# docs_fts_content

c1: EFTA00030364
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030364.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:09:57 +0000
Inline-Images: image001.png
Thank you!!
From:
Sent: Thursday, July 02, 2020 14:09
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
UNITED QUI PRO DOMINA JUSTITIA OF SOFFICE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
EFTA00030364

=== Page 2 ===
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
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.
EFTA00030365

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00030366


c1: EFTA00030705
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030705.pdf
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
Subject: RE: Outstanding requests - update
Date: Mon, 09 Sep 2019 21:43:38 +0000
We had understood the signed post orders to be individually signed by each officer, but this may be it. We should have
confirm though.
From:
(USANYS) [Contractor]
Sent: Monday, September 9, 2019 5:26 PM
To:
(USANYS)
Subject: RE: Outstanding requests - update
I think the file "SHU Training 06-06-19 & Information" may be the post orders. It's too big to attached so I've sent the
folder path.
\\usa.doj.gov\cloud\nys\StAndrews\Shared\InReEpsteinDeath-2019R01059\Evidence\MCCRegs
From:
(USANYS)
Sent: Monday, September 9, 2019 5:07 PM
To:
(USANYS) [Contractor]
V.
(USANYS)
Subject: RE: Outstanding requests - update
Yes please, thank you.
From:
(USANYS) [Contractor]
Sent: Monday, September 9, 2019 5:05 PM
To:
(USANYS)
>;
(USANYS)
Subject: RE: Outstanding requests - update
Will do. Shall I also add other things that we are missing (prisoner remand forms, running boards, etc.)?
From:
(USANYS)
Sent: Monday, September 9, 2019 4:55 PM
To:
(USANYS) [Contractor]
i
(USANYS)
Subject: RE: Outstanding requests - update
Thanks for following up on this.
I did not see the signed SHU post orders. They should look like a series of rules and regulations for the post that are
signed by each officer. They are different from the daily rosters. And we should ask for the daily rosters for the time
period we are missing.
When you're ready, could you follow up with
(copying us) on the outstanding items? Thank you.
From:
(USANYS) [Contractor]
Sent: Monday, September 9, 2019 10:56 AM
EFTA00030705

=== Page 2 ===
To:
(USANYS)
is
(USANYS)
Subject: Outstanding requests - update
I'm working though the outstanding requests, specifically those that we sent
last week.
The
Commissary Reports are in the shared here:
\\usa.doj.gov\cloud\nys\StAndrews\Shared\InReEpsteinDeath-2019R01059\Evidence\Epstein General BOP Records
Additionally, the records for
and
(no
or
)
are here as well (in the same document).
However, all they entail is a single truview page and nothing else. The actual receipts are only for Epstein,
, and
Rugard.
What I'm not sure on is the signed SHU post order review sheets. I have looked through the files and can't seem to find
them anywhere. Albeit I don't know what they look like but I do think I would have recognized them. I will keep looking.
Lastly, are the post orders for SHU the same as the daily assignment roster? I've attached one of them as an example. If
so, we are missing several from the time period that we requested (7/1 - 8/10).
I'm going to continue to work through the spreadsheet as well.
Paralegal Specialist
U.S. Attorney's Office I
SDNY
1 St. Andrew's Plaza
New York, NY 10007
Office:
Cell:
EFTA00030706


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c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031194.pdf
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=== Page 1 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
Shift-Day-Date: M/W Saturday, August 10, 2019
Beginning Count: 758
SHU: 73/5
Daily Sensitive Information:
I/M Felix 85775-054 on Psych Obs. w/inmate companion
M/W
I/M Williams #78640-054 on Psych Obs. w/inmate companion
I/M Gentile #71230-054 on Psych Obs. w/inmate companion
I/M Ramos #85428-054 Psych Obs. w/inmate companion
I/M Fernandez #86824-054 on Dry Cell w/inst. Staff (R-A)
TIME
CHRONOLOGICAL EVENTS
BC
SHU
12:00 AM
Lieutenant
assumes duties as the Morning Watch
758
73/5
Operations Lieutenant. The fire alarm and sprinkler system are
operational w/exception of Control Center Fire Panel. PREA
announcement conducted via the Institution Public Address System
and/or Radio. Restraint Equipment Cage inventory conducted. All
equipment accounted for. Metal Detector checks conducted. All
operative w/the exception of Rear Gate/Facilities/R&D. Roof Check
completed. All secure. Temporary Chit Inventory: #1:2; #2:5; #3:5;
#4:6; #5:5; #6:0; Hosp:0
12:00 AM
Institution Count in progress
12:00 AM
NYPD Phone Check #1283
12:15 AM
Body Alarm testing in progress
12:23 AM
Body Alarm testing completed
12:30 AM
Watch Calls cont.
12:35 AM
-1 SHU (correction) Fernandez #86824-054 (DRY CELL R-A)
72/5
12:36 AM
Good Verbal count announced
12:49 AM
Clear Institution count announced
758
72/5
3:00 AM
Institution Count in progress
3:19 AM
Good Verbal count announced
3:24 AM
Clear Institution count announced
758
72/5
5:00 AM
Institution Count in progress
5:29 AM
Good Verbal count announced
5:30 AM
Clear Institution count announced
758
72/5
Lieutenant
on Board at approximately 5:30am relieving Lt
of duty.
6:33 AM
Medical emergency announced for Unit 9 South inmate Epstein
#76318-054 found unresponsive in cell 206-220 CPR in progress
6:35 AM
911 Emergency service notified
6:43 AM
E.M.S ambulance arrives to the Health Service Area, continued CPR
in progress by E.M.T.
7:10 AM
E.M.S/BOP staff depart with inmate Epstein #76318-054 via
757
71/5
ambulance to local hospital continuation of CPR is still in
progress by EMT.
7:36 AM
Bop staff called to notify institution that inmate Epstein #
STG International Terrorist phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty:
The following Inmate (s) were placed in Administrative Detention:
Name
Reg: Number
Reason
Unit
Time
AD Order
EFTA00031194

=== Page 2 ===
UN
IT
ED
ST
AT
ES
DE
PA
RT
ME
NT
OF
JU
ST
IC
E
ME
TR
OP
OL
IT
AN
CO
RR
EC
TI
ON
AL
CE
NT
ER
Ending Count: 758 SHU: 71; 10-South: 05; SHU OBS: 00;
Ops Lt.
Local Hosp: 00; H/A OBS: 04; B/A OBS: 00; Dry Cell: 01;
H/A (PBS); 00; H/A (PCLAS); 00
SHIFT-DAY-DATE: D/W - Friday, August 09, 2019
Beginning Count: 757
SHU: 71/5
D/W
Daily Sensitive Information:
INSTITUTION ON MODIFIED OPERATIONS
I/M Gentile #71230-054 on Psych obs w/inmate companion
I/M Ramos #85428-054 on Psych obs. w/inmate companion.
I/M Fernandez # 86824-054 on DRY Cell w/staff watch in R&D.
8:00 AM
Lieutenant
assumes duties as the Day Watch Operations
757
71/5
Lieutenant. The fire alarm and pump system is inoperable at this
time. Fire Watch is in Progress. Unable to conduct PREA
announcement over the Institution Public Address System, due to,
system malfunction. Restraint Equipment Cage inventory conducted.
All equipment accounted for. Metal Detector checks conducted. All
operative w/the exception of Rear Gate. Roof Check completed.
All secure. Temporary Chit Inventory: #1:0; #2:5; #3:5; #4:6;
#5:6; #6:5; Hosp:0
Daily Hand Stamp :DJBE/LEFT HAND
8:00 AM
NYPD Phone Check #3371
8:00 AM
Body Alarm Test Initiated.
8:20 AM
Body Alarm Testing Complete.
10:00 AM
Institutional count in progress
757
71/5
11:22 AM
Good verbal count announced
EFTA00031195

