in VNS which can't be changed. Frustrating I know, but I did my best to make it look
decent. Let me know if I can send it out. Thanks and sorry again!
From:
Sent: Thursday, August 01, 2019 4:24 PM
To:
is
>;
Subject: RE: US V. Epstein - Status Hearing Notification
Hi
Thanks. A few things:
EFTA00029515

=== Page 2 ===
In the case caption, please delete "defendant(s)," so that it does not read "defendant(s) Jeffrey Epstein". I'm not
sure if that's the form language, but it looks like a typo.
Regarding the hearing information, there are several other court dates. I'll forward you the scheduling order so
that you can add them.
Please swap out this language:
Because of the Court's schedule, hearing dates could change on very short notice. If you plan on attending,
you may want to call the VNS Call Center or check the website to confirm the date and time. Please note,
there is a 24-hour delay in information transfer to the website.
And replace it with this language:
If you plan on attending, please call me at
in case there are any last minute changes.
Thanks!
From:
Sent: Thursday, August 1, 2019 4:11 PM
To:
is
is
Subject: US V. Epstein - Status Hearing Notification
Hi there, attached is a status hearing notification which showed up on VNS today for this case. Did you want me to send it
out? Thank you.
Victim-Witness Assistant
U.S. Attorney's Office - SDNY
1 St. Andrews Plaza
New York, NY 10007
Office:
EFTA00029516


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
20 Cr. 330 (AJN)
V.
:
:
GHISLAINE MAXWELL,
:
:
Defendant.
:
:
X
REPLY MEMORANDUM OF GHISLAINE MAXWELL
IN SUPPORT OF HER MOTION TO DISMISS THE SUPERSEDING INDICTMENT
FOR BREACH OF THE NON-PROSECUTION AGREEMENT
Christian R. Everdell
COHEN & GRESSER LLP
Phone:
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Phone:
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
Phone:
Attorneys for Ghislaine Maxwell
EFTA00028880

=== Page 2 ===
TABLE OF CONTENTS
Page
I.
The NPA Applies to Ms. Maxwell, and She Has Standing to Enforce It.
2
II.
The Co-Conspirator Immunity Provision is Not Limited to the SDFL.
7
III.
The Co-Conspirator Immunity Provision Is Not Limited to the 2001-07 Time
Period or to Violations of Specific Statutes.
13
IV.
In the Alternative, the Court Should Conduct Discovery and an Evidentiary Hearing
Regarding the Parties' Intent.
16
CONCLUSION
18
i
EFTA00028881

=== Page 3 ===
TABLE OF AUTHORITIES
Page(s)
Cases
Bank of New York Mellon Trust Co. V. Morgan Stanley Mortg. Capital, Inc.,
821 F.3d 297 (2d Cir. 2016)
8, 9
Collins V. Univ. of Notre Dame Du Lac,
929 F.3d 830 (7th Cir. 2019)
8, 9
Penncro Assocs., Inc. V. Sprint Spectrum, L.P.,
499 F.3d 1151 (10th Cir. 2007)
8,9
United States V. Aleman,
286 F.3d 86 (2d Cir. 2002)
17
United States V. Annabi,
771 F.2d 670 (2d Cir. 1985)
passim
United States V. CFW Const. Co.,
583 F. Supp. 197 (D.S.C. 1984), aff'd, 749 F.2d 33 (4th Cir. 1984)
6
United States V. El-Sadig,
133 F. Supp. 2d 600 (N.D. Ohio 2001)
3,6
United States V. Feldman,
939 F.3d 182 (2d Cir. 2019)
5, 6, 10, 17
United States V. Florida West Int'l Airways, Inc.,
853 F. Supp. 2d 1209 (S.D. Fla. 2012)
3, 4, 6
United States V. Gebbie,
294 F.3d 540 (3d Cir. 2002)
12
United States V. Gonzalez,
93 F. App'x 268 (2d Cir. 2004)
8
United States V. Harvey,
791 F.2d 294 (4th Cir. 1986)
12
United States V. Mariamma Viju (01),
No. 3:15-CR-0240-B, 2016 WL 107841 (N.D. Tex. Jan. 11, 2016)
6
United States V. Padilla,
186 F.3d 136 (2d Cir. 1999)
10
ii
EFTA00028882

=== Page 4 ===
United States V. Sattar,
272 F. Supp. 2d 348 (S.D.N.Y. 2003)
17
United States V. Van Thornout,
100 F.3d 590 (8th Cir. 1996)
12
Other Authorities
Dienst, J., Valiquette, J., Winter, T., and Fitzpatrick, S. "Jeffrey Epstein Confidante Ghislaine
Maxwell Arrested on Sex Abuse Charges." NBC New York. July 3, 2020
15
iii
EFTA00028883

=== Page 5 ===
Ghislaine Maxwell respectfully submits this Memorandum in Support of her Motion to
Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement ("Motion").
As though it were wielding an invisible ink pen, the government adds language to its
Non-Prosecution Agreement ("NPA") with Jeffrey Epstein that does not exist in the text, and
then pretends no one can see the clear, unambiguous language that does appear there. The plain
language of the NPA states, without limitation, that "the United States
will not institute any
criminal charges against any potential co-conspirators of Epstein." Because the Superseding
Indictment ("Indictment") contends that Ms. Maxwell was a co-conspirator of Epstein, the NPA,
on its face, applies here. Thus, the government's only argument, which it makes throughout its
opposition, is that the NPA means something other than what it says.
In suggesting that the parties to the NPA intended to immunize only the four individuals
specifically named in the co-conspirator immunity provision, the government flagrantly ignores
the express statement that immunity is "not limited to" those individuals. In arguing that the
provision binds only the United States Attorney's Office for the Southern District of Florida
("USAO-SDFL"), the government asks the Court to add the words "in this District" to that
provision, on the thin suggestion that the parties must have meant to include the same limitation
on location of prosecution that they included in Epstein's immunity provision, even though they
failed to do so. And for good measure, the government asks the Court to find that the parties
must have intended to limit co-conspirator immunity to specific statutory offenses committed
between 2001 and 2007, even though-again-no such limitation appears in the text of the co-
conspirator immunity provision.
Notwithstanding the bedrock principle that plea agreements are construed strictly against
the government, the government asks the Court to simply assume that the parties intended the
EFTA00028884

=== Page 6 ===
NPA to be read more narrowly than the language provides, arguing that following the NPA's
plain language would contradict "common sense." (Opp. 8, 16.) But a non-prosecution
agreement is not an ordinary contract. Federal prosecutors know how to draft clear limitations
on promises made to criminal defendants, and they have a unique obligation to do so. What
strains "common sense" is the notion that any reasonable prosecutor who intended the NPA to be
read as the government contends would have omitted the limitations and modifications the
government now seeks-particularly when dealing with a defendant who sought to "resolve
globally" his criminal liability. NPA at 2. The Court should therefore decline the government's
invitation to rewrite the NPA to its liking, should enforce the NPA as written, and should grant
Ms. Maxwell's Motion.
In the alternative, the Court should permit discovery and hold an evidentiary hearing to
determine the parties' intent with respect to the co-conspirator immunity provision. While Ms.
Maxwell contends that the NPA unambiguously bars her prosecution here, and that neither
discovery nor a hearing is necessary for the Court to grant this motion, the government's
arguments regarding the NPA parties' intent simply cannot be credited without the consideration
of evidence. Because Ms. Maxwell, as a nonparty, has no personal knowledge regarding the
parties' intent and no access to relevant documents, she should be permitted to take discovery in
advance of any hearing.
I.
The NPA Applies to Ms. Maxwell, and She Has Standing to Enforce It.
The NPA's co-conspirator immunity provision forecloses "any criminal charges against
any potential co-conspirators of Epstein, including but not limited to" four named individuals.
NPA at 5 (emphasis added). The phrase "potential co-conspirators of Epstein" obviously
includes Ms. Maxwell. As the opening statement of the Indictment makes clear: "The charges
I "Opp." refers herein to the Government's Omnibus Opposition to the Defendant's Pre-Trial Motions.
2
EFTA00028885

=== Page 7 ===
set forth herein stem from the role of [Ms. Maxwell] in the sexual exploitation and abuse of
multiple minor girls by Jeffrey Epstein." Indictment " 1. The Indictment also contains two
conspiracy counts that charge Ms. Maxwell with conspiring with Epstein. Id.
9, 15.
According to the government, however, Ms. Maxwell's status as an alleged co-
conspirator of Epstein is somehow insufficient for an NPA that immunizes "potential co-
conspirators of Epstein" to apply to her. The government claims that there is "no evidence that
the parties intended to confer a benefit on her in particular." Opp. 20. In essence, the
government implausibly argues that even though the parties expressly agreed to immunize "any
potential co-conspirators of Epstein," only those individuals whom the parties were thinking
about "in particular" qualify for immunity. The government cites no support for the rule it has
concocted, and case law is to the contrary.
For example, in United States V. Florida West Int 'l Airways, Inc., 853 F. Supp. 2d 1209
(S.D. Fla. 2012), where a corporation had entered into a plea agreement that immunized its
employees, the court held that one of those employees had standing to enforce the agreement as a
third-party beneficiary by virtue of his employment; the court did not require a showing that the
parties thought about protecting that employee "in particular" when they agreed to immunize the
class. Id. at 1228. Similarly, in United States V. El-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio
2001), where a Saudi prince had entered into an agreement with the government that none of the
individuals involved in purchasing guns for two members of the Saudi royal family would be
prosecuted, the court did not require the defendant to show that the government and the prince
intended to immunize him "in particular"; to the contrary, as the court noted, the parties to the
agreement did not even discuss the defendant. Id. at 604.
3
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=== Page 8 ===
Ms. Maxwell thus need not show that the parties to the NPA were thinking of her "in
particular"; rather, it is sufficient that she falls within the class of individuals the parties to the
NPA intended to benefit. See, e.g., Florida West, 853 F. Supp. 2d at 1228 ("the signatory parties
unmistakably intended to confer immunity on a discrete class of corporations and individuals
that could include the Defendants"). And that class is clear from the face of the NPA: "any
potential co-conspirators of Epstein," i.e., anyone else who might be prosecuted in connection
with Epstein's conduct. NPA at 5.
Although the NPA expressly provides that that class is "including but not limited to" the
four individuals named in the co-conspirator immunity provision (NPA at 5), the government
asks the Court to disregard this plain language and instead credit a passage from the report of the
Department of Justice's Office of Professional Responsibility ("OPR Report"2) stating that the
line prosecutor who negotiated the NPA "believed" that only the four individuals expressly
named in the co-conspirator immunity provision "would benefit." Opp. 20-21 (quoting OPR
Report at 167). Regardless of the truth of this decade-after-the-fact and self-serving "belief," it
is immaterial. By agreeing to immunize "potential" co-conspirators "including but not limited
to" the four named individuals, the government explicitly agreed that the NPA would apply to
any others who might be charged as co-conspirators in the future-a class that includes Ms.
Maxwell.
The OPR Report itself re-affirms the intent to extend immunity beyond those already
identified as potential co-conspirators. In reviewing the negotiating history of the parties over
this provision, the OPR Report notes that the government had not specifically contemplated other
potential co-conspirators, yet it also demonstrates that the Epstein defense lawyers consistently
2 The OPR Report, of which only the executive summary had been released previously, has been submitted as
Exhibit 3 to the government's opposition.
4
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=== Page 9 ===
and successfully pushed back against the government's attempts to limit the scope of the
provision. Epstein's lawyers, in fact, insisted on a proposal that would have immunized the four
individuals, "any employee" of one of Epstein's companies, and "any unnamed co-conspirators
for any criminal charge that arises out of the ongoing federal investigation." OPR Report at 166
n.237. Defense counsel's efforts were in line with their representations to the government that
Epstein "wanted to make sure that he's the only one who takes the blame for what happened."
Id. at 167 (internal quotations omitted). When the government "finally revised" the language to
the provision that appears in the signed NPA, it obviously acceded to defense's counsel's desire
to leave open the possibility that other "potential co-conspirators" might someday have occasion
to invoke the immunity provision. Id. at 166.
In addition to being irrelevant, the government's argument that Ms. Maxwell had largely
escaped its attention at the time of the NPA is demonstrably incorrect. The government's own
file demonstrates that the FBI had interviewed Accuser-2³ in 2006 (Opp. 16 n.9; Dkt. 148, Ex. B
(sealed)), and thus had obviously learned of Accuser-2's claims regarding Ms. Maxwell now
included in the Indictment. Indeed, an internal FBI document expressly names Ms. Maxwell as
one of the individuals that the FBI's Miami office "began investigating" in 2006 as part of the
investigation that led to the NPA. (See Ex. A). Thus, the government was clearly aware of Ms.
Maxwell at the time it executed the NPA and agreed to extend the immunity provision to "any
potential co-conspirators." She is covered by the NPA.
As a third party immunized by the NPA, Ms. Maxwell has third-party beneficiary status
to enforce it. While the government cites United States V. Feldman, 939 F.3d 182 (2d Cir. 2019),
for the proposition that "plea agreements differ from commercial contracts" (Opp. 18), the
"differ[ence]" to which the Second Circuit was referring was that in construing a plea agreement,
3 Accuser-2 is identified in the Indictment as Minor Victim-2.
5
EFTA00028888

=== Page 10 ===
courts hold the government to an even higher standard than parties to a commercial contract.
Feldman, 939 F.3d at 189 (describing "meticulous standards of performance" to which
prosecutors are held in negotiating plea agreements). As the government acknowledges, at least
three courts have applied the third-party beneficiary doctrine to confer standing on third parties
to enforce immunity provisions in plea agreements. Florida West, 853 F. Supp. 2d at 1228; El-
Sadig, 133 F. Supp. 2d at 608-09; United States V. CFW Const. Co., 583 F. Supp. 197, 203
(D.S.C. 1984), aff'd, 749 F.2d 33 (4th Cir. 1984). The government's attempt to distinguish these
cases on the ground that they did not "analyze" the applicability of the third-party beneficiary
doctrine to plea agreements (Opp. 19) is utterly nonsensical. As demonstrated in Ms. Maxwell's
opening memorandum ("Mem."), all three courts expressly held that the doctrine applies. Mem.
16-17.
The lone case cited by the government to the contrary does not suggest a different result
here. In United States V. Mariamma Viju (01), the court held that a third party may not enforce
rights under a plea agreement "[w]here the defendant himself can obtain relief" from a broken
plea deal." No. 3:15-CR-0240-B, 2016 WL 107841, *4 (N.D. Tex. Jan. 11, 2016). Here,
Epstein cannot obtain relief for the government's breach of the NPA; not only is he deceased, but
he served the sentence stemming from his guilty plea long before his death, paid millions of
dollars to accusers under the NPA's claims provision, and thus would have had no occasion to
enforce the NPA by withdrawing his guilty plea. Nor is it clear that Epstein could have
withdrawn his plea had the NPA been breached while he was serving his sentence, given that the
NPA-unlike a plea agreement-was not submitted to the state court in which Epstein entered
his plea.
6
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=== Page 11 ===
In sum, the Indictment itself establishes Ms. Maxwell as a "potential co-conspirator of
Epstein," and the clear weight of authority vests her with standing to enforce the co-conspirator
immunity provision as a third-party beneficiary.
II.
The Co-Conspirator Immunity Provision is Not Limited to the SDFL.
Ms. Maxwell demonstrated in her opening brief that the NPA, read as a whole, creates an
affirmative appearance that the parties intended the co-conspirator immunity provision-unlike
Epstein's immunity provision-to apply outside the Southern District of Florida ("SDFL"). In
arguing that the NPA's selective use of language limiting the scope of Epstein's immunity
applies to the entire NPA, the government inverts fundamental principles of contract law and
asks the Court to read nonexistent limitations into the NPA. The government then, incredibly,
proceeds to fault Ms. Maxwell-a nonparty to the NPA-for failing to possess and produce
evidence regarding the parties' intent in negotiating the agreement. While the text of the NPA,
read using basic principles of contractual interpretation, unambiguously prohibits the
government from prosecuting Epstein's potential co-conspirators in any district, to the extent that
the Court finds it necessary to consider extrinsic evidence, that evidence is in the hands of the
government and Epstein's attorneys-and thus Ms. Maxwell should be permitted to obtain it
through discovery.
The government argues that application of the co-conspirator immunity provision beyond
the SDFL is barred by United States V. Annabi, 771 F.2d 670 (2d Cir. 1985) (per curiam), in
which the Second Circuit stated that "[a] plea agreement binds only the office of the United
States Attorney for the district in which the plea is entered unless it affirmatively appears that the
agreement contemplates a broader restriction." Id. at 672.4 Ms. Maxwell's opening brief
4 Contrary to the government's suggestion, no court has held that an "affirmative[] appear[ance]" requires an explicit
"promise to bind other districts." See Opp. 4. Rather, in interpreting a plea agreement, "[t]he court looks to the
7
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=== Page 12 ===
demonstrated that the NPA, as a whole, gives rise to such an appearance-and the government
offers no reasonable alternative interpretation.
Unlike Annabi and its progeny, the NPA here contains significant evidence of the parties'
intent to apply the co-conspirator immunity provision outside the SDFL. While the provision
granting immunity to Epstein himself expressly limits his immunity to prosecutions "in this
District," NPA at 2, the co-conspirator immunity provision contains no such limitation.
"[W]here contract provisions use different language, courts must assume the parties intended
different meanings." Bank of New York Mellon Trust Co. V. Morgan Stanley Mortg. Capital,
Inc., 821 F.3d 297, 309 (2d Cir. 2016); see also Collins V. Univ. of Notre Dame Du Lac, 929 F.3d
830, 841 (7th Cir. 2019) (noting "common, if not automatic presumption" that "when parties to
the same contract use such different language to address parallel issues, it is reasonable to infer
that they intend this language to mean different things") (internal punctuation and citation
omitted); Penncro Assocs., Inc. V. Sprint Spectrum, L.P., 499 F.3d 1151, 1156-57 (10th Cir.
2007) (same). Thus, the appropriate inference here is that the parties intended to limit Epstein's
immunity, but not immunity for potential co-conspirators, to prosecutions in the Southern
District of Florida ("SDFL").
The government offers no reasonable alternative explanation for the contrasting language
in the two provisions. Instead, it argues that because the parties limited Epstein's immunity to
the SDFL, they must have meant to limit co-conspirators' immunity to the SDFL as well, but
must have forgotten to include the appropriate language. This argument-that the use of
different language in parallel provisions compels an inference that identical, rather than different
meanings, are intended-turns fundamental contract interpretation on its head. See, e.g., Bank of
reasonable understanding of the parties as to the terms of the agreement." United States V. Gonzalez, 93 F. App'x
268, 270 (2d Cir. 2004) (internal citations and emphasis omitted).
8
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=== Page 13 ===
New York Mellon Trust Co., 821 F.3d at 309; Collins, 929 F.3d at 841; Penncro Assocs., 499
F.3d at 1156-57. Here, the NPA contains only two immunity provisions: one for Epstein, which
is expressly limited to the SDFL, and one for co-conspirators, which is not. The government's
claim that this distinction reflects an intent to apply the limitation universally strains credulity.5
It is simply inconceivable that any reasonable prosecutor who intended to limit the co-
conspirator immunity provision to the SDFL-and who had thought to include precisely such
limiting language in Epstein's immunity provision-would have found it unnecessary to include
identical language in the co-conspirator immunity provision. Indeed, the omission reveals an
intent not to so limit that provision.
Ms. Maxwell's opening memorandum pointed out a second indication in the text of the
NPA that the parties intended to apply the co-conspirator immunity provision outside the SDFL:
where a provision in the NPA is intended to refer only to the USAO-SDFL, it does so explicitly.
See Mem. at 8-9 (citing examples of NPA's explicit references to USAO-SDFL). While the
government is correct that the use of the term "the United States" in a plea agreement, without
more, is insufficient under Annabi and its progeny to demonstrate an intent to bind other
districts, the NPA's references to both the USAO-SDFL and "the United States" require an
inference that a distinction between the two is intended-and that where "the United States" is
used, the intent is to refer to the government as a whole. Again, "where contract provisions use
different language, courts must assume the parties intended different meanings." Bank of New
York Mellon Trust Co., 821 F.3d at 309. The government does not even attempt to offer an
5 The government incorrectly cites to a brief filed by the USAO-SDFL in 2013 as taking the position that "the NPA
did not bind other districts." Opp. 13 (quoting Government Brief, 08 Civ. 80736 (KAM), Dkt. No. 205-2, at 10-11
(S.D. Fla.)). But the cited passage in that brief argued only that the NPA did not bar the prosecution of Epstein in
other districts, which is not in dispute; it made no such argument with respect to the prosecution of potential co-
conspirators. In any event, any self-serving attempts by the USAO-SDFL to limit the NPA's applicability years
after it was executed-after the NPA had been widely criticized and scrutinized-are no more probative of the
parties' intent in 2007 than the arguments made by the government here.
9
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=== Page 14 ===
alternative explanation for this difference in terminology, reasonable or otherwise-presumably
because it cannot.
Thus, a drafting prosecutor who intended to limit the co-conspirator immunity provision
to the SDFL clearly knew how to do so, using either of two methods employed elsewhere in the
document. The government could have used the same language in the co-conspirator immunity
provision that it used in the Epstein immunity provision, providing that "the United States
will not institute any criminal charges in this District against any potential co-conspirators of
Epstein." It did not. Alternatively, it could have referred expressly to the USAO-SDFL, as it did
elsewhere in the NPA, and provided that "the United States Attorney's Office
will not
institute any criminal charges against any potential co-conspirators of Epstein." Again, it did
not. It would be absurd to conclude that a reasonable prosecutor who had used both drafting
tools to limit other provisions of the NPA, yet failed to use either of them in the co-conspirator
immunity provision, intended to impose the same limitations on the co-conspirator immunity
provision-let alone that Epstein would reasonably have understood this intent.
The government's inability to provide a reasonable alternative explanation for its use of
different language in the different provisions of the NPA removes any potential ambiguity from
the co-conspirator immunity provision. But to the extent there remains any doubt, plea
agreements must be construed "strictly against the government," Feldman, 939 F.3d at 189
(internal citations omitted), and the government is held "responsible for imprecisions or
ambiguities in the agreement." United States V. Padilla, 186 F.3d 136, 142 (2d Cir. 1999).
While the government argues that Annabi relieves it of this responsibility where the
"imprecisions or ambiguities" relate to the geographic applicability of a plea agreement (Opp. 6
n.2), it cites no authority for this proposition. While Annabi requires an affirmative appearance
10
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=== Page 15 ===
that the NPA is binding outside the SDFL, any ambiguity as to whether such an appearance
exists must still be resolved against the government.6
Nor does the idea that the government agreed to broader immunity for Epstein's potential
co-conspirators than for Epstein himself "strain[] common sense," as the government argues.
See Opp. 8. According to the OPR Report, the line prosecutor stated that her office "considered
Epstein to be the top of the food chain, and we wouldn't have been interested in prosecuting
anyone else." OPR Report at 70. She also reportedly said that Epstein "wanted to make sure
that he's the only one who takes the blame for what happened." Id. at 167 (internal quotations
omitted). And Epstein and his counsel were clearly aware that the investigation had extended
beyond the SDFL and involved New York-based witnesses. Under such circumstances, any
competent defense lawyer would have sought the broadest immunity possible for Epstein's
potential co-conspirators, in order to limit the potential that he would become embroiled in the
prosecution of a third party-and in fact, Epstein did not agree to the NPA until the co-
conspirator immunity provision was included. And it is entirely logical that the government
agreed to a broader immunity for potential co-conspirators, whom it had no interest in
prosecuting, than for Epstein himself, who was the sole focus of the government's prosecution
efforts. This outcome is consistent with the language of the NPA.
The text of the NPA, read as a whole, thus creates an affirmative appearance that the co-
conspirator immunity provision is not limited to the SDFL, and it is unnecessary for the Court to
6 Notwithstanding the mountain of authority, in this Circuit and elsewhere, articulating the exacting standards to
which the government is to be held in negotiating a plea agreement, the government implies that such standards
somehow do not apply when the plea agreement is enforced by a third party. Opp. 6 n.2. This suggestion is
unsupported by any authority, and the government offers no explanation why its promises of third-party immunity
should be held to a lower standard than other provisions of a plea agreement.
11
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=== Page 16 ===
consider extrinsic evidence of the parties' intent.⁷ To the extent that the Court finds that
extrinsic evidence is relevant, however, the government's argument demonstrates precisely why
the Court should permit discovery in this action. While the government ludicrously faults Ms.
Maxwell for failing to produce "documentary evidence" of the parties' intent and the scope of
the SDFL investigation (Opp. 10), Ms. Maxwell, as a nonparty to the NPA, has no access to such
evidence without discovery. Any evidence of the parties' intent would be in the possession of
the government and Epstein's counsel, and at this stage, Ms. Maxwell can only scour the few
clues available to the public-such as a privilege log filed in a related civil lawsuit-for crumbs
of information about the negotiation and investigation.
The government's response to those crumbs illustrates why any consideration of extrinsic
evidence-which, as noted above, is unnecessary given the unambiguous text of the NPA-
should be preceded by discovery. In her opening memorandum, Ms. Maxwell cited to three
pages from the above-referenced privilege log in a civil lawsuit filed by one of Epstein's victims,
all of which contain entries reflecting the USAO-SDFL's consultation with the United States
Attorney's Office for this District, travel by USAO-SDFL attorneys to New York, or interviews
and/or subpoenas of New York-based witnesses. Mem. at 11 (citing Privilege Log, Doe V.
United States, Case No. 9:08-CV-80736 (S.D. Fla.), Dkt. No. 212-1 (filed July 19, 2013)
("SDFL Privilege Log"), at 4, 5, 7). In response, the government has focused on only one of
those three entries and produced the documents referenced in the privilege log. See Opp. 10.
7 The government's argument that a United States Attorney lacks the "authority" to bind other districts (Opp. 13-
14)-and that the government can simply walk away from a plea agreement in which a United States Attorney has
not received the approvals prescribed by internal Justice Department guidelines-is unavailing. The government
cites no case in which a court has invalidated a plea agreement on this basis, and its argument is contradicted not
only by the Third, Fourth, and Eighth circuits-in which the default rule is that plea agreements bind other
districts-but also by the Second Circuit's statement that a United States Attorney may bind other districts in a plea
agreement if there is an affirmative appearance to that effect. United States V. Gebbie, 294 F.3d 540, 547-49 (3d
Cir. 2002); United States V. Van Thornout, 100 F.3d 590, 594 (8th Cir. 1996); United States V. Harvey, 791 F.2d
294, 303 (4th Cir. 1986); Annabi, 771 F.2d at 672.
12
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=== Page 17 ===
The other two documents remain unavailable to Ms. Maxwell-as, presumably, do other
documents whose existence cannot be discovered in the public record. Nor has Ms. Maxwell
had the opportunity to question those involved in the investigation and negotiation. It is patently
unreasonable for the government to blame Ms. Maxwell for failing to produce evidence relating
to the investigation and negotiation leading up to the NPA, while simultaneously opposing her
request for discovery and cherry-picking its responses to the limited publicly available
information she has been able to identify. That limited information has already yielded
supportive documents and more will no doubt follow with further discovery.
III.
The Co-Conspirator Immunity Provision Is Not Limited to the 2001-07 Time Period
or to Violations of Specific Statutes.
The government's argument that the co-conspirator immunity provision does not apply to
the time period or the offenses charged in the Indictment consists of (i) asserting that the NPA
says things it does not, in fact, say and (ii) attacking a strawman position, never asserted by Ms.
Maxwell, that the NPA gives Ms. Maxwell carte blanche immunity from federal prosecution for
all past and future criminal conduct of any kind, wherever and whenever committed. The co-
conspirator immunity provision simply does not contain the limitations the government now
seeks to attribute to it, and Ms. Maxwell's position that it prohibits the Mann Act charges against
her is entirely reasonable. 8
First, the government's assertion that "the NPA contains detailed provisions that limit the
scope of the crimes immunized in the agreement" is simply not true. See Opp. 15. The NPA
contains only vague limitations as to the scope of Epstein's immunity, and no limitations
whatsoever as to the scope of immunity for potential co-conspirators.
8 To be clear, Ms. Maxwell does not assert that the NPA forecloses the perjury counts of the Indictment, which arise
out of alleged post-NPA conduct.
13
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=== Page 18 ===
As to Epstein, the NPA prescribes immunity for three categories of offenses: (i) "the
offenses set out on pages 1 and 2 of this Agreement"; (ii) "any other offenses" that were the
subject of the "joint investigation" by the FBI and the USAO-SDFL; and (iii) "any offenses that
arose from the Federal Grand Jury investigation." NPA at 2. The government's assertion that
the NPA bars prosecution only for "the specific offenses enumerated in the NPA" (Opp. 15-16)
deliberately ignores the second and third categories listed above. The second category is
significant because, contrary to the government's argument, the NPA does not purport to "list[]
each and every statutory offense under investigation" (see Opp. 15); rather, it states only that the
investigation involved offenses "including" those enumerated. NPA at 1. Moreover, the NPA
expressly states that the joint investigation included not only offenses committed from
approximately 2001 to 2007, but also "Epstein's background." Id. The scope of the third
category-offenses that arose "from the Federal Grand Jury investigation"-is completely
unknown, as the NPA neither defines the term "Federal Grand Jury investigation" nor describes
its scope. But the text of the NPA provides no basis for the government's assertion that Epstein
was immunized only as to the specific offenses enumerated on the first two pages.
As an example, the USAO-SDFL acknowledges that it interviewed Accuser-2 as part of
its investigation. Opp. 16 n.9. Thus, the USAO-SDFL obviously was aware of the allegations
by Accuser-2 against Epstein as set forth in the Indictment, allegations that entail the 1994-97
time period at issue in this case and the offenses with which Ms. Maxwell is charged. If the
NPA were strictly limited to the 2001-07 time period and to the specific offenses enumerated, as
9 Contrary to the government's argument, Ms. Maxwell does not contend that the NPA "immunize[d] Epstein for his
'background.' See Opp. 16 n.9. On its face, however, it immunized Epstein for offenses that were the subject of
the joint investigation-an investigation that, according to the NPA, included Epstein's background. NPA at 1. To
the extent that the joint investigation of Epstein's background uncovered offenses prior to 2001 (such as the conduct
underlying the charges against Ms. Maxwell here), the plain language of the NPA immunized Epstein from
prosecution for those offenses.
14
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=== Page 19 ===
the government claims, it would not have precluded even the SDFL from bringing charges
arising out of Accuser-2's allegations of conduct in the 1990s. The government cannot seriously
make such an argument.
Even the vague contours of the limitations on Epstein's immunity, however, are absent
from the co-conspirator immunity provision. And while the government claims it would be
"exceedingly strange" to interpret the co-conspirator immunity provision more broadly than
Epstein's immunity provision (Opp. 16), as explained in Part II above, such an interpretation is
entirely consistent with the government's focus on Epstein vis-à-vis potential co-conspirators. It
would be "exceedingly strange," however, for a federal prosecutor who intended to limit co-
conspirator immunity to specific conduct or specific offenses to omit such limitations from the
text of an immunity provision in a non-prosecution agreement.
Unable to explain the absence of such limiting language, the government resorts to the
reductio ad absurdum argument that unless the Court writes into the NPA the language the
government now wishes had been included in 2007, Ms. Maxwell can claim that "she is immune
from prosecution for any federal crime, during any time period, anywhere, in the United States."
Opp. 3 (emphasis in original). Ms. Maxwell makes no such argument, and a faithful
interpretation of the NPA leads to no such conclusion. Ms. Maxwell contends only that a
provision that immunizes "potential co-conspirators of Epstein" precludes their prosecution for
conduct allegedly done in conspiracy with Epstein-conduct that even the United States
Attorney for this District has characterized as a "prequel" to offenses by Epstein that the NPA
undisputedly immunizes. See, e.g., Dienst, J., Valiquette, J., Winter, T., and Fitzpatrick, S.
"Jeffrey Epstein Confidante Ghislaine Maxwell Arrested on Sex Abuse Charges." NBC New
York. July 3, 2020 (https://www.nbcnewyork.com/news/local/crime-and-courts/ghislaine-
15
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=== Page 20 ===
maxwell-arrested-jeffrey-epstein-aide/2495762/). Such an interpretation, rather than an insertion
into the co-conspirator immunity provision of arbitrary limitations designed to satisfy the
government's interests here, is the "common-sense way to read the NPA" that the Court should
adopt. See Opp. 16.
IV.
In the Alternative, the Court Should Conduct Discovery and an Evidentiary
Hearing Regarding the Parties' Intent.
For the reasons explained above, Counts One through Four have been brought in breach
of the NPA and should be dismissed. The text of the NPA, read as a whole, unambiguously bars
Ms. Maxwell's prosecution here, and the government is reduced to arguing that the parties must
have meant to write various provisions of the NPA differently than they actually did. These
arguments are manifestly inadequate, and they should be rejected.
Should the Court have any doubt about the parties' intent, however, discovery and an
evidentiary hearing regarding the parties' intent are warranted. The government's arguments
regarding the parties' intent simply cannot be credited without the presentation of evidence. For
example, to the extent that the scope of offenses for which the NPA immunized Epstein is
deemed relevant to the co-conspirator immunity provision, that scope cannot be delineated
without determining precisely which offenses might have arisen out of the investigation by the
FBI and the USAO-SDFL (including the investigation into "Epstein's background"), as well as
which offenses arose out of the undefined "Federal Grand Jury investigation." Similarly, the
government's claims that the parties did not intend to confer the benefit of immunity on Ms.
Maxwell, and that the parties intended to limit the co-conspirator immunity provision to the
SDFL, raise issues regarding the scope of the SDFL investigation, the USAO-SDFL's awareness
of Ms. Maxwell, and the extent to which the investigation involved this District. These issues
16
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=== Page 21 ===
cannot be resolved in the government's favor on this record, and the plain language of the NPA
cannot be disregarded without discovery and an evidentiary hearing.
The government argues that Ms. Maxwell is not entitled to an evidentiary hearing
because she has not submitted affidavits, and that she is not entitled to discovery because she has
offered only "conjecture." Opp. 22. But unlike the cases the government cites, Ms. Maxwell has
submitted evidence far more powerful than an affidavit claiming an oral agreement: she has
submitted the NPA itself, which, on its face, bars her prosecution. See Feldman, 939 F.3d at
184, 190 (hearing based on oral representations made to defendant); United States V. Aleman,
286 F.3d 86, 91 (2d Cir. 2002) (granting hearing where defendant submitted attorney affidavits
alleging oral agreement); United States V. Sattar, 272 F. Supp. 2d 348, 383 (S.D.N.Y. 2003)
(same). Ms. Maxwell's contention that the plain language of the NPA reflects the parties' intent
is not "conjecture," and the Court cannot find to the contrary without hearing evidence-
evidence that we anticipate would confirm that the parties intended the NPA to mean exactly
what it says and that it bars the prosecution of Ms. Maxwell, but is unavailable to Ms. Maxwell
without discovery.¹⁰
10 In addition, unlike the defendants in the cases the government cites, Ms. Maxwell was a nonparty to the NPA, and
her attorneys thus have neither firsthand knowledge of the parties' intent nor access to evidence regarding the
parties' intent. While the government points out that Ms. Maxwell has not submitted an affidavit from Epstein's
counsel, defense counsel notes that it has made several unsuccessful attempts to obtain information from Jay
Lefkowitz, the attorney who was principally involved in negotiating the language of the NPA on Epstein's behalf.
17
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=== Page 22 ===
CONCLUSION
For the reasons set forth herein, Ms. Maxwell respectfully requests that her motion to
dismiss be granted. In the alternative, Ms. Maxwell respectfully requests discovery and
evidentiary hearing regarding the parties' intent in negotiating the NPA.
Dated: March 15, 2021
New York, New York
Respectfully submitted,
/s/ Christian R. Everdell
Christian R. Everdell
COHEN & GRESSER LLP
Phone:
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Phone:
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
Phone:
Attorneys for Ghislaine Maxwell
18
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=== Page 23 ===
CERTIFICATE OF SERVICE
I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the
Court's individual practices in criminal cases, the within memorandum and any accompanying
exhibits upon the following:
U.S. Attorney's Office, SDNY
/s/ Christian Everdell
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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Date: Thu, 11 Jul 2019 02:22:44 +0000
Importance: Normal
Thanks
From:
Sent: Wednesday, July 10, 2019 10:09 PM
To:
is
)
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
I can conference you in if she calls me directly
From:
Sent: Wednesday, July 10, 2019 22:07
To:
is
)
Subject: FW: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
I'm at my desk if you want to have a call.
From: Roberta Kaplan
Sent: Wednesday, July 10, 2019 10:06 PM
To:
is
Conlon
>; Jenna Dabbs
>; Alexandra Elenowitz-Hess
Cc:
is
Subject: Re: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Can you talk?
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
New York, New York 10118
From:
Sent: Wednesday, July 10, 2019 5:56:39 PM
To:
Conlon; Roberta Kaplan; Jenna Dabbs; Alexandra Elenowitz-Hess
Cc:
);
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Hi all,
As you may already know, pursuant to the Crime Victims' Rights Act, specifically 18 U.S.C. 3771(a)(4), a crime victim has
the right to be reasonably heard at certain public proceedings in the district court, including proceedings involving
release. Accordingly, we wanted to be in touch consistent with our responsibilities and obligations-and your client's
EFTA00028355