=== Page 3 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
11:24 AM
Clear institutional count
757
71/5
3:45 PM
Institutional lockdown for count.
3:57 PM
+1; I/M Mutimura #76329-054
757
71/5
3:58 PM
I/M Fernandez #86824-054 transferred to special housing (dry cell)
757
72/5
3:59 PM
-1 Bail Bond; Carreon-Macias #82858-198
756
72/5
4:00 PM
Relieved of duties by Lt. M. Cannata E/W Operations Lieutenant.
Visitation: CANCELLED
Inmates
Adults
Children
Total
ION SCANNING TESTED HITS: 0
STG/High Alert phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
Name
Reg Number
Reason
Unit
TIME
A/D Order
Ops Lt
Ending Count: 756 ; SHU:72 ; 10-South: 05; SHU OBS: 00;
Act Lt
Local Hosp: 00; H/A OBS: 02; B/A OBS: 00; Dry Cell: 00
EFTA00031196

=== Page 4 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHIFT-DAY-DATE: E/W Saturday, August 10, 2019
Beginning Count: 756
SHU: 72/5
Daily Sensitive Information.
INSTITUTION ON MODIFIED OPERATIONS
E/W
I/M Gentile #71230-054 on Psych Obs w/inmate companion.
I/M Ramos #85428-054 on PSYCH OBS. W/inmate companion.
I/M Felix #85775-054 on Suicide watch w/inmate companion.
I/M Wiliams #78640-054 on suicide watch w/ inmate companion.
TIME
CHRONOLOGICAL EVENTS
B/C
SHU
Lieutenant D. Medina assumes duties as the Evening Watch Operations
Lieutenant. Unable to conduct PREA announcement over the
Institution Public Address System, due to, system malfunction.
4:00 PM
Restraint Equipment Cage inventory conducted. All equipment
756
72/5
accounted for. Metal Detector checks conducted. All operative
w/the exception of Rear Gate. Roof Check completed. All secure.
Temporary Chit Inventory: #1:4; #2:4; #3:5; #4:5; #5:5; #6:3;
4:00 PM
Institution count in progress.
4:01 PM
NYPD Phone Check #1980
4:16 PM
Body alarm testing in progress.
4:32 PM
Body alarm testing completed
5:02 PM
Good verbal count
5:13 PM
Clear institutional count.
756
72/5
6:00 PM
Watch call in progress
7:24 PM
I/M Williams #78640-054 and Felix #85775-054 transferred to special
756
74/5
housing (psych observation)
7:45 PM
Trash run in progress
8:42 PM
Trash run complete
10:00 PM
Institutional count in progress.
10:21 PM
Good verbal count announced.
10:38 PM
Clear institutional count announced.
756
74/5
12:00 AM
Relieved of duties by
as the M/W Lieutenant.
VISITING:
INMATES
ADULTS
CHILDREN
TOTAL
STG/High Alert phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
NAME
REG NUMBER
REASON
UNIT
TIME
A/D ORDER
Ops. Lt. D. Medina
Ending Count: 756 ; SHU: 74; 10-South: 05; SHU OBS: 00;
Act. Lt.
Local Hosp: 00; H/A OBS: 02; B/A OBS: 00; Dry Cell: 00;
B/A SHU: 00
EFTA00031197


c1: EFTA00031633
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031633.pdf
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=== Page 1 ===
From:
"
(NY) (FBI)"
To:
(NY) (OGA)"
(OIG)"
(NY) (FBI)"
(OIG)"
(USANYS)"
Cc:
(USANYS)"
Subject: RE: MCC NY Epstein Investigation
Date: Wed, 18 Sep 2019 13:52:14 +0000
On Sep 18, 2019 9:44 AM,
(USANYS)"
wrote:
All,
From:
Sent: Monday, August 19, 2019 11:34 AM
To:
(USANYS)
i
(USANYS)
>;
(OIG)
>;
(NY) (FBI)
>;
(NY) (OGA) (FBI)
is
(NY) (FBI)
Subject: FW: MCC NY Epstein Investigation
Fyi
From:
Sent: Monday, August 19, 2019 11:09 AM
To:
Subject: MCC NY Epstein Investigation
I work at MCC NY. I was working the rear gate area when the gate pass inmate named
brought
back to the gate bays of shredded papers to throw out into the dumpster on Thursday and one bag on Friday. He stated
that members of the BOP after action team that were investigating what happened with the Epstein suicide were
shredding boxes of paperwork. He stated, "they are shredding everything". He stated that he even was told to help them
shred paperwork too. I believe that this conduct maybe inappropriate for a investigative team to be shredding
paperwork related to the investigation and you may want to investigate why BOP employees were destroying records.
EFTA00031633


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=== Page 1 ===
From:
)"
To:
Cc:
Subject: Mark Epstein
Date: Thu, 24 Oct 2019 14:55:48 +0000
We are confirmed for a meeting at 3:00 p.m. on Monday at 1 St. Andrews Plaza. See you then. Thanks.
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00030073


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=== Page 1 ===
From
To
Subject: RE: United States V. Ghislaine Maxwell -
Date: Sun, 28 Nov 2021 17:43:25 +0000
Thanks so much
Really appreciate it.
From
Sent: Sunday, November 28, 2021 12:16 PM
To:
Subject: RE: United States V. Ghislaine Maxwell
Makes sense! Hope you are doing well
you are such an inspiration and these victims are so fortunate to have you
as their advocate.
From:
Sent: Sunday, November 28, 2021 12:11 PM
To:
Subject: Re: United States V. Ghislaine Maxwell
No, fortunately
On Nov 28, 2021, at 10:37 AM
wrote:
Is there going to be a dial in?
From:
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>; USANYS-CRIMINAL PARALEGALS <USANYS-
CRIMINALPARALEGALS@usa.doj.gov>; USANYS-INVESTIGATORS <USANYS-INVESTIGATORS@usa.doj.gov>
Cc:
Subject: United States V. Ghislaine Maxwell --
opens
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors
will do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine
Maxwell sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her
accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
EFTA00031252

=== Page 2 ===
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00031253


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=== Page 1 ===
From:
"
To:
Subject: 19-2221 United States of America V. Epstein "FRAP 42 with Prejudice FILED"
Date: Wed, 21 Aug 2019 14:07:33 +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 08/21/2019
Case Name:
United States of America V. Epstein
Case Number: 19-2221
Document(s): Document(s)
Docket Text:
FRAP 42 STIPULATION, with prejudice, FILED.[2637827] [19-2221]
Notice will be electronically mailed to:
Ms.
, Assistant U.S. Attorney:
Assistant U.S. Attorney:
Martin G. Weinberg, -
Reid Weingarten, -:
,
The following document(s) are associated with this transaction:
Document Description: Order_stipulation
Original Filename:/opt/ACECF/live/forms/MargaretLain_192221_2637827_Order_stipulation_293.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=08/21/2019] [FileNumber=2637827-0]
[18bed1551fae4b1760126e33d4cea61ffdf7f7412298ae77040d85cca9fbfaa7d77b25eb42acbf03aee51d4cc9e11a5
e79a1005016ac49d3b218d6caa20f5e4a]]
Recipients:
Assistant U.S. Attorney
Assistant U.S. Attorney
Martin G. Weinberg, -
Reid Weingarten, -
EFTA00031717


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=== Page 1 ===
From:
"
(USANYS)"
To:
"
)"
Subject: RE: RE: Epstein investigation, prosecution memo
Date: Thu, 20 Jun 2019 17:26:08 +0000
Importance: Normal
Thanks. Much appreciated.
EFTA00030157

=== Page 2 ===
EFTA00030158


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=== Page 1 ===
From:
To:
Subject
has invited you to work together in "Epstein Death" folder on Box
Date: Thu, 31 Oct 2019 05:46:14 +0000
wants to work with you on Epstein Death
Eps
tein
Epstein Death
"I'd like to share my files with you on Box."
Go to Folder
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© 2019 I 900 Jefferson Avenue, Redwood City, CA 94063, USA
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This is an official notification from the USAfx File Exchange system.
EFTA00031400


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=== Page 1 ===
From:
<
To:
>,
Cc:
Subject: Re: Fwd: Letter regarding jail conditions and court appearance
Date: Sat, 22 Aug 2020 00:42:01 +0000
Hi
can give you a call early tomorrow. How early is okay?
>>>
(USANYS)"
> 8/21/2020 3:52 PM >>>
Adding in
since not sure if he's still helping with the COVID stuff at MCC and this is arguably COVID related. My cell is
and I can talk anytime today or over weekend so we can respond to Judge Karas on Monday as ordered.
Thanks.
Co-Chief, Narcotics Unit
O:
U
Begin forwarded message:
From:
(USANYS)"
>
Date: August 21, 2020 at 13:25:00 EDT
To:
>
Cc:
)"
>
Subject: FW: Letter regarding jail conditions and court appearance
- Can we please jump on a call this afternoon to discuss? As you can see, we have only until Monday to respond.
Co-Chief, Narcotics Unit
O:
C:
From: Karas NYSD Chambers
Sent: Friday, August 21, 2020 1:22 PM
To: Bruce Barket
Cc: Aida Leisenring
is
is
>; Michael Bachrach
is
>; John Diaz
is
is
is
(USANYS)
is
(USANYS)
is
>;
(USANYS)
Subject: Re: Letter regarding jail conditions and court appearance
All,
Attached please find a memo endorsement from Judge Karas.
-Chambers of Judge Karas
EFTA00030995

=== Page 2 ===
From: Bruce Barket
Sent: Thursday, August 20, 2020 6:24 PM
To: Karas NYSD Chambers
Subject: FW: Letter regarding jail conditions and court appearance
Good afternoon,
I sent this to
but wanted to forward here as well. Can you confirm that the judge will see it?
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
From: Bruce Barket
Sent: Thursday, August 20, 2020 12:50 PM
To:
Cc: Aida Leisenring
>; tonyricco
is
>; Michael Bachrach
Kenneth J. Montgomery Esq
>; 'john diaz
(
)'
is
i
is
is
(USANYS)
is
is
(USANYS)
(
)'
Subject: Letter regarding jail conditions and court appearance
I hope all is well. Can you please bring this letter to the attention of the judge? Note that I copied the lawyer for the MCC
and the prosecution team as well as firewall counsel. Thank you.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
EFTA00030996


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=== Page 1 ===
From:
)"
To:
Subject: RE: epstein
Date: Tue, 09 Jul 2019 16:53:31 +0000
Importance: Normal
That's a good article - thanks for sending along.
From:
Sent: Tuesday, July 09, 2019 10:10
To:
Subject: RE: epstein
https://www.thedailybeast.com/jeffrey-epstein-shouldnt-expect-to-wiggle-free-again-with-sdny-sex-trafficking-charges
From:
Sent: Tuesday, July 9, 2019 9:43 AM
To:
Subject: Fwd: epstein
The other one was from the second conference; this is from the first one
Sent from my iPhone
Begin forwarded message:
From: Goretti Moya <gmoya@sdreporters.com>
Date: July 8, 2019 at 17:12:36 EDT
To:
=
=
>,
>, "
Subject: epstein
Please e-mail when youg et this
EFTA00030186


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
Subject: FW: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Tue, 16 Mar 2021 22:40:38 +0000
Attachments: 2021.03.16_Maxwell_Discovery_Leter.pdf;
SDNY_GM_02743101_[CONFIDENTIAL].xlsx;
SDNY_GM_02743102_[CONFIDENTIAL].xlsx
Inline-Images: image001.jpg
FYI
From:
Sent: Tuesday, March 16, 2021 6:40 PM
To: 'Laura Menninger' <lmenninger@hmflaw.com>;
is
(USANYS)
Cc: 'Jeff Pagliuca' <jpagliuca@hmflaw.com>; 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding
discovery cover letter. We are sending a copy of these files to the MDC for your client as well.
In response to your questions, the FBI has informed me of the following:
Regarding the Highly Confidential nude/partially nudge images to be reviewed at 500 Pearl:
There are three categories of these images:
Approximately 2,100 electronic images and videos seized from Epstein's electronic devices (which have not
been previously provided to you)
Approximately 3,400 electronic images from discs seized from Epstein's residences in 2019 (which have
previously been provided to you and your client for review at the MDC)
Approximately 7 hard copy nude images located in the file from the FBI Florida office's investigation of
Epstein (which have not been previously provided to you)
The FBI will make all three of those categories available to you. The electronic files will be provided on hard drives,
and the FBI will provide you with the hard copy images for review as well.
All electronic images should be viewable as thumbnails, except those seized from Apple devices, which must
be viewed using Cellebrite.
The Cellebrite software will be provided on the drive for your review of images and videos seized from Apple
devices.
The electronic files have the same metadata on the hard drive that was available when the FBI seized each
image. For images that were carved or deleted, no metadata was recovered, so none is viewable. For all
other images, the metadata recovered should be viewable on the hard drive.
The approximately 2,100 electronic images and videos seized from Epstein's devices are separated by folder
to indicate which device each image was seized from.
EFTA00031589

=== Page 2 ===
Because these images are considered obscene material, the FBI is not permitted to make duplicates of them, and
there is a limited number of clean laptops on which these images can be reviewed. As a result, the FBI is only able
to provide a single laptop for review of these images.
Regarding the physical evidence:
Attached are two lists of all physical items in the FBI's custody relating to this case. The first list relates to items
associated with the FBI Florida office's investigation of Epstein. The second list relates to items associated with the
FBI New York office's current investigation.
The vast majority of physical evidence in the FBI's custody is located at the FBI's warehouse in the Bronx. Two
items (1B 77 & 1B 79) are located at 26 Federal Plaza, but the case agents can check those items out from 26
Federal Plaza and bring them to the Bronx warehouse on whatever day you choose to conduct your review so that
you will have all evidence in one place.
The FBI is able to arrange for the defense team to review all physical evidence at the Bronx warehouse under the
following conditions:
The warehouse requires at least two weeks' notice in order to pull all of the items for the entire case and
place them in a location where a large group of people can view them.
The warehouse is open during normal business hours between 9am and 5pm on weekdays.
At least two FBI agents and an AUSA will be present at the Bronx warehouse to assist and answer questions.
The evidence will be placed in a loading dock at the warehouse to provide additional space for the review.
To ensure that there is sufficient space, please let me know how many members of the defense team intend
to be physically present for this review.
Electronic devices such as cellphones and laptops are not permitted in the warehouse. The defense team
may bring a digital camera that is not connected to the Internet or a cellular network into the warehouse. If
the defense team wishes to photograph an item of evidence, the defense will need to inform the agents who
are present, so that they may confirm that the photographed item is not Highly Confidential based on the
presence of nudity.
Electronic media such as VHS tapes, cassette tapes, and CDs will not be playable at the warehouse.
To the extent the defense requests that the FBI bring any physical items to 500 Pearl Street for your client to review,
the FBI is prepared to bring items that are reasonably sized to 500 Pearl Street. With respect to bulky or large
items, the defense team should be able to photograph those for your client to review, unless they are deemed
Highly Confidential, in which case the FBI can make arrangements to transport the item to 500 Pearl Street if
necessary.
The FBI is in the process of confirming that it can provide devices to play all of the electronic media in the case in a
single location at the FBI's offices in downtown Manhattan. We are also double-checking to confirm that all media
that does not contain witness statements have already been produced to you and your client in discovery. The FBI
anticipates that we can arrange for you to review all non-witness statement electronic media at the FBI's office in
downtown Manhattan in approximately three weeks.
To the extent you wish to review all of the discs containing photographs, which were seized from Epstein's
residences in 2019, we note that all of those images have already been produced to you in discovery. For
your awareness, the FBI has informed me that it took their team several weeks to review all of the images on
all of those discs.
Please let me know how you wish to proceed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00031590

=== Page 3 ===
From:
Sent: Monday, March 15, 2021 6:00 PM
To: 'Laura Menninger' <lmenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
I expect to be able to answer all of your questions about the evidence review by tomorrow.
We have been looking into the discovery request you made last week, and we hope to have a response ready to provide
to you by next week.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 15, 2021 3:01 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of
when you would have answers, it could help me answer your question.
At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the
attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their
evidence when they seized it from NY and LSJ, so I don't think we need to wait for them to now prepare an inventory
before we start reviewing evidence.
Also, when do you believe you will have a response regarding the discovery I requested last Monday?
Thanks,
Laura
EFTA00031591

=== Page 4 ===
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
EFTA00031592

=== Page 5 ===
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 3:44 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you. Is that the only index of physical evidence available?
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
i
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
EFTA00031593

=== Page 6 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
-
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
Code:
Best,
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
)
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
i
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
EFTA00031594