=== Page 2 ===
rights-under that statute, to see whether your client would like to be heard in any fashion, whether through a
submission, a representation that we can include in our bail submission due Friday, or some other form. Of course no
requirement or obligation, but we would be happy to discuss it if that would be useful.
To the extent this information is useful in your consideration, I can say that while I don't want to prejudge the
Would it make sense to set up a brief call sometime tomorrow, if any of you want to discuss? I should be able to make
myself available whenever is convenient for you (and likely will be just me, as the remainder of the team will be traveling).
thank you,
Assistant U.S. Attorney
Southern District of New York
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.
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=== Page 1 ===
From:
To: "Martin G. Weinberg"
Cc:
"Miller, Michael"
>, , 'Reid
Weingarten'
Subject: RE: Protective Order
Date: Wed, 24 Jul 2019 21:58:36 +0000
Attachments: 2019-07-24,_JE,_protective_order_for_discovery_(RMB).pdf
Marty,
Attached is a revised protective order, which incorporates the edits from our discussion today. If there are any issues or
questions, please let us know. Otherwise, if you could please send us a signed copy, we'll take care of submitting it to the
Court.
Thanks,
From: Martin G. Weinberg
Sent: Wednesday, July 24, 2019 10:51 AM
To:
; 'Martin Weinberg'
Cc:
;
'Miller, Michael'
>; 'Reid Weingarten'
Subject: RE: Protective Order
Hi
Some points for discussion or consideration re draft Protective Order:
Pg 2, line 2 - we consent to the entry of the Order but not necessarily all of the averments made by the Government in
support of the Order
Pg 3 - par 2 - we need to distinguish between providing discovery electronically to others on the defense team (encrypt or
password protected) and providing hard copies of discovery for the purpose of review by counsel or by counsel or others
on defense team with the defendant at MCC
Pg 3 - par 3-5 - these obligations should extend to Govt as well as defense
Pg 3 - par 4 - are you precluding public discussion of identity of witnesses already known to the defense i.e. known
independent of the discovery
Pg 3/4 - par 5 - are you asking for redacted public filings or the entire filing being filed under seal - we could redact any
quoting of the discovery or attaching of the discovery if that suffices
Pg 4-5 par 7 - there is no need for allegations of potential obstruction or harm to witnesses in this case - I would request
that such language be redacted as unnecessary if we are not contesting the clause. Please advise if the Govt intends to
mark all 302s as "confidential" or just the identifying info (names, addresses, etc).
Par 12 - defense should be allowed to retain discovery through the filing date of a 2255
Reid, Mike may have additional questions, points.
Available after 1 to discuss.
Thanks
Marty
Martin G. Weinberg, Esq.
EFTA00028423

=== Page 2 ===
Boston, MA 02116
This Electronic Message contains information from the Law Office
of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee
only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents
of this message is prohibited.
From:
Sent: Tuesday, July 23, 2019 7:02 PM
To: Martin G. Weinberg
Cc:
Subject: Protective Order
Marty,
Following up on our conversation this morning, I'm attaching the proposed protective order we discussed. If you have any
questions, or think it would be productive to schedule a call to discuss, please let us know.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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From:
)"
To:
(USANYS)"
Subject: RE: conditions in SHU
Date: Fri, 05 Jul 2019 18:09:03 +0000
Importance: Normal
Ok great thanks.
From:
(USANYS)
Sent: Friday, July 5, 2019 2:08 PM
To:
Subject: Re: conditions in SHU
Yeah whole day is free. I just have to drop
so that's why 915 is usually earliest I can do. So pick time that works for
you and l'll be free.
Assistant U.S. Attorney
On Jul 5, 2019, at 14:05,
)
wrote:
I was actually thinking earlier because I have to start prep for GJ at 9. If that won't work, how's your afternoon?
From:
(USANYS)
Sent: Friday, July 5, 2019 2:02 PM
To:
)
Subject: Re: conditions in SHU
9:15?
Assistant U.S. Attorney
On Jul 5, 2019, at 13:50,
wrote:
Would you be available for a call first thing in the morning?
From:
Sent: Friday, July 5, 2019 1:38 PM
To:
>;
(USANYS)
is
)
is
(USANYS)
Subject: Re: FW: conditions in SHU
Hi
is out today and I'm not sure what his schedule is for Monday. Is there a particular time that works (or doesn't
work) for you?
Thanks,
EFTA00028384

=== Page 2 ===
Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, NY 10007
p:
f:
=
)"
> 7/5/2019 1:24 PM >>>
We should discuss this issue as well as the cellphone on a call on Monday.
what times would work for
you on Monday?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Bruce Barket
Sent: Friday, July 5, 2019 1:02 PM
To:
>
(
is
Cc:
)
is
(USANYS)
V.
tonyricco
(
>; Aida Leisenring
Subject: conditions in SHU
Good afternoon,
As I think you all know Nick has been placed in SHU based on an allegation that he was in possession of a cell phone. If
true, I understand that some appropriate and proportional sanction may be in order.
Leaving that aside I want to address the conditions in his cell. The toilet is leaking and the floor is wet. As of
Wednesday, he hasn't received his personal property, including his books. He has been sitting in the cell with literally
nothing to read, listen to or watch. Can we please make an effort to get him reading material, his radio and the
accompanying batteries.
Most troubling is that he tells me that the legal work he had out when he was removed from the cell has not been
returned to him. This included documents prepared for him by my office which contained substantial and sensitive
work product that falls squarely within the attorney client privilege. Nick made notes on some of these documents to
prepare for our next meeting. When I saw him Wednesday, he had some of his legal paperwork but not the
documents he was working with when he was taken from the cell. I am very concerned that these documents have
EFTA00028385

=== Page 3 ===
been seized by the staff at MCC. Can you please take steps to see to that all of this material be returned to him
immediately.
Lastly, I am hoping we can find time early next week to discuss the conditions of Nick's confinement going forward.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
[P]
[F]
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
EFTA00028386


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=== Page 1 ===
From:
Subject: FW: Ghislaine Maxwell 02879-509
Date: Fri, 08 Jan 2021 18:21:05 +0000
FYI
Original Message
From:
Sent: Friday, January 8, 2021 1:15 PM
To: BOBBI C STERNHEIM <bcsternheim@mac.com>
Cc:
>; Christian Everdell
<CEverdell@cohengresser.com>; Mark S. Cohen <mcohen@cohengresser.com>;
)
Subject: Re: Ghislaine Maxwell 02879-509
Good afternoon Bobbi:
As you noted Ms. Maxwell has continuously been produced in advance of
12:30 PM. In addition, I would like to note that while Ms. Maxwell was produced after the scheduled time
(twice), the additional time was provided to compensate for the delay. Please understand that while we are
working to ensure all inmates are produced for their court and legal calls, there are institutional emergencies that
require additional assistance, causing staff to slightly deviate from time frames.
Should you request a copy of the incident report, Ms. Maxwell may provide you with it, however I cannot. I can
further assure you that the daily searches are consistent with BOP Program Statement § 552.06, Searches of
Housing Units, Inmates, and Inmate Work Areas. It is my understanding that gloves and masks were recently
brought to the unit.
Any further concerns you have indicated will be reviewed and addressed accordingly if need be.
Thank you for your time and patience in this matter,
1/7/2021 9:50 PM
For the past two days, Ms. Maxwell has not been on time for the daily
12:30 VTCs. Yesterday, she arrived at 12:59; today she arrived at 12:47. Until yesterday, Ms. Maxwell appeared
in advance of 12:30. We appreciate
's assistance in facilitating Ms. Maxwell's appearance, but no
explanation has been provided for these delays..
Each delay limits the time Ms. Maxwell can confer with counsel. We hope this will not be repeated and is not
retribution for complaints made by counsel.
We learned today that the complaint report issued to Ms. Maxwell earlier this week has now been revised. I
renew my request for the original report and request a copy of the updated report.
This morning at 6:40 am, the team leader ordered Ms. Maxwell to clean a toilet, providing a few paper towels,
but no gloves, sending a clear message that Ms. Maxwell should clean the toilet bare handed, despite having
cleaned the toilet the night before. Gloves were provided only upon request by Ms. Maxwell. Per the A&O
Handbook, sanitation duties commence at 7:30 am for pretrial inmates (See A&O, p.4). We request that Ms.
EFTA00027923

=== Page 2 ===
Maxwell be permitted to perform sanitation duties in the evening when returned to her isolation cell.
Further, the team leader ordered Ms. Maxwell to clean crumbs from her bed. Lest she face another charge of
being untidy, Ms. Maxwell attempted to comply but there were no crumbs - just stains on the blanket issued to
her. This is another example of the petty officiousness displayed by the present team.
The ear searches continue. Routinely, in connection with open mouth searches, guards run fingers through Ms.
Maxwell's hair and behind her ears, at times before she gets a chance to put on her face mask. These searches -
conducted within 6 inches of Maxwell's face- continue to increase her risk of exposure to COVID. The
number of daily searches of Ms. Maxwell, an isolated inmate under constant surveillance by multiple guards,
seems excessive and unnecessarily violative..
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Main:
Cell:
Fax:
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.
EFTA00027924


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: RE: Request to Produce Ghislaine Maxwell to 500 Pearl Street
Date: Tue, 06 Apr 2021 19:43:13 +0000
Thanks!
From:
Sent: Tuesday, April 6, 2021 3:41 PM
To:
Cc:
is
(
Subject: Re: Request to Produce Ghislaine Maxwell to 500 Pearl Street
Absolutely
On Apr 6, 2021, at 15:36,
wrote:
Excellent, thank you!
Ok for me to park at 1 St. Andrews on 4/13 through 4/16 so that I can be present for this review, please?
From:
Sent: Tuesday, April 6, 2021 3:34 PM
To:
Cc:
is
(
)
Subject: RE: Request to Produce Ghislaine Maxwell to 500 Pearl Street
Yes. I say by 9:15 so a 9:30 start time each day seems right.
From:
Sent: Tuesday, April 6, 2021 3:33 PM
To:
Cc:
is
(
)
Subject: RE: Request to Produce Ghislaine Maxwell to 500 Pearl Street
Thanks so much! So the Marshals are willing to produce her multiple days in a row? And do you know what time they
plan to arrive with her at 500 Pearl?
From:
Sent: Tuesday, April 6, 2021 3:29 PM
To:
Cc:
is
(
)
Subject: RE: Request to Produce Ghislaine Maxwell to 500 Pearl Street
All set for next week.
EFTA00027378

=== Page 2 ===
From:
Sent: Monday, April 5, 2021 4:32 PM
To:
Cc:
Subject: Request to Produce Ghislaine Maxwell to 500 Pearl Street
Hi
Following up on our earlier conversation, defense counsel for Ghislaine Maxwell (USMS No.
)
has requested
to schedule time for Maxwell and her attorneys to review physical evidence in the FBI's custody. The FBI and AUSAs are
able to bring the evidence to the 500 Pearl proffer rooms in order for the review to take place there. Defense counsel
have requested that the first day of review take place on Tuesday, April 13, 2021. Because there is a large volume of
items to review, defense counsel expects that the review will take multiple days. They have requested that Maxwell be
produced on April 13th and every day thereafter until the review is completed.
Would it be possible to please have Maxwell produced on April 13th and every day thereafter until the review is
complete? My best estimate is that the review will take four days, so Maxwell would need to be produced on April 13,
14, 15, and 16. That said, it is always possible the defense will need more time, which would push into the next week.
Thanks very much for your help.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00027379


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=== Page 1 ===
From:
To:
Cc:
Subject: Motion to preclude Dietz and Loftus
Date: Tue, 09 Nov 2021 04:54:24 +0000
Attachments: Motion_to_preclude_-_ECFpdf
Here's the motion as to Dietz and Loftus.
Assistant U.S. Attorney
Southern District of New York
EFTA00027641


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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
May 20, 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:
Today we are producing the materials listed in the below index. These discovery materials
are stamped with control numbers SDNY_GM_02753432 through SDNY_GM_02753551 and
SDNY_GM_SUPP_00219450 through SDNY_GM_SUPP_00219451.
Regarding the materials stamped with control numbers SDNY_GM_02753529 through
SDNY_GM_02753551, 02753551, these folders contain native image files from several devices that
correspond with images previously produced to you in PDF format on November 9, 2020. The
enclosed spreadsheet indicates which control numbers with "SDNY_GM_SUPP" prefixes
correspond with these native "carved" images. The enclosed spreadsheet also details the original
file names of the "carved" files that were previously produced to you in their native format, also
on November 9, 2020.
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. An index of the materials contained in this production is below:
EFTA00028733

=== Page 2 ===
Page 2
Bates Start
Bates End
Summary Description
Confidential
Designation
SDNY_GM_02753432
SDNY_GM_02753528
Interlochen records
Confidential
SDNY_GM_02753529
SDNY_GM_02753529
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024321
SDNY_GM_02753530
SDNY_GM_02753530
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024323
SDNY_GM_02753531
SDNY_GM_02753531
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024324
SDNY_GM_02753532
SDNY_GM_02753532
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024326
SDNY_GM_02753533
SDNY_GM_02753533
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024332
SDNY_GM_02753534
SDNY_GM_02753534
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024336
SDNY_GM_02753535
SDNY_GM_02753535
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024337
SDNY_GM_02753536
SDNY_GM_02753536
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024340
SDNY_GM_02753537
SDNY_GM_02753537
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024341
SDNY_GM_02753538
SDNY_GM_02753538
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024343
SDNY_GM_02753539
SDNY_GM_02753539
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024348
EFTA00028734