=== Page 7 ===
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00031595

=== Page 8 ===
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=== Page 1 ===
From:
)"
To:
Cc:
,
)"
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Maxwell drive delivery Monday 1/11
Date: Tue, 12 Jan 2021 19:10:24 +0000
Embedded:RE:_Maxwell_drive_delivery_Monday_1_11.msg
Sender:
Subject: RE: Maxwell drive delivery Monday 1/11
Message-Id:
<BN3P110MB0339CAEFE636A329E8949BBF92AA0@BN3P110MB0339.NAMP110.PROD.OUTLOOK.CO
M>
Cc:
EFTA00031710


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=== Page 1 ===
From:
Subject: updated draft
Date: Thu, 11 Jul 2019 15:23:03 +0000
Importance: Normal
Attachments: SW_draft_for_agent_review.docx
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=== Page 1 ===
From:
Bcc:
Subject: RE: Expert Testimony
Date: Wed, 04 Nov 2020 22:56:03 +0000
Embedded: RE:_Expert_Testimony.msg
Sender:
Subject: RE: Expert Testimony
Message-Id:
M>
Cc:
Cc:
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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
January 10, 2021
By Electronic Mail
Christian Everdell, Esq.
Bobbi Sternheim, Esq.
Mark Cohen, Esq.
Law Offices of Bobbi C. Sternheim
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Re:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
We write in response to your letter of December 28, 2020, in which you request a bill of
particulars in the above-captioned matter. As set forth herein, the Government does not intend to
provide further particulars because under the well-established law of this Circuit it has no
obligation to do so. To the contrary, and as you are aware, the Government outlined its charges
against your client in a detailed speaking superseding indictment (the "Indictment") and has since
provided considerable additional information through the production of to date of over 2.7 million
items of discovery, all in electronic form and accompanied by an index. Accordingly, the
Government has more than provided the defendant with adequate notice of the charges against her,
and no further particulars are required.
"A bill of particulars is required only where the charges of the indictment are so general
that they do not advise the defendant of the specific acts of which he is accused." United States V.
Walsh, 194 F.3d 37, 47 (2d Cir. 1999) (quotations marks and citation omitted); see also, e.g.,
United States V. Mahabub, No. 13 Cr. 908 (AJN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug. 26,
2014) (same); United States V. Mandell, 710 F. Supp. 2d 368, 384 (S.D.N.Y. 2010) (same).
"Acquisition of evidentiary details is not the function of the bill of particulars." United States V.
Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States V. Marcus,
628 F.3d 36, 41 (2d Cir. 2010) (quotations marks and citation omitted).
EFTA00030943

=== Page 2 ===
Nor may a bill of particulars be used as a general investigative tool. "It is not enough that
the information would be useful to the defendant; if the defendant has been given adequate notice
of the charges against him, the government is not required to disclose additional details about its
case." United States V. Payden, 613 F. Supp. 800, 816 (S.D.N.Y. 1985); see also, e.g., United
States V. Sindone, No. 01 Cr. 517 (MBM), 2002 WL 48604, at *1 (S.D.N.Y. Jan. 14, 2002) (a
defendant may not "use a bill of particulars to preview the government's evidence or trial strategy,
or to require the government to specify the minutiae of how it will prove the charges. The stakes
in a criminal case are high, and temptations of perjury, subornation and intimidation are ever
present. Accordingly, the government is not required to turn over information that will permit a
defendant to preview the government's case and tempt him to tailor proof to explain it away, or
see to it that the government's proof is not presented." (citations omitted)); United States V.
Guerrerio, 670 F. Supp. 1215, 1225 (S.D.N.Y. 1987) (A bill of particulars "is not a discovery tool
and is not intended to allow defendants a preview of the evidence or the theory of the government's
case.").
A bill of particulars is unwarranted in this case because the Government has more than
satisfied its obligations to provide the defense with sufficient information to "prepare for trial, to
prevent surprise, and to interpose a plea of double jeopardy should [the defendant] be prosecuted
a second time for the same offense." United States V. Bortnovsky, 820 F.2d 572, 574 (2d Cir.
1987). The Indictment contains a written statement of the essential facts constituting the offenses
charged, and it describes the conduct of the defendant that the Government expects to prove at trial
with respect to three particular victims. The Indictment itself contains a detailed description of the
accounts these victims have provided law enforcement. In addition to the Indictment, which
provides more than sufficient information about the charges against your client, you are also in
possession of, among other things, numerous search warrant affidavits that outline evidence
revealed during the Government's investigation over time (see, e.g., SDNY_GM_00000423-
SDNY_GM_00000524); documentary evidence, including travel records and contemporaneous
journal entries that corroborate the victims' accounts; and the Government's letters concerning
bail and detention. In sum, the Indictment and the materials produced during discovery provide
you with more than ample information concerning the allegations that the Government intends to
prove at trial and the supporting evidence. See, e.g., United States V. Reinhold, 994 F. Supp. 194,
201 (S.D.N.Y. 1998) (denying request for bill of particulars where the "indictment is detailed in
its allegations" and the "defendants have had extensive discovery").
To the extent that your requests seek information regarding potential witnesses and/or co-
conspirators or aiders and abettors (Requests 1-20, 22-26), the Government is not required to
provide such information at this time. See, e.g., United States V. 'Amico, 734 F. Supp. 2d 321,
335 (S.D.N.Y. 2010) ("A bill of particulars is not a general investigative tool, a discovery device
or a means to compel the government to disclose evidence or witnesses to be offered prior to trial."
(quoting United States V. Gibson, 175 F. Supp. 2d 532, 537 (S.D.N.Y. 2001))); United States V.
Barrera, 950 F. Supp. 2d 461, 478-79 (E.D.N.Y. 2013) (denying motion for bill of particulars as
to identities of unnamed victims of alleged murder conspiracy); United States V. Castro, No. 08
Cr. 268 (NRB), 2008 WL 5062724, at *2 (S.D.N.Y. Nov. 25, 2008) ("An indictment need not
identify all alleged co-conspirators, nor specify the nature, time and place of every overt act the
defendant or others allegedly took in furtherance of a conspiracy, nor must it set forth all the
evidence the government intends to introduce."); United States V. Sindone, 2002 WL 48604, at
2
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(denying request for bill of particulars that would identify alleged co-conspirators and victims);
United States V. Trippe, 171 F. Supp. 2d 230, 240 (S.D.N.Y. 2001) ("[D]emands for particular
information with respect to where, when, and with whom the Government will charge the
defendant with conspiring are routinely denied."); United States V. Mitlof, 165 F. Supp. 2d 558,
569 (S.D.N.Y. 2001) ("What defendant seeks is in the nature of the "wheres, whens and with
whoms' that [c]ourts have held to be beyond the scope of a bill of particulars." (collecting cases));
United States V. Fruchter, 104 F. Supp. 2d 289, 313 (S.D.N.Y. 2000) (denying "Defendants'
request for names of all aiders, abettors, unindicted co-conspirators, and confidential informants"
as "nothing more than a request for a witness list"); see also Fed. R. Crim. P. 16. As previously
stated, and as noted in the Government's letter dated October 28, 2020, with regard to your many
requests for information that fall within the scope of the Government's Giglio and Jencks Act
obligations, we intend to produce all such material in advance of trial and remain available to
confer generally regarding a mutual schedule for pretrial and trial-related disclosures, including
witness statements or Giglio material.
You seek numerous, specific details which amount to requests for a detailed preview of the
Government's case and its legal theories (Requests 7, 14, 19, 25, and 29). The Government is not
required to disclose at this juncture the way in which it expects to prove the charges or the precise
manner in which the defendant committed the charged crimes, nor must the Government provide
a preview of the evidence or legal theories it intends to present at trial. See, e.g., United States V.
Dupigny, 18 Cr. 528 (JMF), 2019 WL 2327697, at *2 (S.D.N.Y. May 30, 2019) (denying motion
for bill of particulars and explaining that the defendant "need not be informed of the specific means
of coercion he is alleged to have employed against the still-unidentified victims in the Superseding
Indictment. And between the indictment, applications for search warrants, court filings, and
proffers during bail hearings, the Government has advised Dupigny of the nature and timeframe
of the conspiracy; the number of victims involved in the substantive trafficking offenses, the ages
of several of the victims, and the residence from which he recruited them; and the types of physical
force and coercion he has employed against at least some of them"); United States V. Pierre-Louis,
16 Cr. 541 (CM), 2018 WL 4043140, at *7 (S.D.N.Y. Aug. 9, 2018) ("Defendant's demand that
the Government provide him with the specifics of how it will prove the 'interstate transportation'
element of its case is an improper attempt to limit the Government's proof at trial and is the type
of 'when, where, and how' bill of particular requests that are "almost uniformly
denied."
(citation omitted)); United States V. Monzon-Luna, No. 11 Cr. 722 (RRM), 2014 WL 223100, at
*4 (E.D.N.Y. Jan. 21, 2014) (denying request for bill of particulars where defendant was charged
with, among other things, sex trafficking of minors and a Mann Act violation, and stating that the
indictment "explains the essential facts constituting each of the crimes charge[d], the time frame
in which the crime is alleged to have occurred, and the victim involved. This information is
sufficient to apprise defendant of the charges against him."). For example, with respect to Requests
7, 14, 19, and 25, the Government directs your attention to the Indictment, at paragraphs 11(b), 13,
17(b), and 19, which refer to sex acts in violation of New York Penal Law, Section 130.55. With
respect to Request 28, the Government refers you to the Indictment, at paragraph 7, which
describes the conduct of the defendant that the Government expects to prove at trial with respect
to three particular victims. Based on the foregoing, you are not entitled to the particulars sought
through your requests, and in any event, much of what you seek is described in the Indictment and
discovery. If you have authority for your requests, we would be happy to consider it.
3
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Please let us know if you have any questions or would like to discuss the foregoing.
Very truly yours,
Acting United States Attorney for the
Southern District of New York
By:
s/
Assistant United States Attorneys
4
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
July 12, 2019
VIA ECF
The Honorable Richard M. Berman
United States District Court
Southern District of New York
United States Courthouse
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Berman:
The Government respectfully submits this letter in response to the defendant's Motion for
Pretrial Release (the "Release Motion"), dated July 11, 2019 (Dkt. 6), and in further support of its
Memorandum in Support of Detention (the "Detention Memo"), submitted to Magistrate Judge
Pitman on July 8, 2019, which is attached hereto and incorporated herein (Ex. A).
Simply put, the Release Motion misconstrues and misunderstands the relevant law, belittles
and smears the many dozens of victims of the defendant's appalling sexual abuse, and utterly fails
to meet its burden of rebutting the presumption that no condition or combination of conditions will
reasonably assure the appearance of the defendant as required and the safety of the community.
Rather than even attempting to address the grave risks of releasing a defendant with extraordinary
financial resources, the defendant instead proposes a bail package that is effectively an unsecured
bond masquerading as a 14-point plan. The Court should reject the defendant's application and
order him detained pending trial.
PRELIMINARY STATEMENT
The defendant is a serial sexual predator who is charged with abusing underage girls for
years. A grand jury has returned an indictment against him setting forth allegations that he abused
dozens of minors, including girls as young as 14 years old, in multiple states. To this day, he is
designated by New York State in the highest category of risk to reoffend, despite his attempts to
lower that classification. And any doubt that he is unrepentant and unreformed was eliminated
when law enforcement agents discovered a trove of nude images of young girls in his Manhattan
mansion on the night of his arrest, more than a decade after he was first convicted of a sex crime
involving a juvenile.
The defendant faces substantial evidence of guilt founded on the corroborated testimony
of numerous victims, and this case presents the very real possibility that he will be go to prison for
the rest of his natural life. He has at his disposal a vast fortune, nearly all of which remains
EFTA00030247

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Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 2
concealed or obscured from the Court and the Government. The defendant also has a history of
obstruction and manipulation of witnesses, including as recently as when his offenses reemerged
in the media mere months ago. And he continues to show a shocking lack of understanding of the
gravity of the harm he has perpetrated, including through the minimization of his conduct and
casual disparagement of victims in his arguments.
Against this backdrop of significant-and fast-growing-evidence, serious charges, and
the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions that
are preposterously inadequate. While there are no conditions of bail that would reasonably assure
the defendant's presence in court proceedings or protect the safety of the community, as further
explained below, the defendant's proposal here is not a serious one. The defendant's Release
Motion sets forth a woefully inadequate bail package that, among other things, offers to pledge as
the only security against at least hundreds of millions of net worth a single property that has already
been designated by the Government for forfeiture and is therefore of no value whatsoever as
collateral. His proposed global waiver of extradition is unenforceable, and even if enforceable
would be little comfort to victims forced to wait additional months or years while the defendant is
located and returned to this country. The promise to "deregister or otherwise ground" his private
jet is meaningless given his wealth and ability to secure other means of travel, and the two
co-signers he proposes only reinforce his minimal community ties. Electronic monitoring would
merely give the defendant less of a head start in fleeing. And the private security force he proposes
to guard his gilded cage, a proposal already rejected by this Court in similar circumstances, simply
reinforced the obvious fact that the defendant should be housed where he can be secured at all
times: a federal correction center.
The defendant faces a presumption of detention, Pretrial Services has recommended
detention, and victims of the defendant seek his detention. The Court should order him detained.
BACKGROUND
A. Overview and Offense Conduct
As previously set forth, a federal grand jury in this District returned an indictment (the
"Indictment") charging the defendant with violating Title 18, United States Code Section 1519,
and conspiracy to commit the same. The defendant argues that the Government "labels this a 'Sex
Trafficking' case," as if the Government invented the term just for this defendant. Release Motion
at 2. In fact, the title of the statute for which a grand jury has found probable cause to believe the
defendant violated is: "Sex Trafficking of Children." 18 U.S.C. § 1591.
As charged by the grand jury, the facts giving rise to those charges involve a years-long
scheme to sexually abuse underage girls. Specifically, the defendant enticed and recruited dozens
of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in
cash, in at least two different states. Victims were initially recruited to provide "massages" to the
defendant, which would be performed nude or partially nude, would become increasingly sexual
in nature, and would typically include one or more sex acts, including groping and direct or indirect
contact with victims' genitals. To perpetuate this exploitation of underage girls, the defendant
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Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 3
actively encouraged certain victims to recruit additional girls to be similarly sexually abused. He
paid these victim-recruiters hundreds of dollars for each additional girl they brought to him,
creating a vast network of underage victims for him to exploit in New York and Palm Beach.
The defendant keeps making clear the he does not understand the gravity of the offenses
with which he is charged, including his claim that he has "no criminal history"-other than a
conviction for engaging in sexual conduct with a minor, precisely the same kind of conduct alleged
here. And following that conviction, as described previously by the Government, the defendant
continued to maintain a vast trove of hundreds or thousands of nude photos of young subjects. The
defendant's victims in this case, often particularly vulnerable girls, were as young as 14 years old
when he abused them. The defendant knew he was abusing minors, including because victims told
him directly they were underage. And he abused these victims repeatedly-day after day, month
after month, year after year.
The defense calls these appalling acts "simple prostitution."¹ Mag. Tr. 12:12; see also
D. Tr. at 6:15-19 ("This is basically the Feds today
redoing the same conduct that was
investigated 10 years ago and calling it, instead of prostitution, calling it sex trafficking"). That
offensive and horrible labeling of underage girls as prostitutes is unrecognized in federal law,
which criminalizes commercial sex acts with minors irrespective of the presence or absence of
force, fraud, or coercion. Defense counsel has already argued repeatedly that the Government's
case is infirm because no threats or coercion is alleged. Mag. Tr. at 12 ("There was no coercion.
There were no threats. There was no violence."), 17 ("there was no coercion. There was no
intimidation. There is no deception."); Release Motion at 2 ("There are no allegations
that he
forced, coerced, defrauded, or enslaved anybody
").
The most charitable explanation of this argument is that defense counsel may not yet realize
with which offense the defendant has been charged, wrongly believing it to be the provision of the
relevant statute that criminalizes recruitment or enticement of adults for commercial sex through
means of force, threats of force, fraud, or coercion. The prong under which the defendant is
charged, conversely, involves minors. As the indictment properly alleges, and the statute provides
for, where victims are underage, the Government principally must prove that a minor is caused to
engage in a commercial sex act. See United States V. Afyare, 632 F. App'x 272, 278 (6th Cir.
2016) ("We hold that $ 1591(a) criminalizes the sex trafficking of children (less than 18 years old)
with or without any force, fraud, or coercion, and it also criminalizes the sex trafficking of adults
(18 or older), but only if done by force, fraud, or coercion.").
Here, incredibly, the defense has already effectively admitted that the Government will be
able to present evidence of these primary elements-that the defendant engaged in sex acts for
money with girls he knew were underage. See Release Motion at 2. If the defendant dislikes the
state of federal sex trafficking law, he may petition any of the nine members of Congress who
I "Mag. Tr." refers to the transcript of the hearing before Magistrate Judge Pitman on July 8, 2019;
"D. Tr." refers to the transcript of the hearing before this Court on July 8, 2019.
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=== Page 4 ===
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 4
represent his places of residence; meanwhile, in the case that has actually been brought, his
insistence that he is innocent of a crime with which he is not charged is irrelevant.
B. The Defendant
It might not occur to a reader of the Release Motion that the defendant is widely reported
to be a billionaire-indeed, even the word "million" only appears once, to offer up as collateral a
property the Government has already noticed for seizure and forfeiture. Release Motion at 4.
Otherwise, there is not a single mention of net worth, income, or valuation of the defendant's vast
assets. This is, at best, obscurative.
Put plainly, the defendant is extraordinarily wealthy. According to records from a financial
institution ("Institution-1") relating to the defendant, in or about 2017, the defendant's estimated
net worth was listed as "$500 MM +" and his estimated annual income was $10 million. According
to records from another financial institution ("Institution-2") relating to the defendant, from 2018
through the present, the defendant's personal and business accounts have spent more than $10
million on credit cards alone.
The defendant has six residences, a private jet, an estimated net worth of at least a half a
billion dollars. His extraordinary incentives to flee, as further discussed below, are equaled by his
means to do so.
ARGUMENT
The Government agrees with Pretrial Services that the defendant should be detained
pending trial. He is a tremendous risk of flight, and a danger to the community, and he cannot
overcome the statutory presumption in favor of detention in this case.
I.
The Defendant's Proposal Does Nothing to Mitigate His Flight Risk
Each of the relevant factors to be considered as to flight risk-the nature and circumstances
of the offense, the strength of the evidence, and the history and characteristics of the defendant-
counsel strongly in favor of detention, and the defendant's proposed package would do nothing
whatsoever to mitigate that risk.
A. The Defendant's Financial Resources
As set forth in the Government's Detention Memo, the nature and circumstances of this
offense and the strength of the evidence create an extraordinary risk of flight. The defendant faces
up to 45 years of incarceration on the current counts with which he is charged, and the possibility
of a severe sentence is a significant factor in assessing the risk of flight. See United States V.
Jackson, 823 F.2d 4, 7 (2d Cir. 1987).
And the evidence of his guilt, already robust less than a week ago when the Indictment was
unsealed, is growing stronger literally by the day. Several additional women have identified
themselves to the Government as victims of the defendant. Pursuant to judicially-authorized
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Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 5
search warrants, the Government has discovered and seized vast amounts of photographs of nude
and seminude young women and girls in the defendant's Manhattan residence, and is in the process
of reviewing dozens of electronic discs that contain still more such photos. And dozens of
individuals have called the Government to convey information regarding the defendant and his
conduct. All this in less than a week, and all in addition to an Indictment that already alleges
dozens of victims in New York and dozens of victims in Florida.
Faced with significant and mounting evidence, the defendant's Release Motion does not
even attempt to account for the numerous entities, accounts, and assets he controls in the United
States and abroad. The Court cannot begin to evaluate the defendant's net worth, much less be
aware of particular obscured, hidden, or foreign-based assets that would further demonstrate the
defendant's ability to finance a comfortable life beyond the reach of United States authorities. The
defendant's financial resources are indisputably a relevant aspect of his "history and
characteristics." 18 U.S.C. $ 3142(g)(3); See United States V. Patriarca, 948 F.2d 789, 795 (1st
Cir. 1991) (explaining that a district court should consider the extent of a defendant's assets and
net worth before determining the amount of property to be posted as forfeiture condition).
In the first instance, because the defendant has refused to fill out a financial affidavit in
connection with his application for bail, the Court simply does not have sufficient information to
properly and accurately evaluate the defendant's risk of flight. Although the defendant continues
to hide the true scope, nature, and amount of his assets, he has repeatedly been described as a
billionaire in press reports, and is identified in documents of his own financial institution as having
a net worth of $500 million or more.
As described in the Government's Detention Memo, these resources, which remain
unknown in scope and would be completely unfettered by the defendant's proposed bail package,
give the defendant access to innumerable means to flee. The defendant is a frequent traveler and
regularly travels to and from the United States, including approximately more than 20 flights in
which he traveled to or from a foreign country since 2018. Extensive international travel of this
nature further demonstrates a significant risk of flight. See, e.g., United States V. Anderson, 384
F. Supp. 2d 32, 36 (D.D.C. 2005).
And not only does the defendant have the means to flee thanks to his vast wealth, crucially,