=== Page 3 ===
Page 3
SDNY_GM_02753540
SDNY_GM_02753540
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024349
SDNY_GM_02753541
SDNY_GM_02753541
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024350
SDNY_GM_02753542
SDNY_GM_02753542
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024351
SDNY_GM_02753543
SDNY_GM_02753543
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024363
SDNY_GM_02753544
SDNY_GM_02753544
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024368
SDNY_GM_02753545
SDNY_GM_02753545
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024370
SDNY_GM_02753546
SDNY_GM_02753546
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024372
SDNY_GM_02753547
SDNY_GM_02753547
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024384
SDNY_GM_02753548
SDNY_GM_02753548
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024386
SDNY_GM_02753549
SDNY_GM_02753549
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024388
SDNY_GM_02753550
SDNY_GM_02753550
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC024392
SDNY_GM_02753551
SDNY_GM_02753551
Native "carved" images
Confidential
previously produced in PDF
format for device
NYC027910
SDNY_GM_SUPP_00219450
SDNY_GM_SUPP_00219450
Image from device
Confidential
NYC024329
EFTA00028735

=== Page 4 ===
Page 4
SDNY_GM_SUPP_00219451
SDNY_GM_SUPP_00219451
Image from device
Confidential
NYC024366
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,
AUDREY STRAUSS
United States Attorney
by:
Assistant United States Attorneys
EFTA00028736


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: [EXTERNAL] information
Date: Thu, 28 Oct 2021 23:00:43 +0000
Thanks.
On Oct 28, 2021, at 6:18 PM,
wrote:
Thanks,
Yes, I passed this on to the contact at BOP. They were aware of his call to BOP yesterday.
Thanks,
From:
Sent: Thursday, October 28, 2021 5:09 PM
To:
Cc:
Subject: Fwd: [EXTERNAL] information
FYI. Do you mind passing this along to your contact? I don't know how much of any of this is appropriate for a FOIA
request after the first category but am not an expert. I believe the video is in the custody of the FBI and USAO since we
seized it from BOP.
Thanks very much.
Begin forwarded message:
From:
Date: October 28, 2021 at 3:50:15 PM EDT
To:
Cc:
Subject: RE: [EXTERNAL] information
Hi,
I submitted the request via the on line website of the BOP as suggested by the person I spoke to there.
The below is what I am requesting at this time.
i am the sole heir and next of kin of JEFFRFEY EPSTEIN, who died while in federal custody at the MCC in NYC.
I am requesting the same information that was released to the New York Times regarding all of the information they
requested under the FOIA regarding my brother's case.
EFTA00028094

=== Page 2 ===
I would also like a copy of the video tape from the camera outside of the SHU on August 9th 2019, which would show
the last time anybody (guards, etc) left the SHU prior to my brother being found dead in his cell the next morning.
This is the tape that then Attorney General Barr publicly stated that he personally watched.
I would also like a list of the inmates that were on that tier on August 9th, 2019. Also, please provide the information
of when they were placed on that tier and when and where they were transferred to if they are not still on that tier.
I would like any information that would reveal the identities of the people in the prison who were directing the action
on that tier and who was in the cell with the EMT's that came after my brother was found dead. I am trying to find
out why normal protocol was not followed in that the body of a clearly dead person was moved prior to the medical
examiner office being given the chance to photograph the crime scene. I would imagine that there was some sort of
incident report filed regarding this matter and I would like that as well.
I would appreciate it if you can get this done in a timely manner.
Thanks,
From:
Sent: Monday, October 25, 2021 8:34 PM
To:
Cc:
Subject: Re: [EXTERNAL] information
Hi Mr.
As I discussed with Ms.
over the summer, you would need to submit a FOIA request to the BOP and note that
you are specifically requesting what they released to the NYT. You can send me copy of that request once it has been
submitted to the BOP and as a courtesy I will ensure that the correct recipient in the Civil Division of our Office has
received it. We do not handle FOIA requests in our division.
Best,
On Oct 25, 2021, at 12:40 PM,
wrote:
Hi,
Hope this finds you well.
I would like to get a copy of ALL of the records that were released to the New York Times on their FOI request
regarding my brother's case (Jeffrey Epstein).
Please advise the quickest way to accomplish this.
Thanks,
EFTA00028095

=== Page 3 ===
Scanned by McAfee and confirmed virus-free.
EFTA00028096


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=== Page 1 ===
From:
To:
Subject: Fwd: Business Insider, Request for comment
Date: Wed, 10 Jul 2019 04:36:14 +0000
Begin forwarded message:
From: Benjamin Goggin
Date: July 9, 2019 at 7:20:41 PM EDT
To:
Subject: Business Insider, Request for comment
Hi
My name is Ben Goggin, I'm writing a story for Business Insider about your participation in the prosecution of
Jeffrey Epstein and wanted to ask you a few questions. I'll list them here but feel free to call me
(
).
*can you confirm that you are 30 years old?
*can you respond to criticisms that you have a conflict of interest due to your father, your past political
donations, or your reported attendence of the women's march? Is the picture on this blog you?
*can you comment on your work at Debevoise & Plimpton LLP?
*can you elaborate on what happened in the 2016 case against the camp counselor who allegedly solicited nude
photos from a middle schooler? Why did he plead to a lesser charge?
Thank you!
Best,
Benjamin Goggin
Weekend Editor
Business Insider INSIDER
W:
/ C:
Sign up for the Executive Summary, a biweekly recap of what's new at Insider Inc.
Follow us on Twitter!
EFTA00028352


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Cc:
(USANYS)"
Subject: Fwd: updates
Date: Sat, 06 Jul 2019 22:27:49 +0000
Importance: Normal
Let us know if/when you hear from defense counsel. My guess is it will be quick.
Sent from my iPhone
Begin forwarded message:
From: "Berman, Geoffrey (USANYS)"
Date: July 6, 2019 at 5:54:01 PM EDT
To:
Cc:
(US
)"
)"
Subject: Re: updates
Epstein is in custody. Search warrants being executed now. Geoff
On Jul 6, 2019, at 12:44 PM, Berman, Geoffrey (USANYS)
wrote:
tells me that he is confirmed on board. Wheels up. Geoff
On Jul 6, 2019, at 11:10 AM,
)
wrote:
Good morning all-
asked me to pass along two quick updates. First, Judge Moses signed the search warrant this morning.
Second, our case agent told us that FBI received a flight manifest from CBP last night. The passengers listed are
Epstein and two pilots. Of course, that is subject to change, and I'm told that FBI will try to get confirmation of the
passengers after the flight takes off.
Assistant United States Attorney
Southern District of New York
EFTA00029512

=== Page 2 ===
EFTA00029513


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=== Page 1 ===
From: Andrew Patel
To:
(USANYS)"
Cc: Jill Shellow'
(USANYS)"
"Donald Yannella
(
)"
Subject: Re: Johnny Contreras - Investigation of Jeffrey Epstein Death
Date: Tue, 03 Sep 2019 14:14:27 +0000
Importance: Normal
We are here.
Andrew G. Patel
Attorney at Law
80 Broad Street, Suite 1900
New York, NY 10004
Sent from my phone
On Sep 3, 2019, at 9:57 AM,
(USANYS)
wrote:
Hi Andy, Jill, and Don,
Change of plans this morning, we will be at
From:
(USANYS)
Sent: Monday, August 26, 2019 5:54 PM
To: Andrew Patel
>; Jill Shellow'
Cc:
(USANYS)
>; ; Donald Yannella
(
Subject: RE: Johnny Contreras - Investigation of Jeffrey Epstein Death
Got it, thanks. Same to you and see you next week.
From: Andrew Patel
Sent: Monday, August 26, 2019 4:31 PM
To:
(USANYS)
>; Jill Shellow'
Cc:
(USANYS)
>; ; Donald Yannella
(
^
>; Andrew Patel
Subject: RE: Johnny Contreras - Investigation of Jeffrey Epstein Death
,
Don Yannella, who is actually Mr. Contreras' lead counsel, will be joining us as well.
Have a good week and weekend.
Andy
EFTA00029264

=== Page 2 ===
Andrew G. Patel
Attorney at Law
80 Broad Street, Suite 1900
New York, NY 10004
Tel:
Fax:
CONFIDENTIALITY NOTICE: This e-mail message is covered by the Electronic Communications Privacy Act,
18 U.S.C. 2510-2521. It is legally privileged. The information it contains is confidential information and is intended
only for the use of the individual or entity named above. If the reader of this message is not the intended recipient,
or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any
dissemination, distribution or copying of the communication is strictly prohibited. If you have received this e-mail
in error, please notify me immediately by telephone at
and by return e-mail, and delete all copies of
the message from your computer. Thank you.
From:
(USANYS) [mailto:
Sent: Monday, August 26, 2019 4:00 PM
To: Andrew Patel; Jill Shellow'
Cc:
(USANYS)
Subject: RE: Johnny Contreras - Investigation of Jeffrey Epstein Death
Hi Andy and Jill,
We are confirmed for 9/3 at 10 am at 1 St. Andrews. See you then.
From:
(USANYS)
Sent: Wednesday, August 21, 2019 4:35 PM
To: 'Andrew Patel'
>; 'Jill Shellow"
Cc:
(USANYS)
Subject: RE: Johnny Contreras - Investigation of Jeffrey Epstein Death
Hi Andy/Jill,
We understand that Mr. Contreras is willing to meet with us in a proffer session, and that the proffer would be limited
only to the information he has regarding Mr. Epstein's death. If so, when would be convenient to meet? Let us know if
you'd like to discuss anything by phone. Thanks.
From: Andrew Patel
Sent: Wednesday, August 21, 2019 4:20 PM
To:
(USANYE)
is
(USANYE)
is
(USANYE)
Cc: 'Donald Yannella
(
)'
>; 'Jill Shellow'
V.
(USANYS)
i
(USANYS)
Subject: RE: Johnny Contreras - Investigation of Jeffrey Epstein Death
Many thanks. Talk to you soon.
Andy
EFTA00029265

=== Page 3 ===
Andrew G. Patel
Attorney at Law
80 Broad Street, Suite 1900
New York, NY 10004
Tel:
Fax:
CONFIDENTIALITY NOTICE: This e-mail message is covered by the Electronic Communications Privacy Act,
18 U.S.C. 2510-2521. It is legally privileged. The information it contains is confidential information and is intended
only for the use of the individual or entity named above. If the reader of this message is not the intended recipient,
or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any
dissemination, distribution or copying of the communication is strictly prohibited. If you have received this e-mail
in error, please notify me immediately by telephone at
and by return e-mail, and delete all copies of
the message from your computer. Thank you.
From:
(USANYE) [mailto:
Sent: Wednesday, August 21, 2019 4:16 PM
To: Andrew Patel;
(USANYE);
(USANYE)
Cc: Donald Yannella (
); 'Jill Shellow';
(USANYS);
(USANYS)
Subject: RE: Johnny Contreras - Investigation of Jeffrey Epstein Death
Hi Andy:
I've spoken with my wonderful former colleagues in SDNY who are handling the investigation, and who are cc'd here.
I
passed along the information you and Jill provided to us yesterday, and they will reach out to you directly to set up a
proffer on this topic.
Thanks, and best,
From: Andrew Patel
Sent: Monday, August 12, 2019 3:15 PM
To:
(USANYE)
is
(USANYE)
is
(USANYE)
Cc: Donald Yannella
>; 'Jill Shellow'
is
Andrew Patel
Subject: Johnny Contreras - Investigation of Jeffrey Epstein Death
Dear
:
This email concerns the investigation into the death of Jeffrey Epstein in
the MCC. We realize that it is unlikely your office is involved, but we
thought that we should inform the government of the following so you can
take whatever action you believe is appropriate.
EFTA00029266

=== Page 4 ===
Jhonny Contreras was recently returned to the SHU in the MCC. At the
time of Mr. Epstein's death, it is my understanding that Mr. Contreras was
housed in a cell on the same tier and across the hall from Mr. Epstein's
cell. Mr. Contreras did not see Mr. Epstein hang himself, but he would be
willing to speak to investigators, in the presence of counsel, about his
observations.
Please let us know if there is anything further we should do to follow-up.
Andy
Andrew G. Patel
Attorney at Law
80 Broad Street, Suite 1900
New York, NY 10004
Tel:
Fax:
CONFIDENTIALITY NOTICE: This e-mail message is covered by the Electronic Communications Privacy Act,
18 U.S.C. 2510-2521. It is legally privileged. The information it contains is confidential information and is intended
only for the use of the individual or entity named above. If the reader of this message is not the intended recipient,
or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any
dissemination, distribution or copying of the communication is strictly prohibited. If you have received this e-mail
in error, please notify me immediately by telephone at
and by return e-mail, and delete all copies of
the message from your computer. Thank you.
EFTA00029267


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=== Page 1 ===
From:
To:
Subject: Epstein defense attorney contact info
Date: Sun, 07 Jul 2019 00:56:23 +0000
Importance: Normal
Martin Weinberg
office:
cell:
email:
Assistant U.S. Attorney
Southern District of New York
EFTA00028383


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c3: VOL00008
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
Cc:
(USANYS)"
Subject: Re:
Date: Mon, 10 Feb 2020 21:07:57 +0000
Prince Andrew
On Feb 10, 2020, at 4:07 PM,
(USANYS) [Contractor]
wrote:
Not sure we know what you're asking? If you get a question about the status of the Epstein investigation (into possible
charges against co-conspirators)? Another Prince Andrew question?
From:
(USANYS)
Sent: Monday, February 10, 2020 4:00 PM
To:
(USANYS) [Contractor]
is
(USANYS)
Subject: Re:
What should I say in response to an Epstein statement?
On Feb 10, 2020, at 3:59 PM,
(USANYS)
wrote:
Begin forwarded message:
From:
(USANYS)"
Date: February 10, 2020 at 9:04:00 AM EST
To:
(USANYS) [Contractor]"
<Ray Statement.ebd.docx>
EFTA00027556


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=== Page 1 ===
STATES
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 1, 2020
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
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
copies of the materials listed in the below index, which materials are stamped with control numbers
SDNY_GM_000174967 through SDNY_GM_00328863. The materials are available for pickup
at the U.S. Attorney's Office in Manhattan.
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
SDNY GM 00174967
SDNY GM 00270985
Deutsche Bank records
Confidential
SDNY_GM_00270986;
JPMorgan Chase records
Confidential
SDNY GM 00323935
SDNY GM 00324015
GM Documents
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. Such files include in their electronic names the
word "Confidential."
06.20.2018
EFTA00028045

=== Page 2 ===
Page 2
SDNY GM 00324016
SDNY GM 00324036
Citibank records for Ghislaine Maxwell
UBS records for Angara Trust, Montepelier
Trust, Terramar Project, Inc., Max
Foundation, Ghislaine Maxwell, Ghislaine
SDNY GM 00324037
SDNY GM 00325754
Maxwell IRA, & Ellmax, LLC
SDNY GM 00325755
SDNY GM 00325761
LSJ Scene2Go
American Express records for Jeffrey
SDNY GM 00325762
SDNY GM 00328069
Epstein and Ghislaine Maxwell
Confidential
The Government is also reproducing to the defendant the files specified in Defense's
September 21, 2020 letter. In order to avoid further difficulties with respect to viewing the files,
the Government offers the following instructions:
1. Any .dat, .dvt, and .vol files can be opened and viewed by right-clicking on the file and
selecting "Edit with Notepad" or a similar text-viewing program.
2. Any video file can be opened with VLC, which has been included.
3. Accessory files (i.e. .dii, .ami, .cms, etc.) are to be ignored, as they serve no functional
purpose besides assisting in the operation of other (i.e. video) files.
4. Any previously flagged files that are not noted here have been converted to PDFs and/or
had their file paths shortened to enable viewing.
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials or if you wish to arrange a time to
review physical items in the FBI's custody.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Went me
Assistant United States Attorneys
06.20.2018
EFTA00028046


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Maxwell update to the Court
Date: Tue, 02 Feb 2021 20:26:28 +0000
Attachments: 2021.02.02_AJN_Order_Denying_Motion_to_Vacate_Order_re_MDC_laptop_access.pdf
All,
Judge Nathan just issued the attached order denying the application to vacate her prior order regarding Maxwell's access
to the laptop.
Please let me know if there is a good time for a call tomorrow to discuss the update letter that is due this Friday.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, February 1, 2021 7:44 PM
To:
Cc:
Subject: Maxwell update to the Court
All,
Attached please find a letter, which we just filed on ECF, informing the Court that although our office generally has no
objection to Maxwell having additional laptop access, we defer to the MDC's judgment regarding how to manage its
inmates, including in this situation. The defense has not filed a letter in response to your request to vacate the Court's
prior order, but I will send you a copy if and when they do.
Relatedly, our next update regarding Maxwell's conditions of confinement is due to the Court this Friday, February 5th.
Per the attached order, we need to update Judge Nathan regarding the following topics:
Access to discovery (we have discussed this topic repeatedly, and my understanding is there are no material
changes here, but we need to confirm)
Access to legal mail (confirming Maxwell is receiving her legal mail on the same basis as all other inmates)
Access to legal email (confirming that Maxwell has access to email with legal counsel via the BOP desktop
computer)
EFTA00028161

=== Page 2 ===
Ability to communicate with legal counsel (confirming the frequency with which Maxwell receives legal calls and
VTCs)
The frequency of searches of Maxwell (including all patdowns, mouth searches, ear searches, strip searches,
body scans, cell searches, and nighttime monitoring)
Is there a time in the next couple days when we could have a quick phone call to check in on these topics, please?
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00028162


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=== Page 1 ===
From: Alex Conlon
To:
)"
Subject: RE: SDNY investigation / interview
Date: Tue, 21 May 2019 20:11:58 +0000
I could see how that would be important. Thursday! Whoops.
Alex Conlon | Kaplan Hecker & Fink LLP
(W)
(M)
Original Message
From:
)
Sent: Tuesday, May 21, 2019 4:11 PM
To: Alex Conlon
Subject: Re: SDNY investigation / interview
Just need the day of the week : )
Sent from my iPhone
On May 21, 2019, at 16:07, Alex Conlon
wrote:
Hi Alex,
I just tried to reach you at your desk, but missed you.
is available to meet this week at 4:30 at our office if that works for you. Also, she plans to make the
phone calls we discussed today and tomorrow on her own. She will contact me once she has connected with two
individuals she's reaching out to and I will reach out to you in turn.
Happy to discuss anything, if that's helpful.
Thanks,
Alex
Alex Conlon | Kaplan Hecker & Fink LLP
(W)
<tel:
EFTA00027765

=== Page 2 ===
(M)
<tel:
From:
)
Sent: Tuesday, May 14, 2019 4:49 PM
To: Alex Conlon
Cc: Alexandra Elenowitz-Hess
Subject: RE: SDNY investigation / interview
Alex,
Just tried calling but missed you - wanted to briefly follow up on our conversation last week to let you know that
we certainly don't have any objection to someone from your firm (whether attorney or staff) taking notes in
connection with Ms.
conversations to tell the individuals we discussed that our office is interested in
speaking with them. I expect we might request a copy of the notes, and, as discussed, whoever is with her would
be a potential, theoretical witness, but no issue on our end with any of that.
Separately, if it's possible, could you please ask Ms.
if there is a time next week or the following that
we could meet with her? We're hoping to cover all the information we need to in this first set of discussions
before June, when I think it will be even more inconvenient for her to meet. I expect the next meeting will
address difficult topics, including Giglio subjects and some review of Epstein's conduct with Ms.
in
particular; but, I also expect that once we get through those issues, we won't need to meet with her again for at
least a little while.
We can generally make ourselves available whenever works on her end, with some combination of our team
(e.g., if it's the latter half of next week, will likely be me and our new team member
but let us know if
,
there are any issues with that), and as always can work around her schedule. And happy to come to your office
for the final push.
Don't hesitate to give a call if any other info would be helpful, or if any questions or issues, and thanks very
much.
Assistant U.S. 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.
EFTA00027766

=== Page 3 ===
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.
EFTA00027767


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Testifying witness notes
Date: Tue, 10 Aug 2021 02:14:26 +0000
Thanks so much!
From:
Sent: Monday, August 9, 2021 10:13 PM
Subject: RE: Testifying witness notes
Thank you! Yes, we have those deadlines, will forward the calendar invites to you.
From:
Sent: Monday, August 9, 2021 9:21 PM
Subject: RE: Testifying witness notes
All set, it's been added to both folders. On a related note, do we have a set deadline for producing testifying witness 3500
and GX to defense/the court yet, or is it still too early?
From:
Sent: Monday, August 9, 2021 9:18 PM
Subject: Testifying witness notes
Hi
Would one of you please save the attached in the testifying witness 3500 folder and the witness folder for Larry Visoski on
the Epstein share?
Thanks,
EFTA00027304


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=== Page 1 ===
From:
Jeffrey Epstein
To:
Sent:
2/7/2011 7:13:12 PM
Subject:
Kenny, Steve Culter at JPM , says he has left a number of messages for you.. I would really appreciate it if
you could call him As I had mentioned to you, - He is the lead counsel for Morgan , and needs to be reassured
that I am a good egg - Steve's cell:
thanks in advance, , and can't wait to see you face to face.
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
Jeffrey Epstein
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. copyright -all rights reserved
Confidential Treatment Requested by JPMorgan Chase
JPM-SDNY-00001413
EFTA00029436


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=== Page 1 ===
Event: Accepted: Call on Epstein/Maxwell Documents
Start Date: 2020-07-23 16:00:00 +0000
End Date: 2020-07-23 16:30:00 +0000
Location: 844-215-6902; Conf. Id 758788
Class: X-PERSONAL
Comment:
Date Created: 2020-07-22 21:00:43 +0000
Date Modified: 2020-07-22 21:00:43 +0000
Priority: 5
DTSTAMP: 2020-07-22 20:23:44 +0000
Attendee:
EFTA00027958


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=== Page 1 ===
From:
(USANYS)"
To: USAEO-Foreign Travel
Cc:
)"
Subject: FW: ECC package - AUSA
ECC ackage
Date: Mon, 27 Jan 2020 18:09:18 +0000
Importance: High
Attachments:
-_ECC_package_2.3.20.pdf
Passport info added.
Thank you
From:
(USANYS)
Sent: Friday, January 24, 2020 2:31 PM
To: USAEO-Foreign Travel
Cc:
is
(USANYS)
Subject: FW: ECC package - AUSA
ECC ackage
Importance: High
Hi RMP,
Please see the attached ECC request package for
If required, please inform the traveler how to determine who the POC is for this trip.
Hi
Please let EOUSA know if you have checked to see if a visa is required for your destination.
View the state dept. link for the country you are traveling to visa link for the country you are traveling to.
Visa policies may be found on the Department of State's website or on the website hosted by each country's 's embassy.
https://travel.state.gov/content/passports/en/country.html
Traveler, Consult EOUSA usaeo.foreign.travel@usdoj.gov mailbox to obtain a visa for you.
To provide sufficient time for the State Dept. to issue the authorization letter and for the foreign government to process the visa
request, it is recommended that visa request package be submitted to EOUSA's RMP Travel.
Staff 15 business days prior to the proposed date of departure.
Thank you
Original Message
From:
Sent: Friday, January 24, 2020 1:41 PM
To:
(USANYS)
V.
(USANYS)
Subject: FW: ITINERARY ONLY -
Travel Date: 03FEB20 - Ref: HEZZTD
Finally have a correct itinerary! This is for both the passport application and the request for approval of the travel.
Thanks so much for your help.
From:
Sent: Friday, January 24, 2020 10:39 AM
To:
(USANYS)
is
EFTA00028458

=== Page 2 ===
Cc:
(USANYS)
Subject: RE: Sorry One more thing - EOUSA also needs your OIA approval email. Thanks
We have reached out to OIA and are awaiting their approval. We'll send it as soon as we have it.
From:
(USANYS)
Sent: Friday, January 24, 2020 10:39 AM
To:
is
Cc:
(USANYS)
Subject: Sorry One more thing - EOUSA also needs your OIA approval email. Thanks
Sorry, One more thing - EOUSA also needs your OIA approval email. Thanks
From:
Sent: Friday, January 24, 2020 10:33 AM
To:
(USANYS)
is
Subject: RE: Questionnaire - Hi We also need this one ASAP. Thanks
Attached is my questionairre
Original Message
From:
(USANYS)
Sent: Thursday, January 23, 2020 2:28 PM
To: USAEO-Foreign Travel
Cc:
(USANYS)
is
Subject: FW: ITINERARY ONLY -
- Travel Date: 04FEB20 - Ref: HEZZTD
Hi
-
Attached is AUSA
S flight itinerary for her upcoming foreign travel. I know you needed this for the passport. We
will be routing a travel authorization for her trip soon.
Thank you!
Original Message
From:
Sent: Thursday, January 23, 2020 2:26 PM
To:
(USANYS)
is
(USANYS)
Subject: FW: ITINERARY ONLY -
- Travel Date: 04FEB20 - Ref: HEZZTD
Hi,
Attached is my itinerary with the revised dates (2/4/20 through 2/6/20) for the trip to Sweden. Should have the draft
travel memo ready to send shortly.
Thanks,
EFTA00028459

=== Page 3 ===
EFTA00028460


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=== Page 1 ===
From:
Subject: Epstein
Date: Tue, 29 Jan 2019 22:55:18 +0000
Importance: Normal
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#Florida Scans\Jeffrey Epstein)
Transcripts
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#Florida Scans\Jeffrey Epstein\ \Juan
Alessi Statement
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#Florida Scans\leffrey
Epstein\Victims - but only portions of each pdf that reflect statements/interviews of witnesses
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\FBl materials (reports, FOIA, etc)
Case, obstruction, materials (file, 302s)\302s
Epstein universe spreadsheet in Investigation folder
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
t.
EFTA00028039


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=== Page 1 ===
From:
"
)"
To:
)"
"
,
(
=
Subject:
Date: Sun, 11 Oct 2020 17:02:02 +0000
Attachments: USGME01389609_native.pdf
See attached. We probably need to interview her again.
EFTA00029495


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: Fwd:
Date: Thu, 26 Aug 2021 13:51:05 +0000
Attachments: USGME00444198_native.pdf
Sent from my iPhone
Begin forwarded message:
From:
)"
Date: August 23, 2021 at 8:14:00 PM EDT
To:
(USANYS)"
N
)"
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00027872


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=== Page 1 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
To:
)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Date: Fri, 26 Mar 2021 21:33:16 +0000
Hi
Just confirming receipt. Also, I'm hopeful that we can have everything gathered by April 12th. However, I'll be out of the
office for the next week so it might be delayed. Will that be a problem?
In addition, and just for confirmation's sake, you are ok that we will make reasonable efforts to notify the
parents/students of the subpoena prior to compliance with the subpoena correct?
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, March 26, 2021 at 3:37 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
Thanks again for taking the time to speak with me this morning. As we discussed, I'm attaching a subpoena for additional
student records.
Thank you,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
EFTA00027717

=== Page 2 ===
Sounds good. Yes, that is the best number.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 4:40 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Thanks so much-let's plan to talk at 9:30 tomorrow morning, if that works for you. Is this the best number to reach you
then: 231-947-0400
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:32 PM
To:
)
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
I'm available between 9am and 10am, and then again after 11am.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
EFTA00027718

=== Page 3 ===
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 3:41 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Are you available for a quick call tomorrow morning?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, January 7, 2021 11:10 AM
To:
)
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
231-947-0400
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, January 7, 2021 at 10:37 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff- what is the best number to reach you this morning? Thanks.
EFTA00027719

=== Page 4 ===
Sent from my iPhone
On Jan 5, 2021, at 3:21 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me.
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, January 4, 2021 at 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
That would be great, thanks. Would Thursday at 11:30 work for you?
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Sure. Does Wednesday or Thursday morning work?
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
EFTA00027720

=== Page 5 ===
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Are you available for a call sometime in the next few weeks? We have one or two follow up
questions that would be helpful to talk through.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, December 30, 2020 2:37 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Sorry about the delay. Interlochen doesn't have any other documents regarding tuition payment information or
payments by Epstein or Epstein entities.
Let me know if you have any other questions.
Thanks,
Jeff Jocks
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
EFTA00027721

=== Page 6 ===
From:
)
Sent: Monday, November 16, 2020 3:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
>;
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. I'm following up on our conversation from earlier this month to see if you have any updates on
the categories of documents we discussed.
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 11:15 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
That works for me. I will call in at 10am Monday.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
EFTA00027722

=== Page 7 ===
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line
Thanks,
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
H
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
EFTA00027723

=== Page 8 ===
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still
be grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
>
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or
determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
EFTA00027724

=== Page 9 ===
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com>, "Donnini, George B." <donnini@butzel.com>
Cc:
)"
>,
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would
you please confirm that your production included all records of any tuition payments that Epstein (or his entities)
made for any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow
and will have limited availability this week, but my colleagues
and
(both cc'd) should be
able to coordinate with you as needed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
Cc:
is
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
EFTA00027725

=== Page 10 ===
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
)"
=
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey
Epstein and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request
confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00027726


c1: EFTA00028665
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028665.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Call re: Epstein FOIA
Start Date: 2021-03-19 13:00:00 +0000
End Date: 2021-03-19 13:30:00 +0000
Organizer:
Location:
Class: X-PERSONAL
Date Created: 2021-03-11 21:40:31 +0000
Date Modified: 2021-03-11 21:40:31 +0000
Priority: 5
DTSTAMP: 2021-03-11 20:29:13 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00028665


c1: EFTA00029025
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00029025.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
(USANYS) [Contractor]"
(USANYS)"
,
)"
Subject: RE: Epstein/Maxwell Upload
Date: Fri, 25 Sep 2020 15:23:40 +0000
Great point, thanks!
From:
(USANYS) [Contractor]
Sent: Friday, September 25, 2020 11:22 AM
To:
Cc:
(USANYS) [Contractor]
is
(USANYS)
>;
Subject: RE: Epstein/Maxwell Upload
Okay great. I reached out to
at BOP to get an answer on their text reader capabilities. Apparently, their computers
are equipped with text readers (as suspected). I'm still waiting to hear back on the specific program(s) that they use. I
figured it would be useful to know and/or include in the next discovery cover letter so that defense can't claim that she
has no capability to open those files.
From:
)
Sent: Friday, September 25, 2020 11:18 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS)
V.
Subject: RE: Epstein/Maxwell Upload
Thanks for flagging. Let's produce in their original format to both for now. If Maxwell has trouble opening them at MDC,
we'll deal with that after she tells us she can't open them. She has not identified every single excel and txt file from past
productions as problematic, so she will hopefully be able to open these.
From:
(USANYS) [Contractor]
Sent: Friday, September 25, 2020 10:47 AM
To:
Cc:
(USANYS) [Contractor]
>;
(USANYS)
>;
Subject: RE: Epstein/Maxwell Upload
How are we handling producing to Maxwell vs. Counsel? With these files there are tons of text and excel files that need to
be converted in order to be sent to MDC. Are we also producing the converted versions to defense or rather the original
natives?
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 2:34 PM
To:
(USANYS) [Contractor]
i
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: RE: Epstein/Maxwell Upload
EFTA00029025

=== Page 2 ===
The zip files have been copied to the below location. Please let me know if there are any issues with the data in the zip
files.
Thank you.
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:42 AM
To:
(USANYS) [Contractor]
>;
Cc:
(USANYS) [Contractor]
is
(USANYS)
;
Subject: RE: Epstein/Maxwell Upload
That's what I figured. Thanks! Now that they are all good to go would you please export both Deutsche Bank and
JPMorgan productions to the shared here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-
2018R01618\Discovery\GM\04 Fourth Production\TO BE PRODUCED
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:39 AM
To:
(USANYS) [Contractor]
is
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: RE: Epstein/Maxwell Upload
No way to put a confidential stamp on a excel file. There should be an image placeholder that says document produced in
native format which has the confidential stamp.
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:36 AM
To:
(USANYS) [Contractor]
>;
Cc:
(USANYS) [Contractor]
>;
(USANYS)
is
Subject: RE: Epstein/Maxwell Upload
Thanks
These look great. One quick question, on documents in native format (excel files) is there a confidential
stamp? I've checked and it seems the answer is no but I just want to be sure that I'm not missing anything.
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:20 AM
To:
)
is
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: RE: Epstein/Maxwell Upload
The documents should now be available for review. Please let me know if there are any questions.
Thank you.
EFTA00029026

=== Page 3 ===
From:
)
Sent: Thursday, September 24, 2020 9:11 AM
To:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS)
;
Subject: RE: Epstein/Maxwell Upload
These documents are not supposed to be privileged reviewed. The only documents that need to be privilege reviewed
are the electronic search warrant returns.
Thanks,
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 9:05 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
V.
(USANYS)
is
Subject: RE: Epstein/Maxwell Upload
The data is probably secured for privilege review. Please let me know if these documents are not supposed to be
privileged reviewed.
Thank you.
From:
(USANYS) [Contractor]
Sent: Wednesday, September 23, 2020 5:39 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
>;
(USANYS)
is
Subject: RE: Epstein/Maxwell Upload
Hey
When I click on each of those links I'm brought to a Relativity page with no data. Am I doing something wrong?
Thanks,
From:
(USANYS) [Contractor]
Sent: Wednesday, September 23, 2020 11:32 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
)
>;
(USANYS)
is
Subject: RE: Epstein/Maxwell Upload
The production of the documents has been completed. The below are links to the production for you to review:
Deutsche Bank - https://d1pe.nss.pae.com/Relativity/go?id=1420850-2343058
EFTA00029027

=== Page 4 ===
JP Morgan - https://d1pe.nss.pae.com/Relativity/go?id=1420850-2343059.
Please review the documents and let me know if anything needs to be adjusted with the production.
Thank you.
From:
(USANYS) [Contractor]
Sent: Friday, September 18, 2020 10:26 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
>;
(USANYS)
>;
Subject: RE: Epstein/Maxwell Upload
1. Yes, we want to mark all of them confidential
2. We are working on that.
3.
I suppose database load files? We want to retain the files as they are currently formatted as best we can.
4. That won't be an issue. I don't think we will be searching through them; the purpose is just to be able to stamp
them.
Thanks!
From:
(USANYS) [Contractor]
Sent: Friday, September 18, 2020 10:10 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
>;
(USANYS)
>;
)
Subject: RE: Epstein/Maxwell Upload
I know you want to produce these documents can you please tell me the following:
1. Will you placing a Confidential stamp on these documents?
2. What bates number do you wish to use on the documents?
3.
How do you want to produce the documents (single page tiff images, database load files or PDF production).
4. Also please note that once the documents have been loaded to Relativity there is no way to run any searches for
these images since they are mostly images and video.
Please let me know if there are any questions.
Thank you.
From:
(USANYS) [Contractor]
Sent: Thursday, September 17, 2020 4:54 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
>;
(USANYS)
is
Subject: Epstein/Maxwell Upload
EFTA00029028

=== Page 5 ===
Hey
We have some materials that we need uploaded to Relativity to the Epstein database for the purpose of stamping them.
The files in question number about 40,000 and are about 300GB in size. They are currently copying onto a drive to be sent
to Relativity and should be ready by tomorrow. Do you want to see them first or can they go directly to PAE?
Folder/Subfolder in Relativity: US V. Epstein
FBI Case File
Images Seized During Search
Thanks,
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
Office:
Cell:
EFTA00029029


c1: EFTA00029444
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00029444.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
Cc:
)"
(USANYS)"
)"
(USANYS)"
)"
)"
,
"PICARELLO, JOSEPH" <JOSEPH.PICARELLO@nypd.org
Subject: Re: Epstein search warrant documents
Date: Wed, 08 Apr 2020 14:06:37 +0000
10-04 Thanks
speak to you soon.
On Apr 8, 2020, at 09:46,
wrote:
All,
I was able to secure a conference line that can accommodate up to 15 people. Dial
and
enter code
,
at 11am.
thanks
From:
Sent: Tuesday, April 7, 2020 3:27:16 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
i
is
is
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
)
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
can also join anytime tomorrow. So whenever is good on your end.
EFTA00029444

=== Page 2 ===
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
From:
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
i
is
is
(USANYS)
Cc:
is
>;
is
is
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but
are you at all able to assist while working remotely? This has been pending for almost two months and we still don't
have a very basic list of each device or item that was seized and searched, or for which of those we've received
materials. We're happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is
the info in the template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
EFTA00029445

=== Page 3 ===
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
-
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
Related, the control numbers in the load file don't match up to the native files. So we have two sets of
numbers and no way to match up anything-that is, even if we were to try to go hunt down every individual
large file in the native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to
get a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a
million documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the
SW returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
is
is
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points
of clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3
drives (9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All
the loose media from the NY apartment is included. All the Windows machines from the NY apartment are included.
Only 2 Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
EFTA00029446

=== Page 4 ===
(office)
(cell)
From:
) [mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
)
in
(USANYS)
>;
>;
(USANYS)
Cc:
is
i
V.
is
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
i
)
is
>;
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
Sent: Monday, February 24, 2020 17:38
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
Totally understand about the network issues we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
EFTA00029447

=== Page 5 ===
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the
two search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed
and/or transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached
is mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think
FBI was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to
be able to review them as well.)
many thanks,
From:
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
is
is
(USANYS)
Cc:
is
>;
is
Subject: RE: Epstein search warrant documents
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated
we delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only
local work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still
working on the rest.
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e.,
which devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are
approximately 40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even
counting at least 60+ CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices,
including multiple servers / server racks.
EFTA00029448

=== Page 6 ===
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
is
Cc:
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have
the hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a
modified date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we
haven't gotten any info on which folders match up to which devices, etc. And then there's another folder titled
"NYC024362" that has a modified date of 1/27/20, so I think that may be the materials we hadn't previously received?
That folder by itself has more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder
or file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition
to what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
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From:
To:
Subject: BOP letters due Monday
Date: Sat, 06 Nov 2021 03:08:55 +0000
Attachments: : 2021-11-08_GM_letter_re_MDC_legal_mail_v1.docx;2021-11-
08_GM_letter_re_transportation_to_courthouse_v1.docx
Drafts attached. If you can make the letters any better or help me avoid having to write yet another letter on this, I
welcome any and all edits.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel:
EFTA00028204


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From:
)"
To:
Cc:
(NY) (FBI)"
i
(USANYS)"
Subject: Court Subpoena
Date: Mon, 04 Oct 2021 18:42:35 +0000
Attachments: 2021.08.27_Court_Subpoena_-_Sacramento_County_Clerk.pdf
Good afternoon,
I'm reaching out regarding the attached subpoena, which was served on your office in connection with an upcoming
criminal trial in the United States District Court for the Southern District of New York. I understand there have been some
questions regarding compliance. Could you please let me know your availability for a call?
Thank you,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00027589


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From:
To:
Cc:
)"
)"
Subject: RE: Question re T-Visa
Date: Fri, 22 May 2020 14:31:12 +0000
Give me a call and I can walk you through it.
From:
Sent: Friday, May 22, 2020 10:31 AM
To:
Cc:
is
Subject: Question re T-Visa
Hi
attorneys have reached out to us to inquire about our office assisting her in obtaining a T-Visa. She is
currently legally in the U.S. on a work visa, but that expires when her passport expires in August of 2020. We've never
dealt with T-Visas before, so would appreciate any guidance you might be able to provide. Would
qualify for a T-
Visa? If so, what would the process be for sponsoring her?
Also happy to have a call if that's easier, or if there's someone else we should reach out to, please let me know.
Thanks,
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From:
To:
Subject: Monday
Date: Fri, 12 Nov 2021 20:06:32 +0000
Attachments: Gov't Letter re MV-3 and Victim [Final].pdf; Govt_Letter_re_MV-3_[unredacted].pdf;
2021.11.11_Letter_to_Judge_Nathan_re_Response_to_Government_Letters_re_Accuser-
3_Evidence.PDF;4_Motion_to_Exclude_Accuser-3_Evidence.pdf;
Govt_Omnibus_Opp_[Unredacted].pdf;
!2021.10.27 Maxwell Reply ISO Motns In Limine.pdf;
Motion to Dietz and Loftus [to file].pdf;
2021.11.01 JSP Letter to USAO re Rul6 16 Disclosures.pdf;
2021.11.01_Final_pretrial_conference.PDF
Hey
Would one of you mind making a binder for me in advance of our court appearance on Monday? I've attached the things
to go in it, and l'll have one more after the defense files something tonight. You can reuse an old binder if that would be
helpful.
Thanks!
Assistant United States Attorney
Southern District of New York
New York, New York 10007
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=== Page 1 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
TD Bank N.A.
Subpoena Department
9000 Atrium Way
Mt. Laurel, NJ 08054
Fax: (856) 533-6795
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before
the GRAND JURY of the people of the United States for the Southern District of New York, at the United States
Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the
Southern District of New York, at the following date, time and place:
Appearance Date:
August 30, 2019
Appearance Time: 10:00 a.m.
to testify and give evidence in regard to an alleged violation of :
18 U.S.C. §§ 201, 371, 1001, 1346, 1519, 2
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
Please see attached rider. Personal appearance is not required if the requested records are (1) produced on or
before the return date to Assistant U.S. Attorney
of the United States Attorney's Office, 1 St.
Andrew's Plaza, New York, NY 10007. Tel:
, email:
, and (2)
accompanied by an executed copy of the attached Declaration of Custodian of Records. Ref No. 2019R01059.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
August 17, 2019
Geoffey S. with
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
MASSACHUSETTS IIIIII UNITED COURT
Assistant United States Attorney
FOR
One St. Andrew's Plaza
THE
RICT
YORK
New York, New York 10007
or
NEW
Telephone:
Email:
rev. 02.01.12
EFTA00027194

=== Page 2 ===
RIDER
(Grand Jury Subpoena to TD Bank, dated August 17, 2019)
Ref. No. 2019R01059
REQUEST:
For the following account, and any other account controlled by the account holder of one of the below
accounts:
Please provide any and all documents, to include, but not limited to those identified below, for the period
January 1, 2019 until the present:
a. Account opening documents, including applications and signature cards;
b. Records of account holders for debit and credit cards liked to the accounts;
c. Account statements and ledgers;
d. Images of checks (both front and back) deposited in account;
e. Images of canceled checks (both front and back) drawn on account;
f. Images of cashier's checks (both front and back) and depositing bank account information;
g. Account deposit slips, withdrawal slips, debit & credit memos, and cash tickets;
h. Detailed wire transfer records, ACH transfer records (including routing/account numbers funds
transferred to/from), money orders, and traveler's check records;
i. All credit card and line of credit records, including, but not limited to: applications, monthly
statements, billing slips, and records evidencing the source of payment (copies of checks, ACH
records (including routing/account numbers funds transferred to/from), or cash received slips);
j. Customer information associated with the account, including name(s), address(es), telephone
number(s), e-mail address(es), and any other identifying or contact information.
INSTRUCTIONS FOR PRODUCTION OF DOCUMENTS:
1. All transactions-based information, include wire and ACH transfers, withdrawals/deposits,
charges/payments, and bank account activity should be provided in electronic spreadsheet
format (either Microsoft Excel or similarly compatible format). Specifically:
a. For wires and other types of transfers, the account holder name, account number, and bank
name of both the originator and beneficiary of the transaction should be clearly stated in
separate fields.
b. Cash and check transactions should be indicated within a transaction type field.
i. Check transactions should include the name of the payee in the recipient
field. Additionally, check images should be attached in graphic data files in a commonly
readable, non-proprietary format with the highest image quality maintained, and named in
a manner that uniquely associates them with the relevant transaction record(s).
ii. Cash withdrawals should be indicated with CASH written in the recipient field.
iii. Cash deposits should be indicated with CASH written in the sender/originator field.
EFTA00027195

=== Page 3 ===
c. Field headers should be included for each column of data, and a data dictionary or other
explanation of the contents of each column provided.
2. Where more than one account is being requested, each account's transaction records should be
returned in a separate file.
3. All document images are to be produced in electronic PDF format. Where images of checks,
deposit slips, withdrawal slips, or cash tickets are being produced, they should be produced no
more than two per page.
4. In lieu of an appearance you may comply with this subpoena by providing the requested
information, along with a business records certification pursuant to Fed. R. Evid. 803(6) to
Assistant U.S. Attorney
of the United States Attorney's Office, 1 St. Andrew's
Plaza, New York, NY 10007. Tel:
, email:
EFTA00027196

=== Page 4 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the
business named below, or I am otherwise qualified as a result of my position with the business named below to
make this declaration.
I am in receipt of a Grand Jury Subpoena, dated August 17, 2019, and signed by Assistant United States
Attorney
,
requesting specified records of the business named below. Pursuant to Rules 902(11) and
803(6) of the Federal Rules of Evidence, I hereby certify that the records provided herewith and in response to the
Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from
information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
-
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any form, of acts,
events, conditions, opinions, or diagnoses. The term "business" as used in Fed. R. Evid. 803(6) and the above declaration
includes business, institution, association, profession, occupation, and calling of every kind, whether or not conducted for
profit.
EFTA00027197

=== Page 5 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 17, 2019
Re:
Grand Jury Subpoena
This letter describes the procedure for requesting reimbursement for subpoenaed records.
12 CFR part 219 (subpart A), issued by the Board of Governors of Federal Reserve System under section
1115 of the Right to Financial Privacy Act (12 U.S.C. $ 3415), sets the rates and conditions for reimbursement of
costs directly incurred by financial institutions in assembling or providing customer financial records to a
government authority pursuant to the Act. No costs are reimbursable if the records are those of a corporation or a
partnership comprised of more than five individuals.
If reimbursement is authorized, and the estimated billing to the government will exceed $500, advance
permission is necessary from
at
If the subpoenaed records indicated on the rider are eligible for reimbursement, please complete section B
of the enclosed form OBD-211, which will serve as your invoice, and return it with a copy of the subpoena to the
following address:
U.S. Attorney's Office - SDNY
Accounts Payable
86 Chambers Street, 3rd floor
New York, NY 10007
(212) 637-2662
Please send your invoice to the above address within 60 days of the submission of the subpoenaed records.
If no invoice is received within 120 days, funds will not be available to pay the invoice.
Thank you for your cooperation in this matter.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
By:
/s/
Assistant United States Attorney
Enclosure: OBD- 211
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From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:13:13 +0000
Inline-Images: image001.png
Thanks very much!
From:
Sent: Thursday, July 2, 2020 2:09 PM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congratulations!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO UNITED DONIMINA SUBTOTAL
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
-
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
EFTA00028741

=== Page 2 ===
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
EFTA00028742

=== Page 3 ===
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
*
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
EFTA00028743

=== Page 4 ===
unless and until proven guilty.
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From:
(USANYS)"
To:
(USANYS)"
Subject: Re: Yo
Date: Tue, 27 Aug 2019 18:33:57 +0000
I just feel terrible for
that he had to miss it!! 20 victims? No need to say more.
> On Aug 27, 2019, at 2:30 PM,
(USANYS)
wrote:
>
> Great. The Epstein circus just wrapped up. It's been a day.
V
> Sent from my iPhone
V
>> On Aug 27, 2019, at 2:29 PM,
(USANYS)
wrote:
did a gorgeous redirect FYI
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From:
To:
Subject: Fwd: Comments
Date: Sat, 27 Jun 2020 17:32:42 +0000
Attachments: Ghislaine_Maxwell_Press_Remarks_v3.docx; ATT00001.htm
Team is gonna go nuts.
Sent from my iPhone
Begin forwarded message:
From: "Strauss, Audrey (USANYS)"
Date: June 27 2020 at 10:15:14 AM EDT
To:
Subject: Comments
see what you think of these changes. I want to sound less like I am reading an indictment and more like I am talking
to regular people.
As always, if you disagree feel free to say so.
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Event: Meeting with
on Epstein
Start Date: 2019-01-29 21:50:00 +0000
End Date: 2019-01-29 22:00:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2019-01-29 21:09:00 +0000
Date Modified: 2019-01-29 21:09:00 +0000
Priority: 5
DTSTAMP: 2019-01-29 20:56:58 +0000
Attendee:
Alarm: Display the following message 15m before start
I
Reminder
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=== Page 1 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 1 of 14
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
JANE DOE 1 AND JANE DOE 2,
Civil Action No.
Petitioners,
08-80736-CIV-MARRA
v.
UNITED STATES OF AMERICA,
Respondent.
Government's Notice of Proposed Procedures for the
Determination of a Remedy
The United States of America, by Byung J. Pak, United States Attorney for the
Northern District of Georgia, and
Special Attorneys for the Southern District of Florida, files this notice outlining
the Government's proposed schedule for determining the issue of what remedy,
if any, should be applied based on the Court's Opinion and Order of February
21, 2019. [Doc. 435].
Pursuant to the Court's order, the parties have conferred extensively over the
past several weeks regarding the steps that may be necessary to aid the Court's
determination of a remedy. While the parties agree on certain components,
including cross-briefing and an opportunity for all parties to be heard, we have
been unable to reach an agreement on a briefing schedule primarily based on
two substantive disagreements.
EFTA00027809

=== Page 2 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 2 of 14
First, the government has requested a sixty-day period to speak directly with
victims who may be affected by any remedy in this matter prior to submitting its
recommendation. For the reasons discussed below, Petitioners' counsel oppose
this request. Based on discussions with Petitioners, the government anticipates
that Petitioners are likely to propose remedies that could impact victims in
significant - and perhaps unintended - ways. At this time, neither the
government nor the Petitioners have spoken to the majority of victims. The
victims' views and concerns are critical to inform the government's
recommendation of an appropriate remedy, particularly given the sensitive
nature of the crime at issue. Accordingly, the government respectfully submits
that a sixty-day period to consult with victims is both reasonable and essential to
the Court's determination of a remedy.
Second, the government proposes that Petitioners should file the first
pleading setting forth their recommended remedy; Petitioners insist that the
government should do so. Requiring Petitioners to file an initial statement is not
only consistent with the well-established practice that plaintiffs must identify
their requested relief, but also necessary to the efficient determination of a
remedy by clarifying the potential scope of options sought by Petitioners.
Based on its careful review of pleadings in this matter and discussions with
Petitioners, the government understands Petitioners' long-stated desire for an
opportunity to be heard and for an efficient resolution of this matter. The
government shares those concerns. The government also appreciates the delicate
600 U.S. Courthouse, 75 Ted Turner Drive S.W., Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
2
EFTA00027810