even were he to sacrifice literally all of his current assets, there is every indication that he would
immediately be able to resume making millions or tens of millions of dollars per year outside of
the United States. He already earns an estimated $10,000,000 per year, according to records from
Institution-1, while living in the U.S. Virgin Islands, traveling extensively abroad, and residing in
part in Paris, France; there would be little to stop the defendant from fleeing, transferring his
unknown assets abroad, and resuming whatever it is he does to earn his vast wealth from a
computer terminal beyond the reach of extradition.
The defendant is in a position to abandon millions of dollars in cash and property securing
any potential bond and still live comfortably for the rest of his life. These resources, and the ease
with which the defendant could flee and live outside the reach of law enforcement make the risk
of flight unacceptably high.
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=== Page 6 ===
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 6
B. The Defendant's Promise of "Consent" to Extradition is Unenforceable and Impractical
The theoretical possibility of extradition does not support release, because extradition is
never guaranteed, and rather is typically lengthy, complicated, and expensive. Additionally, the
defendant's offer to sign a so-called "consent" to extradition provides no additional reassurance
whatsoever. Numerous courts have recognized that such purported waivers are unenforceable and
effectively meaningless. See, e.g., United States V. Morrison, No. 16-MR-118, 2016 WL 7421924,
at *4 (W.D.N.Y. Dec. 23, 2016); United States V. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at
*3 (D. Or. Aug. 3, 2015); United States V. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300,
at *7 (D. Utah Aug. 27, 2013); United States V. Cohen, No. C 10-00547, 2010 WL 5387757, at *9
n.11 (N.D. Cal. Dec. 20, 2010); United States V. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn.
2004); United States V. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000);
United States V. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985). This is for very good reason:
Any defendant who signs such a purported waiver and then flees will assuredly contest the validity
and/or voluntariness of the waiver, and will get to do so in the jurisdiction of his choosing (i.e., the
one to which he chose to flee). The Department of Justice's Office of International Affairs is
unaware of any country anywhere in the world that would consider an anticipatory extradition
waiver binding.
C. Home Confinement and Electronic Monitoring Provide No Assurance
The defendant's proposal of ankle-bracelet monitoring should be of no comfort to the
Court. In particular, the defendant's endorsement of a GPS monitoring bracelet rather than a radio
frequency bracelet is farcical-neither one is useful or effective after it has been removed. At
best, home confinement and electronic monitoring would merely reduce his head start should he
decide to flee. See United States V. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 (E.D.N.Y.
Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application for bail in part because home
detention with electronic monitoring "at best
limits a fleeing defendant's head start"); see also
United States V. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same);
United States V. Anderson, 384 F.Supp.2d 32, 41 (D.D.C. 2005) (same); United States V. Benatar,
No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same).
D. Private Security is Inadequate and Raises Numerous Questions and Challenges
The defendant also proposes the use of a private security force to march him to and from
court under the threat of deadly force. This proposal should be rejected.
At the outset, it is far from clear that the defendant's private jail proposal, which seeks to
replicate the conditions of a government-run detention facility in the defendant's home, is a
condition of "release" that implicates the Bail Reform Act. "[T]here is a debate within the
judiciary over whether a defendant, if she is able to perfectly replicate a private jail in her own
home at her own cost, has a right to do so under the Bail Reform Act and the United States
Constitution." United States V. Valerio, 9 F. Supp. 3d 283, 292 (E.D.N.Y. 2014) (Bianco, J.)
(collecting cases). The Second Circuit has never directly addressed this issue. See United States
V. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) ("The government has not argued and, therefore,
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Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 7
we have no occasion to consider whether it would be "contrary to the principles of detention and
release on bail' to allow wealthy defendants 'to buy their way out by constructing a private jail."
(citations omitted)). While "troubled by [the] possibility" of wealthy defendants being allowed to
construct a private jail, the Second Circuit has not yet had occasion to decide whether district
courts "routinely must consider the retention of self-paid private security guards as an acceptable
condition of release before ordering detention." United States V. Banki, 369 Fed. App'x 152,
153-54 (2d Cir. 2010) (unpublished); see Valerio, 9 F. Supp. 3d at 293-94 (noting that the Bail
Reform Act addresses solely "conditions of release, not conditions of detention"). Indeed, a
decision by this Court reasoned that "the very severe restrictions" in the private jail proposal
presented to him did "not appear to contemplate 'release' so much as it describes a very expensive
form of private jail or detention." United States V. Zarrab, 2016 WL 3681423, at *10 (S.D.N.Y.
June 16, 2016).
Courts have long been troubled by private jail proposals like the defendant's which, "at
best "elaborately replicate a detention facility without the confidence of security such a facility
instills." United States V. Orena, 986 F.2d 628, 632 (2d Cir. 1993) (quoting United States V. Gotti,
776 F. Supp. 666, 672 (E.D.N.Y. 1991) (rejecting private jail proposal)); see also Valerio, 9 F.
Supp. 3d at 295 ("The questions about the legal authorization for the private security firm to use
force against defendant should he violate the terms of his release, and the questions over whether
the guards can or should be armed, underscore the legal and practical uncertainties-indeed, the
imperfections-of the private jail-like concept envisioned by defendant, as compared to the more
secure option of an actual jail."). A private security firm simply cannot replicate the controlled
environment of a federal correctional facility, in which, typically, all of the needs to the prisoner
can be attended to without placing the prisoner in the community at large; the defendant's proposed
private jail arrangement would have the effect of permanently placing him in just such a high-
flight-risk circumstance. The risk of a public escape attempt while in the community and involving
armed private guards attempting to stop the defendant, potentially by force-rather than the
defendant being in the environment of a federal facility-also greatly magnifies the danger of the
defendant's flight to the public. See United States V. Boustani, 356 F. Supp. 3d 246, 257 (E.D.N.Y.
2019) (in rejecting a private jail proposal, noting that it "raise[d] several issues related to use of
force" including that any escape attempt would "present the risk of a confrontation of armed guards
and Defendant
in the streets of New York city, which would mean that any reduction in the
Defendant's flight risk from this proposal would be at least partially offset by a greater risk to the
community") (citation omitted). "This is why, as the Government correctly notes, federal
prisoners should be detained in facilities run by trained personnel from federal correctional
facilities." Id. at 258 (citing Sabhnani, 493 F.3d at 74 13 ("To the extent [armed private guards]
implies an expectation that deadly force may need to be used to assure defendant['s] presence at
trial [s]uch a conclusion would, in fact, demand a defendant's detention")).
In Banki, the Second Circuit has held that it is not legal error "for a district court to decline
to accept," as "a substitute for detention," a defendant hiring private security guards to monitor
him. 369 F. App'x at 154. In the same decision, the Second Circuit noted that it was "troubled"
by the possibility of "allow[ing] wealthy defendants to buy their way out by constructing a private
jail." (internal quotation marks omitted)). Accord, e.g., United States V. Cilins, No. 13 Cr. 315
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=== Page 8 ===
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 8
(WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying
principles of detention and release on bail that individuals otherwise ineligible for release should
be able to buy their way out by constructing a private jail, policed by security guards not trained
or ultimately accountable to the Government, even if carefully selected" (quoting Borodin V.
Ashcroft, 136 F. Supp. 2d 125, 134 (E.D.N.Y. 2001))); Valerio, 9F. Supp. 3d at 293-94 (E.D.N.Y.
2014) ("There is nothing in the Bail Reform Act that would suggest that a defendant (or even,
hypothetically, a group of defendants with private funding) has a statutory right to replicate or
construct a private jail in a home or some other location.").
The defendant's payment of his guards also raises the conflict of interest inherent in having
the defendant having extraordinary influence over a private security company tasked with guarding
him, leaving the company's incentives entirely aligned with the defendant. See, e.g., Boustani,
356 F. Supp. 3d at 257 (in finding that private armed guards would not reasonably assure the
appearance of a defendant, noting a "clear conflict of interest-private prison guards paid by an
inmate" and noting that in a recent S.D.N.Y. case involving private security guards the defendant
"was outside of his apartment virtually all day, every weekday; was vitited by a masseuse for a
total of 160 hours in a 30-day period; and went on an unauthorized visit to a restaurant in
Chinatown with his private guards in tow"); see also United States V. Tajideen, 17 Cr. 046, 2018
WL 1342475, at *5-6 (D.D.C. Mar. 15, 2018) (Finding Zarrab "particularly instructive" and
further noting: "While the Court has no reason to believe that the individuals selected for the
defendant's security detail would intentionally violate federal law and assist the defendant in
fleeing the Court's jurisdiction, it nonetheless is mindful of the power of money and its potential
to corrupt or undermine laudable objectives. And although these realities cannot control the Court's
ruling, they also cannot be absolutely discounted or ignored.").
Finally, in Zarrab this Court found that "the Defendant's privately funded armed guard
proposal is unreasonable because it helps to foster inequity and unequal treatment in favor of a
very small cohort of criminal defendants who are extremely wealthy, such as Mr. Zarrab." 2016
WL 3681423, at *13; see also Boustani, 356 F. Supp. 3d at 258 ("although this Defendant has vast
financial resources to construct his own "private prison,' the Court is not convinced "disparate
treatment based on wealth is permissible under the Bail Reform Act") (quoting United States V.
Bruno, 89 F. Supp. 3d 425, 432 (E.D.N.Y. 2015) (""Even if Defendant had the financial capacity
to replicate a private jail within his own home, this Court is not convinced that such a set of
conditions would be sufficiently effective in this case to protect the community from Defendant,
or that such disparate treatment based on wealth is permissible under the Bail Act.")); Borodin,
136 F. Supp. 2d at 134 (E.D.N.Y. 2001) (Nickerson, J.) ("It is contrary to underlying principles of
detention and release on bail that individuals otherwise ineligible for release should be able to buy
their way out by constructing a private jail, policed by security guards not trained or ultimately
accountable to the government, even if carefully selected.").
The defendant's appearance can only be assured through detention- not through bail
granted based on hollow promises of an intent to clear his name in the face of weighty evidence
and a sentence of up to 45 years in jail, not through release on the threat of forfeiture of a mere
fraction of his wealth and property should he flee, and not through "detention" under the guard of
individuals to be paid by the defendant himself. Indeed: "What more compelling case for an order
EFTA00030254