=== Page 3 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 3 of 14
task facing this Court to craft an appropriate remedy that respects the rights of
all parties without causing unintended harm to victims. Providing the victims
with an opportunity to be heard, both by having Petitioners submit their
suggested remedy first and then by granting the government a reasonable time
to speak with potentially impacted victims, promotes all of these goals and will
best guide the Court's determination of a path forward.
DISCUSSION
Consistent with the principles stated above, the government proposes the
following procedures to aid the Court's determination of a remedy:
Within 30 days of the Court's scheduling order, the Petitioners will
submit their proposed remedies with a brief in support.
The government will have 60 days from the date of the Petitioners'
submission to consult with the Petitioners and any additional victims
who may be impacted by the proposed remedies.
Within 30 days after this consultation period, the government will
respond in writing to the Petitioners' submission.
Within 14 days of the government's submission, the Petitioners may
submit a reply brief.
No sur-replies will be permitted without permission of the Court.
600 U.S. Courthouse, 75 Ted Turner Drive S.W., Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
3
EFTA00027811

=== Page 4 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 4 of 14
Within 30 days of the Petitioners' reply, or notice to the Court that no
reply is being submitted, any briefs by intervening or interested parties
are due.
Within 30 days of the intervening/interested parties' submissions, the
Petitioners and the government may submit a response.
The Court will mandate a mediation between the parties to discuss a
possible resolution of the case.¹
If the mediation is unsuccessful, the Court will hold argument on the
parties' briefs, including any intervening or interested parties'
submissions.
This schedule will facilitate the expeditious resolution of this matter by
clarifying the scope of remedies sought by Petitioners in the initial filing,
granting victims a reasonable time period to share with the government their
thoughts and concerns about the appropriate outcome, and encouraging the
parties to mediate a solution. Although the parties share the same aim to find the
best resolution for victims, Petitioners oppose the government's request for a 60-
day period to speak with victims and do not want to state their requested relief
first, even though they have had more than ten years to consider what relief to
seek. The government respectfully submits that the Court should adopt the
government's proposed schedule.
1 The parties agree that a mediation could be productive and are continuing to
discuss the appropriate timing for one.
600 U.S. Courthouse, 75 Ted Turner Drive S.W., Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
4
EFTA00027812

=== Page 5 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 5 of 14
1. The Government should have a reasonable period of time to speak with
victims prior to recommending a remedy that could affect many of them.
Despite bringing a civil suit based on the government's failure to confer with
victims prior to entering into a non-prosecution agreement, Petitioners' counsel
now oppose granting time for the government to confer with those same victims
in an effort to propose an appropriate remedy for the Court. Counsel's
opposition is contrary to their prior insistence that the government should speak
with victims and would hamstring the Court's consideration of issues relevant to
a proper resolution. In light of the unique procedural posture of this case, the
voices of victims who may be impacted by any remedy entered in this action will
shape the government's recommended relief and should guide the Court's
ultimate resolution.
Any remedy that the Court imposes in this action may have far-reaching
consequences that impact many victims beyond Petitioners. In particular,
Petitioners have repeatedly discussed some form of rescission of the non-
prosecution agreement ("the Agreement") as a remedy in this action. [Doc. 48 at
37; Doc. 127 at 1]. As the Court is well aware, the Agreement required Jeffrey
Epstein to fulfill certain conditions in exchange for the non-prosecution
provisions, including his agreement to compensate victims who chose to file suit
pursuant to 18 U.S.C. $ 2255, a statute that presumed damages of $150,000 per
victim with potential recovery of punitive damages and other relief. [Doc. 48 at
10; Doc. 48-5 at 5]. A rescission of the Agreement may impact victims who
600 U.S. Courthouse, 75 Ted Turner Drive S.W., Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
5
EFTA00027813

=== Page 6 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 6 of 14
recovered damages pursuant to the Agreement by making their settlements
subject to challenge. An understanding of the views of these victims is essential
to the government's, and ultimately this Court's, consideration of this remedy.
The necessity of consulting with victims who could be affected by any remedy
is especially apparent here given the particular vulnerability of these victims. It is
well-recognized that victims of sexual assault may suffer chronic psychological
effects that carry long-term consequences for their well-being, and
"[r]eadjustment after victimization can be challenging." Violence Prevention,
Centers for Disease Control and Prevention, available at
https://www.cdc.gov/violencepreventionsexualviolence/fastfact.html (last accessed May
9, 2019). In this case, even if victim settlements are not disturbed, any rescission
of the Agreement and subsequent investigation may trigger unintended
consequences for victims who have attempted to readjust their lives a decade
after Epstein's conviction for a state offense. And victims' prior statements that
they suffered emotional distress and were troubled by the prospect of any
involvement in the government's investigation of Epstein, and the potential
exposure of their identities, only heightens this concern. [Doc. 403-18 1 12]. The
government thus believes it is essential to understand these victims' concerns
prior to recommending a remedy. See Maryland v. Craig, 497 U.S. 836, 852, 110 S.
Ct. 3157, 3167 (1990) (recognizing the government's "compelling" interest "in the
protection of minor victims of sex crimes from further trauma and
embarrassment." (quotation marks omitted)). The government is sensitive to the
600 U.S. Courthouse, 75 Ted Turner Drive S.W., Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
6
EFTA00027814

=== Page 7 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 7 of 14
trauma already endured by victims in this matter, and consideration of their
concerns prior to imposing a remedy is vital to the Court's determination.
Providing a reasonable period for the government to speak with victims is
also important because both Petitioners and the government lack clarity about
what victims want and how they may be affected by this matter. During the
parties' discussions, Petitioners acknowledged that they have consulted only a
subset (less than a majority) of the victims. The parties also agree that victims are
likely to hold varying opinions about an appropriate remedy, including those
who are likely to oppose rescission of the Agreement. Accordingly, the
government believes that a sixty-day period to confer with victims is the
minimum amount of time needed to inform its judgment about a remedy so it
can effectively advise the Court.
In light of the government's expressed commitment to speak to victims about
a remedy, Petitioners' opposition to the government's request is disappointing
and would lead to a flawed process. Petitioners' counsel have cited multiple
reasons for their opposition, none of which withstand scrutiny.
First, counsel contend that the government has declined the opportunity to
confer with victims over the past ten years, so it should not be given time to do
so now. While the government understands Petitioners' concern regarding the
prior efforts of the U.S. Attorney's Office of the Southern District of Florida to
communicate with victims, undersigned counsel have repeatedly expressed to
Petitioners our intention to speak with victims from the outset of our
600 U.S. Courthouse, 75 Ted Turner Drive S.W., Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
7
EFTA00027815

=== Page 8 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 8 of 14
involvement in March 2019. Indeed, a different approach was necessitated by the
different procedural posture of this case after the Court entered its order of
partial summary judgment.² [Doc. 435] Based on that order, the government now
seeks to assist the Court's determination of a remedy through a recommendation
informed by an understanding of the victims' concerns. The government's
commitment to confer with victims at the remedy stage has been, and will
remain, firm.
Second, Petitioners' counsel suggest that a period dedicated to conferring
with victims would further delay proceedings. But the government's request for
a sixty-day period to speak with victims after Petitioners' submission on
remedies is reasonable, if not ambitious, particularly in light of the fact that
Petitioners have only consulted with a subset of victims over the past ten years.
The government does not seek an open-ended delay, but instead asks for a
2 Petitioners' counsel also have suggested that the government's prior
objection to their motion to add Jane Doe No. 3 and Jane Doe No. 4 as plaintiffs is
inconsistent with the government's commitment to speak with victims. Not so.
The government objected to their joinder based on legal infirmities in Petitioners'
motion, including the untimely nature of the request, the statute of limitations,
and the injection of new legal issues when Jane Doe No. 4 was not known to the
government at the time of the Agreement. [Doc. 290 at 12-13; Doc. 314 at 23-24].
The Court agreed that adding Jane Doe No. 3 and Jane Doe No. 4 was improper
this "late in the proceedings." [Doc. 324 at 7]. The government never asserted
that the views of these victims could not be considered at the remedy stage.
600 U.S. Courthouse, 75 Ted Turner Drive S.W., Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
8
EFTA00027816

=== Page 9 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 9 of 14
reasonable chance to speak to as many victims as possible so that it can frame a
proper remedy and inform the Court.³
Third, Petitioners' counsel claim that the government could file its proposed
remedy first and then amend its pleading later, if necessary, after speaking to
victims. Such an approach would lessen, not promote, an efficient resolution by
inviting the prospect of amended filings with accompanying multiple rounds of
briefing. No judicial or victim interests are served in requiring the government to
submit an incomplete filing lacking victim input before supplementing later.
Most troubling, Petitioners' counsel suggest that only the views of Jane Doe
No. 1 and Jane Doe No. 2 should be relevant to a remedy, and that the Court
should not consider the opinions of other victims given the certainty that some
will hold differing views. The fact that victims likely have diverse concerns and
opinions about the proper path forward makes it more essential, not less, that the
Court have the benefit of their viewpoints for its consideration. The government
trusts that Petitioners' counsel will effectively advocate for Petitioners' desired
relief. But Petitioners should not impede the Court's consideration of other
3 Although Petitioners assert that the Court's "limited" extension granted in
March gave the government enough time to confer with victims, this claim does
not align with what the Court ordered the government to do, which was to
confer with Petitioners regarding the procedures for deciding a remedy after
reviewing the voluminous pleadings in this matter. [Doc. 448 at 1-2]. The
government has worked diligently to do so.
600 U.S. Courthouse, 75 Ted Turner Drive S.W., Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
9
EFTA00027817

=== Page 10 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 10 of 14
victims who may be affected by a remedy, particularly when the parties have not
spoken to the majority of them.
Accordingly, the government's request for a sixty-day period to speak to
victims who may be affected by a remedy should be granted. Such a process is
fair to Petitioners, just to the victims, and essential for the Court.
2. Petitioners should file a pleading setting forth their requested remedy to
clarify the relief sought before the government's response.
The parties disagree as to which party should submit the initial statement
setting forth a recommended remedy, but general rules of civil practice, the
statutory language of the Crime Victims' Rights Act ("CVRA"), and the judicial
interest in an efficient resolution of this matter require Petitioners to identify
their remedy first.
General principles of civil practice require the plaintiff to identify the relief
requested. Civil complaints must contain "a demand for the relief sought." Fed.
R. Civ. P. 8(a)(3). No authority supports Petitioners' apparent position that if a
plaintiff subsequently establishes a claim for relief, the burden shifts to the
respondent to propose the remedy to be entered. Simply stated, Petitioners must
identify the specific relief they seek to accord the government with fair notice
and an opportunity to respond.
Contrary to Petitioners' contentions, the CVRA does not mandate a different
result. The "Enforcement and Limitations" provisions of the CVRA, 18 U.S.C.
$ 3771(d), outline the remedial steps that may be taken by victims seeking to
600 U.S. Courthouse, 75 Ted Turner Drive S.W., Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
10
EFTA00027818

=== Page 11 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 11 of 14
assert their rights enumerated in 18 U.S.C. $ 3771(a). Specifically, Section 3771(d)
provides that victims may seek relief for any violation of their CVRA rights,
states that victims may do so by filing a motion, and sets forth limitations on
remedies that may be granted under the CVRA. 18 U.S.C. §§ 3771(d)(1), (d)(3),
(d)(5)-(6). Although Section 3771(d) does not explicitly state which party must
recommend specific relief in all cases, it does identify the party who must make a
motion for at least one of the potential remedies: "the victim." 18 U.S.C.
$ 3771(d)(5). If the "victim" must make a request to reopen a plea or sentence, id.,
it is incumbent on Petitioners to file a pleading setting forth their requested
remedy if they seek to reopen the Agreement here.
In an improper effort to shift this burden to the government, Petitioners claim
that a different CVRA subsection, Section 3771(c), which is separate from the
Section 3771(d) remedial provisions, requires the government to file first. But this
provision merely sets forth the general principle that the government should
"make their best efforts" to notify victims of their rights under the CVRA. 18
U.S.C. $ 3771(c)(1). To the extent that this provision has any bearing on this issue,
the government's request for reasonable time to confer with victims, and to
thereby treat them with "fairness and respect for the victim's dignity and
privacy," represents the government's best efforts to accord the victims their
rights at this stage. 18 U.S.C. §§ 3771(a)(5), (a)(8).
In addition, an initial statement from Petitioners clarifying the specific
remedies sought will facilitate a more efficient resolution because it will focus the
600 U.S. Courthouse, 75 Ted Turner Drive S.W., Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
11
EFTA00027819

=== Page 12 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 12 of 14
government's discussions with victims. It is presently unclear what relief
Petitioners believe is suitable in this case. Shortly after initiating this lawsuit,
Petitioners' counsel stated that "because of the legal consequences of invalidating
the current agreement, it is likely not in my clients' best interest to ask for the
relief that we initially asked for." [Doc. 403-21 at 4]. Three years later, Petitioners
proposed a list of more than a dozen potential remedies, including the rescission
of the Agreement. [Doc. 127 at 14-15]. In recent discussions, Petitioners have not
identified what, if any, of these remedies they will seek in addition to some form
of rescission of the Agreement. The government needs to know what remedies
Petitioners propose in order to speak openly and effectively with victims about
their views on relief. Delaying the Petitioners' pleading would force the
government either to have multiple discussions with victims before and after
receiving clarity on Petitioners' requested relief, or to forgo discussions with
victims until both parties had already recommended relief without victim input.
This proposal is neither efficient nor serves the victims' interests.
Accordingly, Petitioners should set forth their requested relief, followed by
the government's responsive brief after a reasonable period to confer with
victims.
600 U.S. Courthouse, 75 Ted Turner Drive S.W., Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
12
EFTA00027820

=== Page 13 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 13 of 14
CONCLUSION
For the foregoing reasons, the Court should adopt the government's proposed
procedures to aid in its determination of what remedy, if any, should apply.
Respectfully submitted,
BYUNG J. PAK
United States Attorney
/s/
Special Attorney
/s/
Special Attorney
600 U.S. Courthouse, 75 Ted Turner Drive S.W., Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
13
EFTA00027821

=== Page 14 ===
Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 14 of 14
Certificate of Service
I served this document today by filing it using the Court's CM/ ECF system,
which automatically notifies the parties and counsel of record.
May 10, 2019
Assistant United States Attorney
EFTA00027822


c1: EFTA00028168
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028168.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
To:
)"
Cc:
(USANYS)"
)"
)"
Subject: Re: [EXTERNAL] Re: Subpoena to Interlochen Center for the Arts
Date: Thu, 04 Nov 2021 16:17:39 +0000
You can contact him directly. I do not anticipate representing him in connection with the case, but I'll let you know if that
changes.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, November 4, 2021 at 12:16 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
(USANYS)"
)"
>,
)"
Subject: Re: [EXTERNAL] Re: Subpoena to Interlochen Center for the Arts
Thanks, Jeff. Should we connect with him directly, or would you like to be on the call? Please let me know whether you'll
be representing him in connection with this case.
On Nov 4, 2021, at 12:11 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi
-
Sorry about the delay. The person is Dan Besselsen.
Dan Besselsen, CPA
Assistant Vice President of Finance
Interlochen Center for the Arts
E: dan@interlochen.org
P: 231.276.7345
EFTA00028168

=== Page 2 ===
I told him to expect a call. Let me know if you need anything else.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Tuesday, November 2, 2021 at 3:45 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: Re: Subpoena to Interlochen Center for the Arts
Jeff,
Following up on our conversation, could you please let us know when works to have a call with the records custodian
who will be testifying?
Thanks,
On Oct 22, 2021, at 2:45 PM,
wrote:
Thanks very much. Let's plan to talk at 1 p.m. on Monday, if that works.
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 22, 2021 1:55 PM
To:
Subject: [EXTERNAL] Re: Subpoena to Interlochen Center for the Arts
Monday afternoon works. Today is shot.
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
EFTA00028169

=== Page 3 ===
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, October 22, 2021 at 1:25 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Are you available for a call today or Monday to follow up on our conversation about a records
custodian testifying at trial?
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com
Sent: Friday, May 14, 2021 10:50 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
I just reached out to Interlochen and they do not have a color version.
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, May 14, 2021 at 10:38 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Received, thanks very much Jeff. Do you have a color copy of the photograph on page 87?
EFTA00028170

=== Page 4 ===
Best,
Alison
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, May 13, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
Attached is what went in the mail today.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Wednesday, May 12, 2021 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on this.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Monday, April 26, 2021 10:32 AM
To:
Cc:
)
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
EFTA00028171

=== Page 5 ===
I'm working on it and hope to have it complete and ready in the next couple of days.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, April 26, 2021 at 9:28 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Could you please let us know when you expect to produce these materials?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, March 26, 2021 5:33 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Just confirming receipt. Also, I'm hopeful that we can have everything gathered by April 12th. However, l'll be out of
the office for the next week so it might be delayed. Will that be a problem?
In addition, and just for confirmation's sake, you are ok that we will make reasonable efforts to notify the
parents/students of the subpoena prior to compliance with the subpoena correct?
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
EFTA00028172

=== Page 6 ===
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Friday, March 26, 2021 at 3:37 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
Thanks again for taking the time to speak with me this morning. As we discussed, I'm attaching a subpoena for
additional student records.
Thank you,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Sounds good. Yes, that is the best number.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 4:40 PM
EFTA00028173

=== Page 7 ===
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Thanks so much-let's plan to talk at 9:30 tomorrow morning, if that works for you. Is this the best number to reach
you then: 231-947-0400
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:32 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm available between 9am and 10am, and then again after 11am.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, March 25, 2021 at 3:41 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Are you available for a quick call tomorrow morning?
Thanks very much,
EFTA00028174

=== Page 8 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, January 7, 2021 11:10 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
231-947-0400
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, January 7, 2021 at 10:37 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff- - what is the best number to reach you this morning? Thanks.
Sent from my iPhone
On Jan 5, 2021, at 3:21 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me.
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
EFTA00028175

=== Page 9 ===
From:
"
)"
Date: Monday, January 4, 2021 at 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
That would be great, thanks. Would Thursday at 11:30 work for you?
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Sure. Does Wednesday or Thursday morning work?
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Are you available for a call sometime in the next few weeks? We have one or two follow up
questions that would be helpful to talk through.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, December 30, 2020 2:37 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
EFTA00028176

=== Page 10 ===
Sorry about the delay. Interlochen doesn't have any other documents regarding tuition payment information or
payments by Epstein or Epstein entities.
Let me know if you have any other questions.
Thanks,
Jeff Jocks
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
From:
Sent: Monday, November 16, 2020 3:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
^
is
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. I'm following up on our conversation from earlier this month to see if you have any
updates on the categories of documents we discussed.
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 11:15 AM
EFTA00028177

=== Page 11 ===
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
That works for me. I will call in at 10am Monday.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line:
Thanks,
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi
-
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do
so. Regardless, the response included everything that Interlochen has. They only keep tuition payment
information for 7 years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
EFTA00028178

=== Page 12 ===
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the
use of the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under
applicable law. If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd
still be grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
EFTA00028179

=== Page 13 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or
determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the
use of the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under
applicable law. If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com>, "Donnini, George B." <donnini@butzel.com>
Cc:
)"
)"
=
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose.
EFTA00028180

=== Page 14 ===
Would you please confirm that your production included all records of any tuition payments that Epstein (or his
entities) made for any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial
tomorrow and will have limited availability this week, but my colleagues
and
(both
cc'd) should be able to coordinate with you as needed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
Cc:
is
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the
use of the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under
applicable law. If you are not the named addressee, please delete it immediately. Thank you.
From: "
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
)"
=
Subject: Subpoena to Interlochen Center for the Arts
EFTA00028181

=== Page 15 ===
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey
Epstein and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request
confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00028182


c1: EFTA00027255
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027255.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Draft OCME Letter
Date: Tue, 27 Aug 2019 23:27:10 +0000
Attachments: 2019.08.28_Letter_to_OCME.docx
Please see attached for your review. We tried to keep this as brief as possible while still accurately describing the contents
of their file that we do not want disclosed, and the circumstances under which they were disclosed. Let us know if you
have any thoughts. Our call is at 10 tomorrow morning and we'd like to send this after the fact. I also spoke with the GC
by phone tonight to give her a head's up that this was coming, and she did not have any issues with it.
Thanks,
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00027255


c1: EFTA00028480
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028480.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Bcc:
"
Subject: FW:
documents
Date: Sun, 25 Oct 2020 17:40:41 +0000
Embedded: FW:
documents.msg
Sender:
Subject: FW:
documents
Message-Id:
<SN5P110MB0542F21B9949813432155A2292180@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM>
Cc:
Cc:
EFTA00028480


c1: EFTA00028451
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028451.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: SW for devices
Date: Mon, 15 Jul 2019 12:20:29 +0000
Importance: Normal
Attachments: SW_for_JE_Phone_iPad_Suitcases_v2docx.docx
Hi
Attached is the affidavit seeking a search warrant for Epstein's phone and ipad, as well as the electronic media seized from
the suitcases at the house. Please review it and give me a call if you have any concerns or edits. Hope is to swear this out
after the bail hearing.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00028451


c1: EFTA00028823
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028823.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS) [Contractor]"
)"
Cc:
(USANYS) [Contractor]"
(USANYS)"
)"
Subject: RE: Epstein/Maxwell Upload
Date: Thu, 24 Sep 2020 18:33:31 +0000
The zip files have been copied to the below location. Please let me know if there are any issues with the data in the zip
files.
Thank you.
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:42 AM
To:
(USANYS) [Contractor]
is
Cc:
(USANYS) [Contractor]
is
(USANYS)
;
)
Subject: RE: Epstein/Maxwell Upload
That's what I figured. Thanks! Now that they are all good to go would you please export both Deutsche Bank and
JPMorgan productions to the shared here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-
2018R01618\Discovery\GM\04 Fourth Production\TO BE PRODUCED
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:39 AM
To:
(USANYS) [Contractor]
>;
Cc:
(USANYS) [Contractor]
>;
(USANYS)
Subject: RE: Epstein/Maxwell Upload
No way to put a confidential stamp on a excel file. There should be an image placeholder that says document produced in
native format which has the confidential stamp.
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:36 AM
To:
(USANYS) [Contractor]
is
Cc:
(USANYS) [Contractor]
is
(USANYS)
>;
Subject: RE: Epstein/Maxwell Upload
Thanks
These look great. One quick question, on documents in native format (excel files) is there a confidential
stamp? I've checked and it seems the answer is no but I just want to be sure that I'm not missing anything.
EFTA00028823

=== Page 2 ===
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:20 AM
To:
is
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS)
i
Subject: RE: Epstein/Maxwell Upload
The documents should now be available for review. Please let me know if there are any questions.
Thank you.
From:
)
Sent: Thursday, September 24, 2020 9:11 AM
To:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS)
;
Subject: RE: Epstein/Maxwell Upload
These documents are not supposed to be privileged reviewed. The only documents that need to be privilege reviewed
are the electronic search warrant returns.
Thanks,
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 9:05 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
)
V.
(USANYS)
>;
Subject: RE: Epstein/Maxwell Upload
The data is probably secured for privilege review. Please let me know if these documents are not supposed to be
privileged reviewed.
Thank you.
From:
(USANYS) [Contractor]
Sent: Wednesday, September 23, 2020 5:39 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
V.
(USANYS)
is
)
Subject: RE: Epstein/Maxwell Upload
Hey
When I click on each of those links I'm brought to a Relativity page with no data. Am I doing something wrong?
Thanks,
EFTA00028824

=== Page 3 ===
Will
From:
(USANYS) [Contractor]
Sent: Wednesday, September 23, 2020 11:32 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
>;
(USANYS)
>;
)
Subject: RE: Epstein/Maxwell Upload
The production of the documents has been completed. The below are links to the production for you to review:
Deutsche Bank - https://d1pe.nss.pae.com/Relativity/go?id=1420850-2343058
JP Morgan - https://d1pe.nss.pae.com/Relativity/go?id=1420850-2343059
Please review the documents and let me know if anything needs to be adjusted with the production.
Thank you.
From:
(USANYS) [Contractor]
Sent: Friday, September 18, 2020 10:26 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
V.
(USANYS)
>;
Subject: RE: Epstein/Maxwell Upload
1. Yes, we want to mark all of them confidential
2. We are working on that.
3.
I suppose database load files? We want to retain the files as they are currently formatted as best we can.
4.
That won't be an issue. I don't think we will be searching through them; the purpose is just to be able to stamp
them.
Thanks!
From:
(USANYS) [Contractor]
Sent: Friday, September 18, 2020 10:10 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
V.
(USANYS)
is
Subject: RE: Epstein/Maxwell Upload
I know you want to produce these documents can you please tell me the following:
1.
Will you placing a Confidential stamp on these documents?
2.
What bates number do you wish to use on the documents?
3.
How do you want to produce the documents (single page tiff images, database load files or PDF production).
4. Also please note that once the documents have been loaded to Relativity there is no way to run any searches for
these images since they are mostly images and video.
Please let me know if there are any questions.
EFTA00028825

=== Page 4 ===
Thank you.
From:
(USANYS) [Contractor]
Sent: Thursday, September 17, 2020 4:54 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
>;
(USANYS)
is
Subject: Epstein/Maxwell Upload
Hey
We have some materials that we need uploaded to Relativity to the Epstein database for the purpose of stamping them.
The files in question number about 40,000 and are about 300GB in size. They are currently copying onto a drive to be sent
to Relativity and should be ready by tomorrow. Do you want to see them first or can they go directly to PAE?
Folder/Subfolder in Relativity: US V. Epstein
FBI Case File
Images Seized During Search
Thanks,
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
Office:
Cell:
EFTA00028826


c1: EFTA00028030
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028030.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Cc:
Subject: RE: [EXTERNAL] information
Date: Tue, 26 Oct 2021 14:14:59 +0000
Hi
I think for now please just pass along any request that comes in to me. I've let BOP know about this, and can pass along
any request to our contacts there.
Thanks,
From:
Sent: Monday, October 25, 2021 9:14 PM
To:
Cc:
Subject: Re: [EXTERNAL] information
Thanks,
!
I'll figure out where it should go and let you know.
Sent from my iPhone
On Oct 25, 2021, at 8:36 PM,
wrote:
FYI- we discussed this over the summer but I guess he never submitted the request. I know you're no longer on the case
but let me know who I should forward this to in the event I receive a copy of his request. Copying
for his
awareness.
Begin forwarded message:
From:
)
Date: October 25, 2021 at 8:33:40 PM EDT
To:
Cc:
Subject: Re: [EXTERNAL] information
Hi Mr.
As I discussed with Ms.
over the summer, you would need to submit a FOIA request to the BOP and note that
you are specifically requesting what they released to the NYT. You can send me copy of that request once it has been
submitted to the BOP and as a courtesy I will ensure that the correct recipient in the Civil Division of our Office has
received it. We do not handle FOIA requests in our division.
Best,
EFTA00028030

=== Page 2 ===
On Oct 25, 2021, at 12:40 PM,
wrote:
Hi,
Hope this finds you well.
I I would like to get a copy of ALL of the records that were released to the New York Times on their FOI request
regarding my brother's case (Jeffrey Epstein).
Please advise the quickest way to accomplish this.
Thanks,
Scanned by McAfee and confirmed virus-free.
EFTA00028031


c1: EFTA00029492
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00029492.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: search terms for devices
Date: Sat, 10 Oct 2020 16:24:11 +0000
Embedded: RE:_search_terms_for_devices.msg
Sender:
Subject: RE: search terms for devices
Message-Id:
<SN5P110MB0542186AD3CA621EE33AD81892090@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM
>
To
Cc
EFTA00029492


c1: EFTA00027875
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027875.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
:
)"
Subject: RE: New Maxwell Lawsuit
Date: Wed, 18 Mar 2020 21:55:23 +0000
Attachments: Maxwell_suit.pdf
Yeah we saw this, thanks. Suit itself is attached.
From:
(USANYS)
Sent: Wednesday, March 18, 2020 11:53
To:
>;
)
>;
Cc:
(USANYS)
Subject: New Maxwell Lawsuit
https://www.nytimes.com/2020/03/18/business/jeffrey-epstein-ghislaine-maxwellawsuit.html?
action=click&module=Latest&pgtype=Homepage
EFTA00027875


c1: EFTA00027710
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027710.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: November 11th 2021 password for Maxwell #
Date: Mon, 15 Nov 2021 20:05:40 +0000
Attachments: 2021.11.11_MDC - Maxwell_PASSWORD.pdf
Hi - Attached is the letter with the password
Thanks,
Original Message
From:
Sent: Monday, November 15, 2021 2:33 PM
To:
Cc:
Subject: Fwd: November 11th 2021 password for Maxwell #
Can you please provide us a letter with the password so that we can give her the hard drive tomorrow?
11/15/2021 2:21 PM
We have received the hard drive (key pad ) for Maxwell #
but haven't received the password. Can
you assist me with this request?
Legal Assistant
(P)
EFTA00027710


c1: EFTA00028662
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028662.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Ce:
Subject: SDNY NEWS CLIPS, OCTOBER 26, 2020
Date: Mon, 26 Oct 2020 18:57:08 +0000
Inline-Images: image001.png
OFFICER OF
SDNY PRESS CLIPPINGS
ENTER
DEPARTMENT
JUSITTIA
MAXWELL
POST: https://nypost.com/2020/10/24/operation-underway-to-spring-ghislaine-maxwell-from-jail/
BLOOMBERGhttps://www.bloomberg.com/news/articles/2020-10-24/maxwell-dlaims-u-s-reneging-on-promise-to-turn-over-evidenc
GUARDIA:https://www.theguardian.com/uk-news/2020/oct/23/grince-andrew-asked-ghisiaine-maxwel-about-acuser-documents-sugest
MATTERS OF INTEREST
POST: https://nypost.com/2020/10/26/trump-would-dump-christopher-wray-if-he-wins-o-second-term-report/
WSJ: https://www.wsj.com/articles/sports-gambler-billy-walters-files-suit-faulting-ex-fbi-agent-over-leaks-11603400794-
CNBC: https://www.cnbc.com/2020/10/26/heres-what-wal-street-analysts-aresaying-obout-the-newly-public-palantic.html
LAW.COM: https://www.law.com/newyorklawjournal/2020/10/23/timing-quirk-meons-that-injanuary-us-gg-bor-may-directly-oversee-sdnyprosecutors-offce/
WASHINGTON EXAMINER:-https://www.washingtonexaminer.com/news/hunter-biden-aleged-sextope-and-images-uplooded-on-bonnon-conected-chinese-website-
DAILY NEWS: https://www.thedailybeast.com/boston-ballot-box-set-on-fire-outside-library-votes-destroyed
DAILY BEAST: https://www.thedailybeast.com/blame-comey-first-and-last-for-trump-taking-the-white-house
THE HILL: https://thehill.com/homenews/campaign/522706-white-house-lawyer-helped-shop-controversial-hunter-biden-story-to-wal
VOX: https://www.vox.com/21527215/hunter-blden-jared-ivanka-eric-don-junior
LA TIMES: https://www.latimes.com/opinion/story/2020-10-26/belarus-election-fraud-mass-protests
EPOCH TIMES: htps://www.theepochtimes.com/new-york-times-8-month-long-investigation-of-the-epoch-times-light-on-facts-heovy-or-bios_3487144.hml
NYT: https://www.nytimes.com/2020/10/25/business/media/hunter-biden-wall-street-journal-trump.html
MAIN: Watch Video: This Week at Justice
EFTA00028662

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=== Page 1 ===
From:
To: Nathan NYSD Chambers
Cc:
Jeff Pagliuca
>, , Laura Menninger
Subject: US V. Maxwell - 20 Cr. 330 - Letter re Minor Victim-3
Date: Sat, 06 Nov 2021 03:56:27 +0000
Attachments: Gov't_Letter_re_MV-3_[unredacted].pdf; Govt_Letter_re_MV-3_[proposed_redactions].pdf
Chambers,
Attached please find the Government's letter regarding Minor Victim-3, and a letter with proposed redactions. Pursuant
to the Court's procedure, and unless otherwise ordered, the Government will file a redacted version on the docket once
the defense notifies the Government whether it has any redactions.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00028203


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=== Page 1 ===
From:
To:
Subject: FW: Victims' Rights
Date: Fri, 22 Feb 2019 23:59:24 +0000
Importance: Normal
Attachments: Epstein_Opinion_(CVRA)_(2019-02-21).pdf
From:
Sent: Friday, February 22, 2019 2:29 PM
To:
Cc:
Subject: Victims' Rights
As a reminder, the Crime Victims' Rights Act applies in many if not most of our cases.
We most often deal with the CVRA by making sure that victims know about court appearances and are allowed to be
heard at sentencing, but the CVRA also provides, inter alia, that victims have "[t]he right to be informed in a timely
manner of any plea bargain or deferred prosecution agreement." 18 U.S.C. $ 3771(a)(9).
In the attached opinion, a district judge in Miami found that victims' rights were violated when the U.S. Attorney's Office
entered into a non-prosecution agreement without notifying them. (See pp. 25, et seq.)
This case is outside our Circuit, involved some unusual facts - including, arguably, actual deception of the victims, rather
than mere failure to notify - and it does not order a remedy.
That said, it is a case of some notoriety (Jeffrey Epstein's trafficking and sexual abuse of minors), so it is getting press
attention and is likely to be on the minds of our judges. Please be mindful of the CVRA as you negotiate pleas, and talk to
your supervisors about whether, how and when to inform victims. They don't get to determine how we dispose of cases,
but they're generally entitled to notice.
Thanks,
Assistant U.S. Attorney
Deputy Chief, Criminal Division
Eastern District of New York
Brooklyn, NY 11201
EFTA00029443


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=== Page 1 ===
From: Christian Everdell
To:
Cc: Jeff Pagliuca
>, Laura Menninger
BOBBI C STERNHEIM
Subject: [EXTERNAL] FW: 20cr330, US V. Maxwell
Date: Tue, 09 Nov 2021 18:38:47 +0000
Attachments: 20cr330_Order_docketed_11.8.21.pdf
All -
Our understanding was that the government was going to handle victim notifications and report to the Court. Please let
us know ASAP if that is not the case.
Thanks,
Chris
From:
Sent: Tuesday, November 9, 2021 1:30 PM
To: Jeff Pagliuca
; ; Laura Menninger
; Christian Everdell
;
Subject: 20cr330, US V. Maxwell
Counsel:
The attached Order was filed yesterday, which ordered a response by 12:00 p.m. today. See Dkt. No. 421. The
Court is not in receipt of the parties' response.
Sincerely,
Chambers of the Hon. Alison J. Nathan
EFTA00027648


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c3: VOL00008
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein Estate Touhy Requests
Date: Tue, 20 Aug 2019 18:57:20 +0000
Yes, I hoping to! I'm actually from TX and was taken years ago as a child, but don't really remember it.
From:
(USANYS)
Sent: Tuesday, August 20, 2019 2:21 PM
To:
(USANYS)
Subject: RE: Epstein Estate Touhy Requests
Go to the JFK museum if you have never been before and have the time - well worth the visit!
From:
(USANYS)
Sent: Tuesday, August 20, 2019 2:21 PM
To:
(USANYS)
Subject: Automatic reply: Epstein Estate Touhy Requests
Hello,
I am in Dallas for depositions, through Friday, August 23, 2019.
is covering.
Thanks,
EFTA00027229


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027699.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
"
(USANYS)"
Subject: updates
Date: Fri, 01 Mar 2019 15:31:43 +0000
Importance: Normal
Attachments:PC_Unit_--Short_Form_Update.3.1.19.v2.docx
Use this
EFTA00027699


c1: EFTA00028595
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028595.pdf
c6: pdf
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c0:
=== Page 1 ===
From:
)"
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Date: Fri, 14 May 2021 14:38:17 +0000
Received, thanks very much Jeff. Do you have a color copy of the photograph on page 87?
Best,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, May 13, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Attached is what went in the mail today.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Wednesday, May 12, 2021 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on this.
EFTA00028595

=== Page 2 ===
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Monday, April 26, 2021 10:32 AM
To:
Cc:
>;
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm working on it and hope to have it complete and ready in the next couple of days.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, April 26, 2021 at 9:28 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>, "
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Could you please let us know when you expect to produce these materials?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, March 26, 2021 5:33 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
EFTA00028596

=== Page 3 ===
Just confirming receipt. Also, I'm hopeful that we can have everything gathered by April 12th. However, l'll be out of the
office for the next week so it might be delayed. Will that be a problem?
In addition, and just for confirmation's sake, you are ok that we will make reasonable efforts to notify the
parents/students of the subpoena prior to compliance with the subpoena correct?
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, March 26, 2021 at 3:37 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
Thanks again for taking the time to speak with me this morning. As we discussed, I'm attaching a subpoena for additional
student records.
Thank you,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Sounds good. Yes, that is the best number.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
EFTA00028597

=== Page 4 ===
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 4:40 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Thanks so much-let's plan to talk at 9:30 tomorrow morning, if that works for you. Is this the best number to reach you
then: 231-947-0400
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:32 PM
To:
Cc:
)
>;
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm available between 9am and 10am, and then again after 11am.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 3:41 PM
EFTA00028598

=== Page 5 ===
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Are you available for a quick call tomorrow morning?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com
Sent: Thursday, January 7, 2021 11:10 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
231-947-0400
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, January 7, 2021 at 10:37 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff what is the best number to reach you this morning? Thanks.
Sent from my iPhone
On Jan 5, 2021, at 3:21 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me.
Jeff
EFTA00028599

=== Page 6 ===
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, January 4, 2021 at 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
That would be great, thanks. Would Thursday at 11:30 work for you?
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Sure. Does Wednesday or Thursday morning work?
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Are you available for a call sometime in the next few weeks? We have one or two follow up
questions that would be helpful to talk through.
EFTA00028600

=== Page 7 ===
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, December 30, 2020 2:37 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
Sorry about the delay. Interlochen doesn't have any other documents regarding tuition payment information or
payments by Epstein or Epstein entities.
Let me know if you have any other questions.
Thanks,
Jeff Jocks
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
From:
)
Sent: Monday, November 16, 2020 3:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
EFTA00028601

=== Page 8 ===
Cc:
is
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. I'm following up on our conversation from earlier this month to see if you have any updates on
the categories of documents we discussed.
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 11:15 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
That works for me. I will call in at 10am Monday.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line:
133318
Thanks,
Sent from my iPhone
EFTA00028602

=== Page 9 ===
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00028603

=== Page 10 ===
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still
be grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
>
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or
determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
EFTA00028604

=== Page 11 ===
From:
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com> "Donnini, George B." <donnini@butzel.com>
Cc:
)"
>,
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would
you please confirm that your production included all records of any tuition payments that Epstein (or his entities)
made for any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow
and will have limited availability this week, but my colleagues
and
(both cc'd) should be
able to coordinate with you as needed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
>
Cc:
is
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
EFTA00028605

=== Page 12 ===
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
)"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey
Epstein and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request
confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00028606


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=== Page 1 ===
From:
To:
Subject: Final Voucher
(1) prepared by a travel arranger is pending your review
Date: Mon, 10 Feb 2020 22:33:21 +0000
Importance: Normal
Dear
Final voucher
(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID:
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13340 - Epstein investigation (2018R01618) - Witness Interviews
Destination: Stockholm, Sweden
Dates: 2020-02-03 - 2020-02-06
Current status: Pending Voucher Approval
Voucher total expenses: 2143.49
Estimated trip cost: 2954.54
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
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Reference ID# V0012
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00027844


c1: EFTA00027391
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027391.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
Cc:
Subject: Fact Witness Travel Request
Date: Mon, 02 Aug 2021 13:50:01 +0000
Attachments:
_Fact_Witness_Travel_Request.dotx
Hi
Attached please find a request for
to travel to SDNY for trial prep with me this month. l'll need to meet
with him on August 17th at 2pm and August 18th at 10am.
Thanks so much,
EFTA00027391


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c0:
=== Page 1 ===
From:
"
)"
To:
(USANYS)"
Subject: Accepted: Epstein Team Meeting
Date: Sun, 08 Dec 2019 21:09:57 +0000
Importance: Normal
Attachments: unnamed
EFTA00029304


c1: EFTA00028544
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028544.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Declined: Epstein discovery deadline
Date: Thu, 15 Aug 2019 17:27:33 +0000
Importance: Normal
Attachments: unnamed
EFTA00028544


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c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028125.pdf
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c0:
=== Page 1 ===
From:
"
)"
To:
Subject:
Date: Fri, 20 Jul 2018 00:27:39 +0000
Importance: Normal
Attachments: 2017.06.12_Southside_Protective_Order_v4.docx
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00028125


c1: EFTA00028682
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028682.pdf
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=== Page 1 ===
From: Mariann Wang
To:
)"
, Gloria Allred
Subject: Re: Follow up
Date: Mon, 23 Nov 2020 02:09:26 +0000
Inline-Images: image001.png; image002.png
Ok, thank you. Shall we say 2pm EST/11AM PST? If so, I can call you with Gloria on the line then.
From:
Sent: Sunday, November 22, 2020 6:04 PM
To: Gloria Allred ; Mariann Wang
Subject: RE: Follow up
I'm wide open Wednesday if there is a time that day when a call would work on your end. I have been waiting for the
information you request from the FBI, and I will urge the case agents to get me this information in time for a Wednesday
call.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gloria Allred
Sent: Friday, November 20, 2020 1:53 PM
To: Mariann Wang ;
Subject: RE: Follow up
I could be available on Wednesday at any time, but I am in a mediation Monday and Tuesday and would not be available
then.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA
www.amglaw.com
www.gloriaallred.com
GLORIA ALLRED
2020
Best Lawyers
Martindale-Hubbel
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
From: Mariann Wang
Sent: Friday, November 20, 2020 10:50 AM
EFTA00028682

=== Page 2 ===
To:
Cc: Gloria Allred
Subject: Re: Follow up
:
I hope you're well. Could we set up a call maybe on Monday or Tuesday, depending on your/Gloria's availability
to hear anything at all on the two requests below, especially more info on the photos? We had been holding off
on sharing this potentially difficult-to-hear news with our clients till we had more info from you, but really need
to inform them soon.
Thank you,
Mariann
From: Mariann Wang
Sent: Wednesday, October 14, 2020 5:12 PM
To:
Cc: Gloria Allred
Subject: Re: Follow up
Got it, thank you.
From:
)
Sent: Wednesday, October 14, 2020 3:35 PM
To: Mariann Wang
Cc: Gloria Allred
Subject: RE: Follow up
Hi Mariann,
I apologize for the delayed response regarding your other questions. I've been waiting for the case agents to provide me
with the answers, but they have been swamped and have not had the chance to get back to me on this. They are traveling
for work this week, but I will check back in with them on this when they return.
Best,
From: Mariann Wang
Sent: Monday, October 12, 2020 3:12 PM
To:
Cc: Gloria Allred
Subject: Re: Follow up
,
Thanks to you and your team for your sensitivity and support in hearing our clients on Friday. They all very
much appreciated it.
May I just check in about the other two items below to see when you might have an update. Re the photograph
info especially, we don't want to convey the info to our clients until we understand the scope/clarifications.
Thank you,
Mariann
On Sep 30, 2020, at 9:26 PM, Mariann Wang
wrote:
Hi
:
We just wanted to check in on a few things.
The below request re documents/prior communications.
Any other news/info about the photographs.
And whether you/your team might be available on October 9th to interview the clients we had to adjourn a
few weeks ago,
and
,
EFTA00028683

=== Page 3 ===
Thanks,
Mariann
From: Mariann Wang
Sent: Thursday, August 13, 2020 6:03 PM
To:
)
Cc: Gloria Allred
Subject: Follow up
Thanks again for making time to talk the other day. Below are clients for whom we'd like to schedule
interviews with your office. (The initials next to their names are just for my purposes to remember who I need
to add from my office for these calls/meetings.) I'd also like to hop on the phone when you have a free 10
minutes to briefly discuss a few other clients who we haven't listed below. Please just let me know if you have
a moment tomorrow sometime.
Thanks,
Mariann
Cuti Hecker Wang LLP
To Be Scheduled -- interviews
one incident in New York.
,
-
,
multiple incidents in New York.
=
,
multiple incidents in NY. Some interactions with Maxwell
-
one incident in New York.
-
multiple incidents in Paris and Florida. Interacted
with others working for Epstein.
-
multiple incidents in NY and FL as well as incidents with two other
men at Epstein's direction in New York, California, and Washington, DC. In
,
final interaction with Epstein
included interaction with Prince Andrew at townhouse.
Over earlier time period, Maxwell left VMs on the apartment message machine.
interacted with and/or
traveled with multiple others working for Epstein.
8-10 incidents in Florida
From:
Sent: Tuesday, August 11, 2020 11:51 PM
To: Mariann Wang
>; ; Gloria Allred
is
i
)
Subject: RE: Zoom conference link for Wednesday at 2 pm ET / 11 am PT
Thank you, I'll plan to use the Zoom link Gloria sent tomorrow at 1pm ET/ 10am PT.
From: Mariann Wang
Sent: Tuesday, August 11, 2020 11:50 PM
To:
)
>; Gloria Allred
is
is
Subject: Re: Zoom conference link for Wednesday at 2 pm ET / 11 am PT
Works for me as well.
From:
)
Sent: Tuesday, August 11, 2020 11:31 PM
To: Gloria Allred
i
i
)
EFTA00028684

=== Page 4 ===
Cc: Mariann Wang
Subject: RE: Zoom conference link for Wednesday at 2 pm ET / 11 am PT
Thank you so much. Can we please plan on 1pm ET?
From: Gloria Allred
Sent: Tuesday, August 11, 2020 11:24 PM
To:
>;
)
V.
Cc: Mariann Wang
Subject: RE: Zoom conference link for Wednesday at 2 pm ET / 11 am PT
Either one of those new times works for me,
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA
www.amglaw.com
www.gloriaallred.com
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Tuesday, August 11, 2020 8:00 PM
To: Gloria Allred
i
i
)
Cc: Mariann Wang
Subject: RE: Zoom conference link for Wednesday at 2 pm ET / 11 am PT
Thank you very much. I apologize- I did not realize that I already have a meeting scheduled from 1:30pm to 3pm ET
tomorrow. Would it be possible to move this call either to 1pm ET or to 3pm ET, please?
From: Gloria Allred
Sent: Tuesday, August 11, 2020 5:16 PM
To:
)
y.
)
V.
Cc: Mariann Wang
Subject: Zoom conference link for Wednesday at 2 pm ET / 11 am PT
For the call on Wednesday 8/12 at 2 pm ET / 11 am PT -
Please click the link below to join the Zoom Meeting
Meeting ID:
Passcode:
Please join just a few minutes prior to the start time so the call can begin right away.
Please confirm you've received and thank you.
Executive Assistant to Gloria Allred
Los Angeles, CA
EFTA00028685

=== Page 5 ===
Facsimile
www.amglaw.com
From: Gloria Allred
Sent: Tuesday, August 11, 2020 12:44 PM
To:
in
is
Cc: Mariann Wang
Subject: RE: New potential victims of Epstein and some of Maxwell who are willing to speak to you and the FBI.
Thank you. We will send you a Zoom.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA
www.amglaw.com
www.gloriaallred.com
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Tuesday, August 11, 2020 11:26 AM
To: Gloria Allred
i
is
)
Cc: Mariann Wang
Subject: RE: New potential victims of Epstein and some of Maxwell who are willing to speak to you and the FBI.
Yes, I am available for a call tomorrow (Wednesday 8/12) at 2pm Eastern Time. Please let me know what number to call.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gloria Allred
Sent: Monday, August 10, 2020 7:31 PM
To:
)
is
)
is
Cc: Mariann Wang
Subject: New potential victims of Epstein and some of Maxwell who are willing to speak to you and the FBI.
My co- counsel, Mariann Wang, and I would like to schedule a call with one of you to discuss some questions we have
prior to scheduling our clients' interview with you. Would you be available for a call with us on Wednesday at 2 P.M.
e.s.t.?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA
www.amglaw.com
www.gloriaallred.com
Inducted into National Women's Hall of Fame - 2019
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
EFTA00028686

=== Page 6 ===
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged
information intended only for the addressee. If you are not the addressee you may not use, forward, copy or disclose to
anyone any information contained in this message. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY
ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT
Thank
you.
This message is CONFIDENTIAL and may contain legally
privileged information intended only for the addressee. If you are not the addressee you may not use, forward,
copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS COMMUNICATION
IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
EFTA00028687


c1: EFTA00028188
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028188.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
US V Epstein
Search Terms Report
Report Name: Search Terms . OPR Materials
Searchable Set: STR - Search Terms - OPR
Materials
300,000
280,000
267,137
260,000
240,000
220,000
200,000
180,000
160,000
140,000
120,000
100,000
80,000
60,000
32,986
40,000
19,512
20,000
0
Total documents with
Total documents with
Total documents without
hits
hits, including Family
hits
Results Summary
Documents in
Total documents with
Total documents with
Total documents
searchable set
hits
hits, including Family
without hits
300,123
19,512
32,986
267,137
Report Generated: 3/15/2021 10:00:14 AM
Page 1 of 4
EFTA00028188

=== Page 2 ===
US V Epstein
Search Terms Report
Report Name: Search Terms . OPR Materials
Searchable Set: STR - Search Terms - OPR
Materials
4,406
39
56
2,059
0
2
114
4
3,170
33
963
7
629
4
167
75
0
4
1,225
438
Report Generated: 3/15/2021 10:00:14 AM
Page 2 of 4
EFTA00028189

=== Page 3 ===
US V Epstein
Search Terms Report
Report Name: Search Terms - OPR Materials
Searchable Set:
STR - Search Terms - OPR
Materials
2,297
329
63
7,509
36
500 1000 1500 2000 2500 3000 3500 4000 4500 5000 5500 6000 6500 7000 7500 8000
Terms Summary
Term
Documents with hits
Documents with hits,
Unique hits
including Family
4,406
6,215
3,560
39
148
6
56
308
3
2,059
3,191
1,886
0
0
0
2
3
0
114
254
72
4
8
0
3,170
5,014
2,188
33
128
23
963
2,488
279
7
20
3
629
1,976
428
4
6
2
Ghislaine
167
484
0
75
135
14
gmax*
0
0
0
4
6
0
Maxwell
1,225
3,242
623
Report Generated: 3/15/2021 10:00:14 AM
Page 3 of 4
EFTA00028190