=== Page 9 ===
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 9
of detention is there than a case in which only an armed guard and the threat of deadly force is
sufficient to assure the defendant's appearance?" Zarrab, 2016 WL 3681432, at *12
(quoting United States V. Valerio, 9 F. Supp. 3d at 295).
Very truly yours,
GEOFFREY S. BERMAN
By: United A
Assistant United States Attorney
Southern District of New York
Tel:
Cc:
Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant
EFTA00030255


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=== Page 1 ===
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 21, 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:
This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of
Criminal Procedure ("Fed. R. Crim. P."). Based on your request for discovery in this case, today
we are producing copies of the materials listed in the below index, which materials are stamped
with control numbers SDNY_GM_000165541 through SDNY_GM_00174966. A reproduction
of materials previously produced by the Government on August 12, 2020, which are stamped with
control numbers SDNY_GM_00086557 through SDNY_GM_00096055 and
SDNY_GM_00164920 through_SDNY_GM_00165517 is also included. The materials are
available for pickup at the U.S. Attorney's Office in Manhattan.
Materials stamped with control numbers SDNY_GM_00166247 through
SDNY_GM_00166273, SDNY _GM 00167093 through SDNY GM 00167097,
SDNY_GM_00167911 through SDNY_GM_00167913, SDNY_GM_00174366 through
SDNY_GM_00174369, and SDNY_GM_00174431 through SDNY_GM_00174458 have been
designated as "highly confidential" because they contain nude, partially nude, or otherwise
sexualized images of individuals. Consistent with the Protective Order in this case, the
Government is only producing these "highly confidential" materials to defense counsel and is not
producing these materials directly to the defendant.
06.20.2018
EFTA00030992