=== Page 4 ===
US V Epstein
Search Terms Report
Report Name: Search Terms - OPR Materials
Searchable Set: STR - Search Terms - OPR
Materials
Term
Documents with hits
Documents with hits,
Unique hits
including Family
438
1,156
226
0
0
0
2,297
5,132
1,217
329
1,033
210
63
575
42
7,509
15,037
5,874
36
125
7
Report Generated: 3/15/2021 10:00:14 AM
Page 4 of 4
EFTA00028191


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c3: VOL00008
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c0:
=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 20-3061 United States of America V. Maxwell "Opposition FILED to dismiss"
Date: Mon, 28 Sep 2020 21:26:24 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 09/28/2020
Case Name:
United States of America V. Maxwell
Case Number: 20-3061
Document(s): Document(s)
Docket Text:
OPPOSITION TO MOTION, to dismiss [37], on behalf of Appellant Ghislaine Maxwell, FILED. Service date
09/28/2020 by CM/ECF. [2940206] [20-3061]
Notice will be electronically mailed to:
Ty Gee,
Adam Mueller,
Laura Menninger, -
Gerard Whidbee, Deputy Clerk: Gerard
Notice will be stored in the notice cart for:
Gerard Whidbee, Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Opposition FILED
Original Filename: 2020.09.28 Response to Mot to Dismiss.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=09/28/2020] [FileNumber=2940206-0]
[50223f720a6c84b9eb7833f116a46755f7fcb429f3e11f55033ac2531fc2bb46b5e36e9130727a7e007b724f177ce9)
EFTA00028538

=== Page 2 ===
d06e0f5293f15f790fd1f5a4d9434e3b6e]
EFTA00028539


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c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027838.pdf
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c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
<m
,
,
Subject: Travel Authorization 10982122 approved by
, now awaiting further
approval
Date: Tue, 28 Jan 2020 16:08:43 +0000
Importance: Normal
Dear
Travel authorization 10982122 has been approved by
, now awaiting further approval.
Trip ID: 10982122
Traveler name:
Purpose: R20NYS13340 - Epstein investigation (2018R01618) - Witness Interviews
Destination: Stockholm, Sweden
Dates: 2020-02-03 - 2020-02-06
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.
EFTA00027838


c1: EFTA00029587
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00029587.pdf
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=== Page 1 ===
From:
"
)"
To:
"
(USANYS) [Contractor]"
,
(USANYS) [Contractor]"
Cc:
"
)"
(USANYS)"
,
)"
Subject: Another GM exhibit
Date: Sun, 29 Aug 2021 00:08:32 +0000
Attachments:
- Vol.pdf
Hi,
Would you please add the attached deposition transcript for
to the trial exhibits for the
Maxwell trial?
Thanks!
EFTA00029587


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=== Page 1 ===
From:
To:
Subject: Fwd: Prince Andrew
Date: Mon, 10 Feb 2020 23:37:41 +0000
email:
Sent from my iPhone
Begin forwarded message:
From:
Date: February 10, 2020 at 6:20:54 PM EST
To:
Cc:
Subject: Prince Andrew
- Per your request:
Following Geoff's comments about Prince Andrew on January 27, the team heard from counsel for several witnesses
who had seen Geoff's remarks and had concerns. Specifically, following the comments about Prince Andrew, the team
heard from counsel for
each of whom sought to confirm that their own
communications with the team about their clients would remain confidential.
and
- both of whom are
believed to have worked in some capacity for Maxwell/Epstein during relevant time periods - have never been
interviewed before but have expressed a willingness to come in, and the team has been working with their counsel to
arrange for interviews (we have an interview on the calendar with
for February 28).
who also was an
employee/assistant of Epstein's, who was ostensibly covered by the Florida NPA, and whose name has come up with
some frequency during the investigation, had previously declined to be interviewed, but more recently her counsel has
expressed a willingness to provide an attorney proffer as a first step toward a possible voluntary interview.
EFTA00028001


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=== Page 1 ===
From:
USANYS)"
To:
)"
Cc:
(USANYS) [Contractor]"
)"
)"
Subject: Re: Maxwell VW Page
Date: Thu, 16 Jul 2020 18:13:16 +0000
Sure thing, will do.
Sent from my iPhone
On Jul 16, 2020, at 12:48 PM,
)
wrote:
This looks great, thanks
and thanks especially for conforming it to what we posted in the Epstein case last year. I
just made a few very small changes, and we should be good to go. Let's please post the following:
July 16, 2019 update:
On July 14, 2019, an arraignment, initial conference, and bail hearing was held in the case of United States v.
Ghislaine Maxwell, 20 Cr. 330 (AJN). The defendant entered a plea of not guilty to the Superseding Indictment.
The court announced its ruling that the defendant will be incarcerated pending trial. The Court scheduled
discovery and motion deadlines for counsel as well as a trial date of July 12, 2021, before the Honorable Alison J.
Nathan, United States District Judge for the Southern District of New York, Thurgood Marshall United States
Courthouse, 40 Foley Square, New York, New York, in Courtroom 906. No next conference was scheduled at this
appearance.
Separately, currently on the home page we have a box for the Epstein case, that's a link to the updates and also
information on where to call with information. Could we please change that to the Maxwell case? So exact same
language, just change the case heading to the one for Maxwell, above, and switch "Jeffrey Epstein" to "Ghislaine
Maxwell" - so that if people just go to our main website, they can easily see where the updates are. Thank you!!
From:
(USANYS)
Sent: Wednesday, July 15, 2020 21:49
To:
is
>;
Cc:
USANYS) [Contractor]
Subject: Maxwell VW Page
Should we be updating to the page to reflect yesterday's hearing and order? Let me know if this works:
July 14, 2019 update:
On July 14, 2019, the initial conference, arraignment, and bail hearing were held in the case of United States v.
Ghislaine Maxwell, 20 Cr. 330 (AJN). The defendant entered a plea of not guilty to the Superseding Indictment.
The court announced its ruling that the defendant will be incarcerated pending trial. The Court scheduled discovery
and motion deadlines for counsel as well as trial date for July 12, 2021, before the Honorable Alison J. Nathan,
EFTA00028777

=== Page 2 ===
United States District Judge for the Southern District of New York, Thurgood Marshall United States Courthouse,
40 Foley Square, New York, New York, in Courtroom 906.
Sent from my iPad
EFTA00028778


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=== Page 1 ===
From: Richard Signorelli
To:
)"
Subject: Epstein
Date: Tue, 09 Jul 2019 21:17:41 +0000
Hi
and
,
I am sure you are already looking at this but there is a real mystery as to how this guy acquired his wealth and its
possible relationship with the charges thus far in the indictment. I already see significant tax evasion at the local
and state level with the way in which the mansion was transferred to him back in 1996 (no record, no transfer
taxes paid) as well as claiming the VI as his supposed primary residence. It would not surprise me that there is
significant tax evasion at the federal level along with underlying criminality involved in the acquisition of the
wealth in the first place.
Good luck with everything.
Best,
Rich
Richard E. Signorelli
www.nycLITIGATOR.com
Law Office of Richard E. Signorelli
)
This message may be privileged and confidential. If received in error, please delete it. All applicable privileges are reserved.
Thank you.
EFTA00028316


c1: EFTA00029068
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00029068.pdf
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c0:
=== Page 1 ===
From: "Weinstein, Marc A."
To:
Cc:
, Andrew Tomback
Subject: RE: Epstein - false warranty deed
Date: Wed, 11 Nov 2020 14:24:32 +0000
Thanks
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Tuesday, November 10, 2020 12:23 PM
To: Weinstein, Marc A.
Cc:
Andrew Tomback
Subject: Re: Epstein - false warranty deed
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
Thanks for letting us know. I've shared this with my supervisors, who asked me to let you know that our office is declining
to open an investigation. However, please feel free to contact local authorities.
Best,
Sent from my iPhone
On Nov 9, 2020, at 4:43 PM, Weinstein, Marc A.
wrote:
Attached is the warranty deed filed for the Palm Beach property which we believe to be fabricated. As mentioned, we
understand there has been a similar deed filed for the New Mexico property.
EFTA00029068

=== Page 2 ===
Best regards,
Marc
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
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<OR 31849 39 WD.pdf>
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=== Page 1 ===
Human Trafficking and Sexual Exploitation of Minors
This Office prioritizes the investigation and prosecution of numerous child pornography, child
enticement, child endangerment, and sex trafficking offenses.
In July 2019, prosecutors charged Jeffrey Epstein with sex trafficking of minors between
2002 through 2005, Epstein sexually exploited and abused dozens of underage girls by
enticing them to engage in sex acts with him in exchange for money. Epstein allegedly
worked with several employees and associates to ensure that he had a steady supply of
minor victims to abuse, and paid several of those victims themselves to recruit other
underage girls to engage in similar sex acts for money. The indictment against Jeffrey
Epstein was vacated following his death in August of 2019.
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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
(USANYS)"
Subject: RE: Epstein Account Documents
Date: Thu, 07 Oct 2021 16:57:06 +0000
Attachments: GX-504 - JPM-SDNY-00005512.pdf; GX-502
June_2007_statement_for_Ghislaine_Maxwell_(JPM-SDNY-00052158_-_IPM-SDNY-
00052165).pdf
Thanks! Could you please send me the account opening/signature/KYC documents for the two accounts attached here?
From:
Sent: Thursday, October 7, 2021 7:38 AM
To:
Cc:
(USANYS)
is
(USANYS) [Contractor]
Subject: RE: Epstein Account Documents
I have uploaded the account statement to DOJ USA File Exchange site. I have give you,
and
access rights to the
folder.
If you have any questions, please contact me.
Best
From:
)
Sent: Wednesday, October 6, 2021 4:12 PM
To:
(NY) (FBI)
Cc:
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Epstein Account Documents
Hi
Thanks very much. Could you please send us the account statements for a few months after these documents were
executed? It would be helpful to see the balances.
Thanks!
From:
Sent: Monday, October 4, 2021 8:27 AM
To:
Subject: Epstein Account Documents
As a follow up to our conversation regarding Epstein accounts where Ghislaine Maxwell was a signer on the account, I
have compiled the attached documents for your review.
EFTA00029227

=== Page 2 ===
If you have any question, please contact me.
Best
Forensic Accountant
FBI New York Field Office
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=== Page 1 ===
From: "subpoena-criminal@amazon.com". <subpoena-criminal@amazon.com>
To:
)"
Subject: [EXTERNAL] Amazon Ref. No. CRIM1153768 2021 (External Case No. 20 Cr. 330)
Date: Wed, 10 Nov 2021 16:49:56 +0000
amazon
This is an official communication from Amazon.
Certificate of Authenticity
I,
declare as follows:
1. I am an employee of Amazon, Inc. ("Amazon"). I make this declaration based on personal, firsthand
knowledge and, if called and sworn as a witness, I could and would testify as set forth below.
2. Amazon produced documents responsive to the above-referenced law enforcement request.
3. All documents produced by Amazon are authentic, are what they purport to be, and accurately describe the
transactions, communications, and events set forth therein.
4. All documents produced by Amazon are business records in that they are (i) records kept in the ordinary
course of business; (ii) created at or near the time of the transactions or events reflected therein, or based
on information from a person with knowledge of the transaction or events; and (iii) kept as a part of a
regular business activity.
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and
correct.
Executed on 11/10/2021, at Seattle, Washington.
Law Enforcement Response Team
Amazon.com, Inc.
NOTICE: This communication might contain privileged and/or confidential information. If you are not the
intended recipient or you believe that you have received this communication in error, please delete this message
and do not print, share, or otherwise use this message or its contents in any way. Please also indicate by reply
email that you have received this communication in error and that you have deleted it.
EFTA00029580


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=== Page 1 ===
From:
To:
Subject: RE: Maxwell
Date: Thu, 22 Apr 2021 20:32:57 +0000
Attachments: 2021-04-
-_request_to_file_under_seal.docx; 2021-
04-22_Govt_letter_re_GM_request_for_adjournment_v4.docx
Me too, thanks. Attached are the versions she plans to file by 5, FYI. The paragraph on the trial team's availability is the
last paragraph in the letter.
From:
Sent: Thursday, April 22, 2021 3:10 PM
To:
Subject: RE: Maxwell
Great. Thanks for letting me know. Glad we solved this.
From:
Sent: Thursday, April 22, 2021 3:09 PM
To:
Subject: RE: Maxwell
agreed with the sealed letter, and
wants to do that. l'll send you the final language as an FYI. Thank
you.
From:
>
Sent: Thursday, April 22, 2021 2:24 PM
To:
Subject: RE: Maxwell
I should be generally around until 3.
From:
Sent: Thursday, April 22, 2021 2:06 PM
To:
Subject: Maxwell
Maxwell filed her substantive trial adjournment letter today at 12, and our response is due at 5. I'd like to run one thing
by you that we plan to put in the response regarding our availability for trial if you have a couple of minutes to discuss.
Let me know when is convenient and l'll give you a call, thank you.
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
Desk
Cell
EFTA00027174


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=== Page 1 ===
From:
To:
Cc:
)"
Subject: Re: Phone call
Date: Sun, 11 Aug 2019 19:30:44 +0000
I will call and see if he is available
Sent from mobile device, please excuse typos.
Special Agent
Office of the Inspector General
1 Battery Park Plaza, 29th floor
New York, NY 10004
Cell
Office
> On Aug 11, 2019, at 3:08 PM,
wrote:
>
> Understood, thanks.
>
V
Can we set up a meeting with the warden for tomorrow? Nick and I are free any time. Thank you.
>
>
Original Message
> From:
> Sent: Sunday, August 11, 2019 :53 PM
> To:
i
> Subject: Phone call
V
V
It appears there is new information about the phone call at 7:17pm Friday night.
V
V
The Warden briefed OIG SAC Modano that the call was 19 minutes long. I did not brief the Warden on any
information regarding that call.
>
V
Epstein was never in general population, because of that he did not need an approved list of people to call.
V
> On Friday he had a legal visit that lasted from 8:00ish an until almost 7:00pm. He was supervised the entire
time by BOP staff.
V
V
Sent from mobile device, please excuse typos.
V
>
V
Special Agent
> Office of the Inspector General
> 1 Battery Park Plaza, 29th floor
EFTA00027263

=== Page 2 ===
New York, NY 10004
V V V V VVVV
Cell
Office
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=== Page 1 ===
From:
"
To:
Subject: FW: Disclosures for Robert Adams
Date: Thu, 12 Nov 2020 16:09:17 +0000
Attachments: Adams_Disclosures.rd.docx
My edits attached.
From:
Sent: Thursday, November 12, 2020 10:52 AM
To:
is
Subject: Disclosures for Robert Adams
Hey Chiefs:
We have our discovery deadline tomorrow in the Adams case. Nick and I have gone through the
witness interviews and propose making the attached disclosures, which we'll incorporate into the
discovery cover letter. We'd be grateful if you could take a look.
We've also checked in with the agents to get their views on these disclosures, and to make sure we are
not missing anything.
S Attorney
United States Attorney's Office for the Southern District of New York
New York, NY 10007
Tel:
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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
(USANYS)"
Subject: FW: Contact info for victim
(Epstein vic)
Date: Fri, 12 Jul 2019 21:09:00 +0000
Importance: Normal
Can I add this person. I would like to email them and ask who would like to get notification in the case the system will
only allow me to put one law firm.
From
Sent: Friday, July 12, 2019 4:45 PM
To:
(USANYS)
Subject: Contact info for victim
(Epstein vic)
Through her 3 attorneys.
1) )Daniel Kaiser
Kaiser Saurborn & Mair P.C.
2) William Kaiser
Kaiser Saurborn & Mair P.C.
3) Kimberly Lerner
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=== Page 1 ===
Date: 7/13/06
PALM BEACH POLICE DEPARTMENT
Page:
52
Time: 9:27:55
Incident Report
Program: CMS301L
Case No
: 1-05-000368
(Continued)
NARRATIVE
# 20
NA
Reported By:
-
11/16/05
Entered By. :
,
11/17/05
On 10/20/2005, I assisted executing a search warrant at
in the Town of Palm Beach, Palm Beach County Florida under
the direction of affiant Detective
-
EFTA00028592

=== Page 2 ===
Date: 7/13/06
PALM BEACH POLICE DEPARTMENT
Page:
53
Time: 9:27:55
Incident Report
Program: CMS301L
Case No
: 1-05-000368
(Continued)
Detective
and I searched the pantry room that is west
next to the kitchen. This room had all white cabinets with a dark
grey and black counter top. We did not find anything in this room.
We searched the yellow and blue room that is west next to the
pantry room. This room had a very large statue of man with a bow.
Taken into evidence from this room were nine photographs in frames of
various women.
We searched the main entrance foyer that is to the north of the
yellow and blue room. This room contained two bamboo chairs and
ottomans with cushions. It also contained a round table with numerous
books.
We searched another blue room that is west of the foyer. This
room had a stereo system and book shelves that were from the floor to
the ceiling. Taken into evidence from this room were eight
photographs in frames of various women and/or Epstein, the owner of
the residence.
We searched the room to the west of the blue room that has
sliding glass doors that lead out to the pool. In this room in a
dresser were two DVD's and two VCR tapes. These items were taken into
evidence.
We searched a 2004 black Chevy Suburban bearing Florida tag
X99-EGL, registered to Jeffrey Epstein DOB
,
which was located
on the east side of the driveway facing south. I found a Thrifty
rental agreement between the passenger seat and the middle console
The name on the rental agreement was
from
.
The phone number on the
rental agreement was
.
The vehicle rented was a white
2005 Chrysler Sebring bearing Florida tag W99-FUN. The vehicle was
rented on 9/25/05 at 17:58 hours and was returned on 9/26/05 at 16:52
hours. The last four numbers of the credit card used are
.
Detective
found a piece of paper in the middle console that
said I used the cash in here to fill up the tank and was signed by
.
I searched the 2005 black Cadillac Escalade ESV bearing Florida
tag Q29-9GT, registered to Jeffrey Epstein dob
, which was
located on the west side of the driveway facing south. I did not find
anything in this vehicle.
All of the items that were taken into evidence were photographed
in the place they were located and then turned over to crime scene.
NARRATIVE
#
21
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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: Read: RE: Epstein search materials for upload and privilege review
Date: Fri, 07 Feb 2020 14:41:56 +0000
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=== Page 1 ===
From:
To:
Subject: 19-2221 United States of America V. Epstein "FRAP 42(b) Stipulation with Prejudice RECEIVED"
Date: Tue, 20 Aug 2019 20:28:33 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 08/20/2019
Case Name:
United States of America V. Epstein
Case Number: 19-2221
Document(s): Document(s)
Docket Text:
FRAP 42 STIPULATION, With Prejudice, RECEIVED. Service date 08/20/2019 by CM/ECF.[2637473] [19-
2221]
Notice will be electronically mailed to:
Notice will be stored in the notice cart for:
Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: FRAP 42(b) Stipulation with Prejudice RECEIVED
Original Filename: Signed Stipulation to Withdraw Appeal.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=08/20/2019] [FileNumber=2637473-0]
[24edbf73536ccf434c106600e47e00d3f001156664e37f1ceed0b42c97de866d0cfeb1e9d23923b4c0d571f04ac5a6
e67a7be3ae1013ad10896b3a5835b9f17d]]
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=== Page 1 ===
From: "Berman, Geoffrey (USANYS)"
To:
Subject: Second Epstein victim says she had sex with Prince Andrew
Date: Sat, 07 Dec 2019 22:04:11 +0000
https://nypost.com/2019/12/07/second-epstein-victim-says-she-had-sex-with-prince-andrew./
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=== Page 1 ===
From:
To:
)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: RE: case lookup for L.A. County court?
Date: Mon, 16 Nov 2020 21:41:13 +0000
Embedded: RE:_RE:_case_lookup_for_LA._County_court?.msg
Sender:
Subject: RE: RE: case lookup for L.A. County court?
Message-Id:
<BN3P110MB0548263EF27EA3FC0D7974409CE30@BN3P110MB0548.NAMP110.PROD.OUTLOOK.COM
V
To:
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
Cc:
)"
Subject: RE: US V. Epstein
Date: Tue, 14 Jul 2020 14:59:47 +0000
Approved
From:
(USANYS) [Contractor]
Sent: Tuesday, July 14, 2020 10:57 AM
To:
(USANYS)
Cc:
Subject: US V. Epstein
Good Morning,
I received a new set of data from
(cc'd) for the Epstein matter. The cost for processing and uploading this data to
Relativity will be approximately $8,000.00. The data should be ready to ship to PAE by Wednesday or Thursday. I wanted
to know if I have your approval to send this data to the vendor.
Thank you.
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=== Page 1 ===
From:
To:
Cc:
Subject: RE:
notes
Date: Fri, 25 Jun 2021 18:32:16 +0000
Hey
,
This is all set. The folders have been created.
\Usa.doj.gov/cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Trial3500\1.Testifying\Production
1\
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Witnesses & Cooperators\
Thanks,
Original Message
From:
Sent: Friday, June 25, 2021 12:14 PM
To:
Cc:
Subject: FW:
notes
Hey
,
Would you please create new testifying witness folders for
on the Epstein share and
save the attached documents in those folders?
Thanks,
Original Message
From:
Sent: Friday, June 25, 2021 12:01 AM
To:
Subject:
notes
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: FOIA matter
Date: Tue, 12 May 2020 13:17:48 +0000
Great. We will pass along your contact info.
Original Message
From:
Sent: Monday, May 11, 2020 1:20 PM
To:
Cc:
Subject: RE: FOIA matter
Hi
,
That's fine. I'll likely pass them along to our General Counsel's Office who handles these issues.
Original Message
From:
Sent: Monday, May 11, 2020 1:18 PM
To:
Cc:
Subject: FOIA matter
I wanted to give you a heads up that an AUSA in our Civil Division is handling an Epstein-related FOIA request.
He has been keeping us informed as that matter proceeds. He may need to speak with someone in OIG, so if it's
okay with you, we would pass along your name and contact info.
Hope you're doing well,
Sent from my iPhone
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=== Page 1 ===
From:
To:
Subject: clean and redline
Date: Mon, 08 Jul 2019 14:05:12 +0000
Importance: Normal
Attachments: 2019-07-08,_JE,_detention_memo_draft.docx; detention_memo_redline.pdf
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
09
JPMorgan Chase Bank
2002
JPMorgan Private Bank
Account Number: Q 79961-00-1
Asset Account Portfolio
Page 8 of 9
JEFFREY EPSTEIN
September 01, 2002 - September 30, 2002
Activity by Date
continued
Settlement
Date
Type
Quantity Description
Amount USD
Sep 16
Misc. Disbursement
TRANSFERRED BY WIRE TO
1,000,000.00
PALM BEACH NATL BK & TR CO
FAO JEFFREY EPSTEIN
LETTER FROM CLIENT
Sep 18 Sale
-
- 5,000,000 JP MORGAN TAX FREE MONEY MARKET
5,000,000.00
FUND INSTITUTIONAL SHARE CLASS
(FUND 840)
J.P.MORGAN SECURITIES INC AS AGENT
@ 1.00
TRADE DATE 09/18/02
Sep 18
Misc. Disbursement
TRANSFERRED BY WIRE TO
-5,000,000.00
PALM BEACH NATL BK & TR CO
FAO GHISLAINE MAXWELL
LETTER FROM CLIENT
GOVERNMENT
EXHIBIT
504
$2 20 Cr. 330 (AJN)
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00005512
Chase
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=== Page 1 ===
90A-NY-3151227 Serial 49
FD-1057 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Electronic Communication
Title: (U) Chain of Custody- Digital Evidence
Date: 08/21/2019
Laboratory - Items 1B20, 1B21
From: NEW YORK
NY-C19
Contact:
,
Approved By: A/SSA
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S);
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Synopsis: (U) Chain of Custody- Digital Evidence Laboratory - Items
1B20, 1B21
Enclosure (s) : Enclosed are the following items:
1. (U) Chain of Custody- Digital Evidence Laboratory - Items 1B20, 1B21
Details:
On 08/16/2019, SA
and SA
transferred
items 1B20 and 1B21 of OTD/ the Digital Evidence Laboratory at
approximately 12:06AM. The OTD/ the Digital Evidence Laboratory chain of
custody is attached in a 1A package.
UNCLASSIFIED
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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
(USANYS)"
Subject: Re: Friendly Subpoena to
Attorney
Date: Fri, 26 Mar 2021 23:16:13 +0000
I just called her, she hopefully will respond momentarily.
Sent from my iPhone
On Mar 26, 2021, at 6:59 PM,
)
wrote:
FYI, haven't heard from Audrey.
From:
Sent: Friday, March 26, 2021 12:05 PM
To: Strauss, Audrey (USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
is
(USANYS)
>;
Subject: Friendly Subpoena to
Attorney
Hi Audrey,
The Maxwell team would like to send the attached "friendly subpoena" to
attorney
During our interviews in Florida,
informed me that he has a copy of the settlement agreement between
and Epstein, which resolved
2009 civil suit against Epstein.
is willing to provide us with a copy of the
agreement, but he indicated that he believes he needs a subpoena before he can do so. His firm has already provided
us with copies of all other court filings and deposition transcripts from the civil case voluntarily. The settlement
agreement resolving the case is relevant to our ongoing investigation into Maxwell's participation in the abuse of
and other underage girls.
Thanks,
<2021.03.26, subpoena to
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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: FW:
Date: Tue, 21 Jul 2020 17:16:22 +0000
Attachments: IMG_0266.JPG; IMG_0361.JPG
FYI
From:
Sent: Monday, July 20, 2020 22:08
To:
)
Cc:
Subject:
Pleasure talking with you on Friday.
As
had mentioned, she very much wants to get a copy of the pictures that
had taken.
If you find them, please forward a copy to us so we can give to her. This is something she has been asking me to get for years, but I
could never find.
To assist you with identifying
as she is now over a decade older, I am enclosing two pictures of
I had from 2008 or
2009, that were closer to the time the Epstein pictures were taken.
You are authorized to provide the pictures I am sending you to
and
Thanks for your help.
West Palm Beach, FL 33402
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=== Page 1 ===
Lisa M. Rocchio, Ph.D.
Johnston, RI
Phone:
Fax:
EDUCATION
1995
Ph.D. Clinical Psychology
University of Rhode Island, Kingston, RI
1992
MA Clinical Psychology
University of Rhode Island, Kingston, RI
1989
BA Psychology and English
Emory University, Atlanta, Georgia
1988
Visiting Student
Westfield College, London, England
ACADEMIC APPOINTMENT
2020 present
Clinical Instructor
Department of Psychiatry and Human Behavior
Alpert Medical School of Brown University
Providence, RI
LICENSURE
11/14 - present
Licensed Psychologist (MA) #10025
02/12 present
Licensed Psychologist (NY) #019490
12/97 present
Licensed Psychologist (RI) #00631
CLINICAL EXPERIENCE
7/98 present
Clinical Director and Owner, Inter-Disciplinary Independent Group Practice
Lisa M. Rocchio, Ph.D. & Associates, Inc. Johnston, RI
Psychotherapy, Assessment, Consultation, Education and Training,
Forensic Assessment, Forensic Consultation, Expert Testimony
12/97 6/98
Independent Practice
Associates in Psychotherapy, North Kingstown, RI
Psychotherapy, Assessment, Education and Training
7/96 11/97
Post-Doctoral Fellow in Psychology
Ann Begin, Ph.D., Associates in Psychotherapy, North Kingstown, RI
Women's Day Hospital Program, Butler Hospital, Providence, RI
3502-006
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Lisa Marie Rocchio, Ph.D. 2
7/94 7/95
Pre-Doctoral Intern in Psychology
Yale University School of Medicine, New Haven, CT
New Haven Hospital and Yale Psychiatric Institute
9/93 5/94
Clinical Psychology Extern
Counseling Center, University of Rhode Island, Kingston, RI
5/91 5/94
Clinical Psychology Trainee
Psychological Consultation Center, University of Rhode Island, Kingston, RI
9/92 5/93
Clinical Psychology Extern
Psychological Services, Brown University, Providence, RI
6/90 8/90
Family Service Student Counselor
7/91 8/91
Pre-Natal Clinic, St. Joseph's Hospital
Department of Family Service, Providence, RI
TRAINING AND CONSULTATION EXPERIENCE
2000 2002
Psychological Consultant
North Providence School Department
Performed comprehensive psychological evaluations of elementary school students
to determine the impact of psychological difficulties on school performance and
functioning. Evaluations involved clinical diagnostic interviews, psychological
testing, classroom observations and collateral interviews.
2000 2001
Psychological Consultant
Diagnostic Assessment Services, Middletown, RI
Performed comprehensive psychological evaluations of adolescents who had been
court ordered for outpatient psychological, cognitive and educational testing.
1999 2002
Consultant: Professional Development, Education and Training
Department of Children, Youth, and Families, Providence, RI
Developed and presented workshops to DCYF employees in the areas of trauma,
vicarious traumatization, and stress management.
1994
Mock Trial Expert Witness
Yale University School of Medicine, New Haven, CT
1992 1994
Workshop Leader
College Counseling Center, University of Rhode Island, Kingston, RI
Eating Disorders Workshops presented across campus to various student groups
and organizations
1992
Mock Trial Expert Witness
Travelers Worker's Compensation Trial Advocacy Program, Hartford, CT
RESEARCH EXPERIENCE
1999 2003
Research Group Member
Trauma Science Research Group, Providence, RI
6/93 9/93
Research Assistant
3502-006
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Lisa Marie Rocchio, Ph.D. 3
Outpatient Eating Disorders Research Group, Butler Hospital, Providence, RI
10/89 8/91
Research Project Coordinator
The Social Behavior of Developmentally Disabled Children, Bradley Hospital,
East Providence, RI
TEACHING EXPERIENCE
9/96 12/96
Adjunct Assistant Professor
University of Rhode Island, College of Continuing Education, Providence, RI
Introduction to Women's Studies (2 sections)
1/96 5/96
Special Instructor in Psychology
Providence College, Providence, RI
Psychology of Women (2 sections)
9/92 5/94
Instructor
Counseling Center, University of Rhode Island, Kingston, RI
Workshop Training for Eating Disorders Prevention
5/92 and 5/93
Teaching Assistant
University of Rhode Island, Continuing College of Education, Providence, RI
Psychology of Sexual Equality
9/91 5/92
Teaching Assistant
University of Rhode Island, Kingston, RI
Towards Self Understanding
SELECTED SPECIALIZED PROFESSIONAL TRAINING
2011 - 2012
Leadership Institute for Women in Psychology
Sponsored by the American Psychological Association, Committee on Women in
Psychology
Selected (through a competitive selection process) to participate in a leadership
training program for women in psychology, the mission of which
"is to prepare, support, and empower women psychologists as leaders to promote
positive changes in institutional and organizational life and increase the diversity,
number, and effectiveness of women psychologists as leaders".
2011
Continuing Education in Forensic Psychology (14 hours)
American Academy of Forensic Psychology (AAFP)
Comprehensive Assessment of Feigning in Forensic Settings
Forensic & Correctional Applications of the Personality Assessment Inventory
2006
Continuing Education in Forensic Psychology (28 hours)
American Academy of Forensic Psychology (AAFP)
Stalking: The State of the Science
Assessment of Response Style in Forensic Contexts
Excusing and the New Excuses
Psychological Evaluation and Testimony in Cases of Clergy or Teacher Sexual
Abuse
2005 2006
Psychotherapy Training Course for Dissociative Disorders (22.5 hours)
3502-006
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Lisa Marie Rocchio, Ph.D. 4
International Society for the Study and Treatment of Trauma and Dissociation
(ISSTD)
2004
Continuing Education in Forensic Psychology (21 hours)
American Academy of Forensic Psychology (AAFP)
Advanced Topics in Criminal Forensic Assessment
Forensic Consultation, Expertise & Testimony
Forensic Mental Health Assessment: Principles and Cases
2001
Eye Movement Desensitization and Reprocessing, Levels I & II (34 hours)
Eye Movement Desensitization and Reprocessing International Association
(EMDRIA)
1999 2000
Dialectical Behavior Therapy, Intensive Training, Parts I & II (72 hours)
Behavioral Technology Transfer Group
PUBLICATIONS
Bailey, T.D. & Rocchio, L.M. (2020). Evaluating the effects of repeated psychological injury: Introduction to the
Special Issue. Psychological Injury and the Law. NY: Springer
Rocchio, L.M. (2020). Ethical and professional considerations in the forensic assessment of complex trauma and
dissociation. Psychological Injury and the Law. NY: Springer
Rocchio, L.M. (Fall, 2015). Ethics corner: Psychologists Coping with Serious Health Concerns: Ethical,
Professional, and Risk Management Issues. The Newsletter of the Rhode Island Psychological Association.
Rocchio, L.M. (Spring 2011). Ethics corner: Ethical Considerations in Trauma Psychology: Vicarious
Traumatization and Self-Care. The Newsletter of the Rhode Island Psychological Association.
Rocchio, L.M. (Spring 2009). Ethics corner: How should I respond to a subpoena? The Newsletter of the
Rhode Island Psychological Association.
Lott, B. & Rocchio, L. M. (1998). Standing up, talking back, and taking charge: Strategies and outcome in
collective action against sexual harassment. In L.H. Collins, J. Chryslers, and K. Quina (Eds.) Career
strategies for women academics: Arming Athena. NY: Sage.
Lott, B. & Rocchio, L. M. (1997). Individual and collective action: Social approaches and remedies for
sexist discrimination. In H. Landrine and E. A. Klonoff (Eds.) Sexist discrimination: Prevalence,
correlates, and remedies. CA: Sage.
Rocchio, L. M., Feinstein, C., & Appareddy, V. (1997). The sibling of the psychiatrically disturbed child. In
J. Nashpitz (Ed), Handbook of Child and Adolescent Psychiatry.
Baker's Dozen (1997). Feminist student voices. In J. Worell and N. Johnson (Eds.) Feminist visions: New
directions for education and practice. American Psychological Association.
PROFESSIONAL PRESENTATIONS
Rocchio, L.M. (August, 2020). Ethical and professional considerations in the forensic assessment of trauma and
PTSD. In J. Scroppo (Chair), Ethics and Risk Management in Forensic Evaluations and Settings. Symposium
conducted virtually at the National Meeting of the American Psychological Association, Washington, DC.
3502-006
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Lisa Marie Rocchio, Ph.D. 5
Rocchio, L.M. (August, 2020). Ethical challenges when a client is engaged in a lawsuit: Dr. Helpful wants to help.
In APA Ethics Committee, Ethics Hot Topics. Panel presentation conducted virtually at the National Meeting of
the American Psychological Association, Washington, DC.
Rocchio, L.M. (August, 2015). Ethical dilemmas in the treatment of trauma in independent practice settings. In
Rocchio (Chair), Trauma treatment in independent practice settings: Ethical and relational issues. Skill
Building session conducted at the National Meeting of the American Psychological Association,
Washington, DC
Rocchio, L.M. (August, 2014). Trauma psychologists with serious health concerns: Ethical issues. In L. Rocchio
(Chair), Trauma psychologists with serious health concerns: Ethical, clinical and professional issues.
Symposium conducted at the National Meeting of the American Psychological Association, Washington,
DC.
Hughes, D.M. & Rocchio, L.M. (August, 2014). Essentials of forensic assessment of trauma in civil and
criminal litigation. Skill building session presented at the National Meeting of the American
Psychological Association, Washington, DC.
Rocchio, L.M. (August, 2013). Trauma in the treatment room: What the independent practitioner needs
to know. Skill building session presented at the National Meeting of the American Psychological
Association, Honolulu, HI
Rocchio, L.M. (August, 2012). The forensic evaluation of traumatic stress and dissociation in civil
litigation. In L. Rocchio (Chair), The forensic evaluation of traumatic stress and dissociation:
Malpractice and personal injury cases. Symposium conducted at the National Meeting of the American
Psychological Association, Orlando, FL.
Rocchio, L.M. (April, 2012). Trauma psychology: Legal considerations and ethical dilemmas in treatment.
Workshop presented at the 32nd Annual Meeting of the Anxiety Disorders Association of America,
Arlington, VA.
Courtois, C.A. & Rocchio, L.M. (April, 2012). Relationship dimensions and ethical factors in the
treatment of complex trauma. Workshop presented at the 32nd Annual Meeting of the Anxiety Disorders
Association of America, Arlington, VA.
Anthony, J., Feil, L., Rocchio, L.M., Plante, W., Sabo, R., and Spencer, M. (March 2012). Mental health
professionals in transition: Clinical, ethical, and practical considerations when life changes.
Professional Continuing Education Workshop sponsored by the Rhode Island Psychological
Association, Providence, RI.
Rocchio, L.M. (November 2011). Conceptualization and assessment of sexual harassment in civil
litigation. In D. Hughes (Chair), The conceptualization of trauma in a forensic context. Symposium
conducted at the 27th Annual Meeting of the International Society for Traumatic Stress Studies,
Baltimore, MD
Rocchio, L.M. (August 2011). Assessment of complex trauma in a clinical setting. In L. Rocchio (Chair),
Assessment of complex trauma and dissociation in clinical, forensic and research settings. Symposium
conducted at the National Meeting of the American Psychological Association, Washington, D.C.
Rocchio, L.M. (March 2011). Conceptualization, assessment, and treatment of trauma and dissociation:
Translating research into practice. In K. Rose (Chair), Advancing the applications and boundaries of
traumatic stress research: Translation between empirical inquiry and clinical case findings.
Symposium conducted at the National Meeting of the American Anxiety Disorders Association, New
Orleans, LA.
3502-006
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Lisa Marie Rocchio, Ph.D. 6
Rocchio, L.M. (March, 2011). The effects of trauma on the therapist. Paper presented at the National
Meeting of the American Anxiety Disorders Association, New Orleans, LA.
Hughes, D.M. & Rocchio, L.M. (November 2010). Forensic assessment of psychological trauma and PTSD.
Workshop presented at the 26th Annual Meeting of the International Society for Traumatic Stress
Studies, Montreal, Canada.
Rocchio, L.M. (August 2010). Professional and ethical considerations in trauma psychology: Psychotherapy.
In L. Rocchio (Chair), Professional and ethical considerations in trauma psychology: Psychotherapy,
forensics, research. Symposium conducted at the National Meeting of the American Psychological
Association, San Diego, CA.
Rocchio, L.M. (March 2010). Trauma psychology: What the anxiety disorders specialist needs to know.
Paper presented at the National Meeting of the American Anxiety Disorders Association, Baltimore,
MD.
Ethics Committee of the Rhode Island Psychological Association (June 2008). From In Treatment to our
treatment: Ethical considerations raised in the television program In Treatment. Continuing education
salon presentation sponsored by the Rhode Island Psychological Association, Providence, RI.
Ethics Committee of the Rhode Island Psychological Association (January 2007). Sex, lies &
confidentiality: A discussion of the top ten ethical issues posed to the RIPA Ethics Committee.
Professional Continuing Education Workshop sponsored by the Rhode Island Psychological Association,
Providence, RI.
Rocchio, L.M. (October 1999). The effects of trauma on the professional. Workshop presented at the Fifth
Annual Conference of the RI Coalition Against Domestic Violence, Providence, RI.
Rocchio, L.M. (April 1999). Discussant. In J.C. Chrisler (Chair), Addressing fat oppression: Research and
practice. Symposium conducted at the National Meeting of the Eastern Psychological Association,
Providence, RI.
Rocchio, L.M. (October 1997). Discussant. In J.C. Chrisler (Chair), Current issues in feminist therapy.
Symposium conducted at the National Meeting of the New England Psychological Association, Easton,
MA.
Johnston-Robledo, I., Rocchio, L. M., & Chrisler, J. C. (March 1997). AWP program content 1981 - 1996:
Where we 've been, where we 're heading. Discussion facilitated at the National Meeting of the
Association for Women in Psychology, Pittsburgh, PA.
Rocchio, L.M. (October 1996). Discussant. In J.C. Chrisler (Chair), Women and weight: Gendered
messages from the media. Symposium conducted at the National Meeting of the New England
Psychological Association, New London, CT.
Rocchio, L. M. (August 1996). The pursuit of beauty through thinness and the impact of advertising on
college women's attitudes. In C. Smith (Chair), Empirical investigations of women's pursuit of beauty.
Symposium conducted at the National Meeting of the American Psychological Association, Toronto,
Canada.
Cogan, J. & Rocchio, L. M. (March 1995). Fat oppression and body hatred: Strategies for change. One-half
day training workshop presented at the National Meeting of the Association for Women in Psychology,
Indianapolis, IN.
3502-006
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Lisa Marie Rocchio, Ph.D. 7
Cogan, J. & Rocchio, L. M. (March 1994). Celebrating and redefining our diverse beauty: Rejecting body
hatred. Workshop presented at the National Meeting of the Association for Women in Psychology,
Oakland, CA.
Rocchio, L. M. (March 1993). Battered women who kill, psychology, and the law. Paper presented at the
National Meeting of the Association for Women in Psychology, Atlanta, GA.
Gregory, C.J., Minugh, P. A., Riedford, M., Rocchio, L. M., & Saris, R. (March 1993). Women Against
Sexual Harassment (WASH): Working to eliminate sexual harassment from the academic community.
Workshop presented at the National Meeting of the Association for Women in Psychology, Atlanta, GA.
Silver, B., Rocchio, L. M., & Gregory, C.J., (November 1992). A model for gender role assessment. Paper
presented at the meeting of the New England Psychological Association, Fairfield, CT.
Rocchio-Giordano, L. M. (February 1992). Moral reasoning related to gender and dilemma content. Paper
presented at the National Meeting of the Association for Women in Psychology, Long Beach, CA.
INVITED ADDRESSES
Rocchio, L.M. (January, 2021). Trauma psychology: What the trauma psychotherapist needs to know. Invited
presentation to the PGY 3 Residency Seminar at Brown Alpert School of Medicine. Providence, RI.
Rocchio, L.M. (March, 2016, 2017, 2018). Vicarious traumatization: The effect of trauma exposure on the
helping professional. Invited continuing education presentation to the New England Society for the
Treatment of Trauma and Dissociation workshop: Fundamentals of Complex Trauma and Dissociation,
Cambridge, MA.
Rocchio. & Mills, M.A.M. (May, 2017). The anxiety and obsessive compulsive disorders: Overview and
treatment strategies. Invited continuing education presentation to the members of the Behavioral
Health Pod of the Rhode Island Primary Care Physician's Corporation, Cranston, RI.
Hughes, D.M. & Rocchio, L.M. (August, 2016). Forensic work with trauma populations. Invited hospitality
suite presentation sponsored by Division 56 of the American Psychological Association. Presented at the
National Meeting of the American Psychological Association, Denver, CO.
Rocchio, L.M. (2016). Trauma psychology: What the therapist needs to know. Invited continuing education
presentation to the members of the Behavioral Health Pod of the Rhode Island Primary Care Physician's
Corporation, Cranston, RI
Rocchio, L.M. (2016, 2015, 2013, 2012, 2011, 2010, 2009, 2008). Ethical considerations in the practice of
clinical and forensic psychology: Business and forensic issues. Invited presentation to the participants
of the Fellows Ethics Workshop, Brown University, Providence, RI.
Rocchio, L.M. (2015, 2014). Ethical considerations in the practice of clinical and forensic psychology:
Multiple Relationships. Invited presentation to the participants of the Fellows Ethics Workshop, Brown
University, Providence, RI.
Brown, LS., Gold, S., & Rocchio, L.M. (August, 2014). The forensic assessment of trauma. Invited
hospitality suite presentation sponsored by Division 56 of the American Psychological Association.
Presented at the National Meeting of the American Psychological Association, Washington, DC
Brown, LS., Gold, S., & Rocchio, L.M. (August, 2013). The forensic assessment of trauma. Invited
hospitality suite presentation sponsored by Division 56 of the American Psychological Association.
3502-006
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Lisa Marie Rocchio, Ph.D. 8
Presented at the National Meeting of the American Psychological Association, Honolulu, HI.
Rocchio, L.M. (August 2011). Development of a successful independent group practice in psychology.
Hospitality suite conversation hour sponsored by Division 42 of the American Psychological Association.
Presented at the National Meeting of the American Psychological Association, Washington, D.C.
Rocchio, L.M. (April 2009). Practical, legal and ethical considerations in establishing an independent
practice in psychology. Invited salon presentation to Early Career Psychologists sponsored by the
Rhode Island Psychological Association, Providence, RI.
Rocchio, L.M. (April 1996). The pursuit of beauty through thinness and the impact of advertising on
college women's attitudes. Invited colloquium presented to the Providence College Department of
Psychology, Providence RI.
Rocchio, L.M., Gregory, C.J., & Minugh, P.A. (1993). Women Against Sexual Harassment (WASH):
Dealing with sexual harassment in the workplace. Invited presentation to the participants of the Feminist
Lecture Series, Butler Hospital, Providence, RI.
Rocchio, L.M. (April 1993). Women and weight. Panel discussion participant, Brown University,
Providence, RI.
Rocchio, L.M. (May 1991). Images of women in the media, the pursuit of beauty, and eating disorders.
Invited presentation to Psychology of Sexual Equality class, University of RI, Kingston, RI.
DISSERTATION AND THESIS
Rocchio, L. M. (1995). The pursuit of beauty through thinness and the impact of advertising on college
women's attitudes. Doctoral dissertation, University of RI, Kingston, RI.
Rocchio, L. M. (1993). Moral reasoning related to gender and dilemma content. Master's thesis, University
of RI, Kingston, RI.
PROFESSIONAL ACTIVITIES
American Psychological Association
2021 - present
Division 56 (Trauma Psychology) President-Elect
2020 present
APA Ethics Committee Member: Forensic Slate
2014 - present
Division 56 Journal, Trauma Psychology: Theory, Research, Practice and Policy,
Editorial Review Board Member
2019 - 2020
Division 56 Member at Large
2013 - 2019
Division 56 Treasurer
2009 - 2019
Division 56 Representative to the Committee on Women in Psychology (CWP)
2015 2016
APA Committee for State Leaders, Past-Chair
2014 - 2015
State Leadership Convention (SLC) 2020 Initiative Task Force, CSL
Representative
2013 - 2015
APA Committee for State Leaders, Chair
2012 2013
APA Committee for State Leaders, Member-at-large
2010 - 2013
Division 56 Membership Chair; Program Review Committee Member
1996 2000
Division 35 Student Research Prize Reviewer
1992 1995
Division 35 Student Committee Member
3502-006
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Lisa Marie Rocchio, Ph.D. 9
Association for Women in Psychology
2011, 1992 - 2000
Program Review Committee Member
1996 2000
Student Research Prize Review Committee Member
1999
Conference Planning Committee Member
1991 1995
Co-Coordinator, RI Chapter
1992 1995
Student Caucus Coordinator
Blue Cross Blue Shield of RI
2020 present
Grant Recipient for Behavioral Health Provider Quality Support
Grant Pilot Program
2015 present
Quality Measures Workgroup Member
Coalition of Mental Health Providers in RI
2004 - present
Founding Committee Member
Healthsource RI
2014 - 2015
Expert Advisory Panel, Member
New England Psychological Association
1995
Program Review Committee, Member
Rhode Island Primary Care Physicians Corporation Behavioral Health Network
2014 - present
Vision Committee Member
2013 - present
Communications Committee Member
Rhode Island Psychological Association
2020 - present
Social Justice Committee Member
2016 — present
APA Council Representative
2013 - present
Healthcare Task Force/Committee Member
2011 - present
Legislative Affairs Committee Member
1996 present
Ethics Committee Member
2015 2016
Secretary
2010 - 2014
Colleague Assistance Task Force/Committee Member
2014 2015
Past-President
2012 - 2014
President
2011 - 2012
President-Elect
2006 2008
Ethics Committee Chair
Rhode Island and Southeastern Massachusetts Trauma Study Group
2010 - 2016
Co-founder and member
3502-006
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Lisa Marie Rocchio, Ph.D. 10
PROFESSIONAL ADVOCACY
Congressional Visits
Visits organized by the American Psychological Association:
March, 2016
Medicare and Mental Health Reform. Senators Jack Reed and Sheldon Whitehouse
(Rhode Island)
March, 2016
Medicare and Mental Health Reform. Representatives David Cicilline and James
Langevin (Rhode Island)
March, 2015
Medicare. Senators Jack Reed and Sheldon Whitehouse (Rhode Island)
March, 2015
Medicare. Representatives David Cicilline and James Langevin (Rhode Island)
March, 2014
Medicare. Senators Jack Reed and Sheldon Whitehouse (Rhode Island)
March, 2014
Medicare. Representatives David Cicilline and James Langevin (Rhode Island)
Feb., 2012
Medicare and Healthcare Reform. Senators Jack Reed and Sheldon Whitehouse
(Rhode Island)
Feb., 2012
Medicare. Representatives David Cicilline and James Langevin (Rhode Island)
Rhode Island Legislative Advocacy
09/2013 — 02/ 2014
Special Joint Commission to Study the Integration of Primary Care and Behavioral
Health, Co-Chaired by Senator Joshua Miller and Representative David Bennett,
Commission Member.
2004 present
Advocacy regarding legislation:
The increased oversight of Blue Cross/Blue Shield of RI by the office of the Insurance
Commissioner. Changes to the RI licensing law for psychologists
The inclusion of psychologists in corporate practice of medicine legislation
Ensuring that psychologists' scope of practice was not restricted by the passage of
statutes related to the practice of applied behavioral analysis
Local mental health parity legislation
Marriage equality in the state of RI.
PROFESSIONAL AFFILIATIONS
American Psychological Association (APA), Fellow Divisions 42 and 56
3502-006
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Lisa Marie Rocchio, Ph.D. 11
American Psychological Association (APA), Member Divisions 12, 29, 31, 35, 41,
Association for Women in Psychology (AWP)
Eye Movement Desensitization and Reprocessing International Association (EMDRIA)
International Society for the Study of Trauma and Dissociation (ISSTD)
International Society for Traumatic Stress Studies (ISTSS)
Massachusetts Psychological Association
New England Society for the Treatment of Trauma and Dissociation (NESTTD)
Rhode Island Psychological Association (RIPA)
COMMUNITY ACTIVITIES
2019 - present
Governance Committee Member, Moses Brown School, Providence, RI
2011 - 2019
Nominating Committee Member, Moses Brown School, Providence, RI
2013 - 2017
Clerk, Nominating Committee, Moses Brown School, Providence, RI
2013 -2017
Executive Committee Member, Moses Brown School, Providence, RI
2011 - 2017
Board of Trustees, Moses Brown School, Providence RI
2008 - 2015
Trustee Committee Member, Moses Brown School, Providence, RI
2002 - 2006
Founding Director, Board of Directors, Quest Montessori School, Exeter.
3502-006
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