=== Page 2 ===
Page 2
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case.¹ This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order.
An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
SDNY_GM_00086557;
SDNY_GM_00096055;
Reproduction of Boies Schiller
Confidential
SDNY_GM_00164920
SDNY_GM_00165517
materials
SDNY_GM_00165541
SDNY_GM_00165557
Emails
Confidential
SDNY_GM_00165558
SDNY_GM_00165924
Message pad scans
Confidential
SDNY_GM_00165925
SDNY_GM_00165981
NYPD computer checks
Confidential
SDNY_GM_00165982
SDNY_GM_00166006
Photos of Journal entries and people
Confidential
SDNY_GM_00166007
SDNY_GM_00166043
Search warrant scans
Confidential
SDNY_GM_00166044
SDNY_GM_00166190
Sentinel search warrant and arrest
Confidential
reports
SDNY_GM_00166191
SDNY_GM_00169759
Search warrant photos
Confidential
SDNY_GM_00169760
SDNY_GM_00171456
Ghislaine Maxwell phone data
SDNY_GM_00171457
SDNY_GM_00172215
Database searches
Confidential
SDNY_GM_00172216
SDNY_GM_00172217
Recordings from Jeffrey Epstein
deposition; February 17, 2010
SDNY_GM_00172218
SDNY_GM_00173008
FBI Florida Physical Evidence
Confidential
SDNY_GM_00173009
SDNY_GM_00173019
Ghislaine Maxwell New Hampshire
Residence
SDNY_GM_00173020
SDNY_GM_00173128
Records
Confidential
SDNY_GM_00173129
SDNY_GM_00173156
Jeffrey Epstein arrest materials and
Confidential
statement
SDNY_GM_00173157
SDNY_GM_00173876
Jeffrey Epstein properties
SDNY_GM_00173877
SDNY_GM_00173944
Jeffrey Epstein travel and SORNA
Confidential
records
SDNY_GM_00173945
SDNY_GM_00174213
records
Confidential
SDNY_GM_00174214
SDNY_GM_00174966
Palm Beach Police Department and
Confidential
Florida Materials
This production includes certain materials from the files of the Florida office of the Federal
Bureau of Investigation ("FBI"). The Government notes that the remainder of the Florida FBI
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
EFTA00030993

=== Page 3 ===
Page 3
files are loaded onto an electronic review platform and will be processed and produced on a rolling
basis as part of electronic discovery.
Additionally, the Government notes that the physical items referenced in the productions
to date can be made available for you to review at the FBI New York office, upon request. Those
physical items include numerous hard copies of photographs and discs containing photographs,
which were seized during searches of Jeffrey Epstein's residences. As a courtesy, the FBI is in
the process of scanning those hard copy photographs and copying the photographs contained on
the discs. Once that process is complete, the Government intends to produce electronic copies of
any such photographs that do not contain highly confidential images. Any photographs among
those physical items identified as highly confidential will be made available for review at the FBI
New York office.
Finally, the Government wishes to inform you, as a courtesy, that it is in possession of a
copy of the FBI's case file regarding the investigation of a former employee of Jeffrey Epstein's
named
for obstruction of justice (the
File"). The
File is
maintained under a different FBI case number from the investigation that led to the charges against
your client. The
File has no relation to your client and no bearing on the charges in this
case. Accordingly, the Government does not intend to produce the
File because it is
not discoverable in this case.
Please do not hesitate to reach out if you have any difficulty accessing these materials or if
you wish to arrange a time to review physical items in the FBI's custody.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
06.20.2018
EFTA00030994


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: RE: FW:
Date: Thu, 06 Aug 2020 00:31:28 +0000
Attachments: 2020.08.06_MDC Maxwell.docx; 2020.08.05,_Maxwell,_Discovery_Letter.pdf
Hi
,
Thanks for all your help today -- when you send out the drive to MDC tomorrow, here are the two letters (the
updated cover letter fixing the designation issue, and the letter to BOP).
Thanks!
Original Message
From:
(USANYS) [Contractor]
Sent: Wednesday, August 5, 2020 5:55 PM
To:
Cc:
Subject: RE: FW:
This is a draft letter.
Unfortunately, I do not think the DVDs will work. McAfee is problematic and skips ~300 PDFs when I try to
burn it.
Original Message
From:
)
Sent: Wednesday, August 5, 2020 4:00 PM
To:
Cc:
(USANYS) [Contractor]
Subject: Re: FW:
Thanks
would you mind sending me a zipped version please? I'll get this out to defense counsel after
emails about the other issue. Thanks all.
Sent from my iPhone
> On Aug 5, 2020, at 3:55 PM,
)
wrote:
V
>
,
thanks very much for jumping on this.
V
V
per my email a moment ago. It may be easiest to zip these and send that way, or otherwise to send in
two emails since the total file size is large.
V
V
Please anyone let me know if any issues? And thanks again to all for the quick fix.
V
V
> From:
(USANYS) [Contractor]
> Sent: Wednesday, August 05, 2020 15:50
EFTA00031407

=== Page 2 ===
> To:
> Subject:
V
V
>
>
Special Assistant to the U.S. Attorney United States Attorney's
>
Office, SDNY
>
>
>
SDNY_GM_00000834-SDNY_GM_00000846.pdf>
>
SDNY_GM_00000847-SDNY_GM_00000852.pdf>
>
SDNY_GM_00000853-SDNY_GM_00000874.pdf>
>
SDNY_GM_00000875-SDNY_GM_00000900.pdf>
>
SDNY_GM_00000901-SDNY_GM_00000903.pdf>
>
SDNY_GM_00000904-SDNY_GM_00000905.pdf>
>
SDNY_GM_00000906-SDNY_GM_00000918.pdf>
> <SDNY_GM_00000919-SDNY_GM_00000924.pdf>
> SDNY_GM_00000925-SDNY_GM_00000955.pdf>
> SDNY_GM_00000956-SDNY_GM_00000962.pdf>
EFTA00031408


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=== Page 1 ===
From:
To:
)"
Subject: RE: epstein
Date: Tue, 09 Jul 2019 14:09:55 +0000
Importance: Normal
https://www.thedailybeast.com/jeffrey-epstein-shouldnt-expect-to-wiggle-free-again-with-sdny-sex-traficking-charges
From:
Sent: Tuesday, July 9, 2019 9:43 AM
To:
Subject: Fwd: epstein
The other one was from the second conference; this is from the first one
Sent from my iPhone
Begin forwarded message:
From: Goretti Moya <gmoya@sdreporters.com>
Date: July 8, 2019 at 17:12:36 EDT
To:
=
=
i
=
i
Subject: epstein
Please e-mail when youg et this
EFTA00030181


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Fox News Channel Request - EPSTEIN
Date: Wed, 06 Nov 2019 20:11:52 +0000
No, unfortunately.
From:
Sent: Wednesday, November 6, 2019 3:11 PM
To:
Cc:
Subject: RE: Fox News Channel Request - EPSTEIN
At least some of this is false. Is this someone we know?
From:
Sent: Wednesday, November 6, 2019 9:49 AM
To:
Cc:
Subject: Fwd: Fox News Channel Request - EPSTEIN
FYI
Sent from my iPhone
Begin forwarded message:
From: "Llenas, Bryan"
Date: November 6, 2019 at 9:31:35 AM EST
To:
Subject: Fox News Channel Request - EPSTEIN
Hi
My name is Bryan Llenas and I am a National Correspondent at the Fox News Channel.
Mark Epstein, the brother of Jeffrey Epstein, is telling Fox News Channel that the SDNY is withholding
Jeffrey's full medical examiner files and that the SDNY continues to cancel meetings on him.
Does the SDNY have a response to Mark's claims above?
What does the SDNY have to say about his claims that no one has given him evidence or explained to him why
they ruled his brother's death a homicide?
EFTA00031699

=== Page 2 ===
We'd like to publish an article today - including a statement from the SDNY.
I hope to hear from you soon.
All the best,
Bryan Llenas
Correspondent
Fox News Channel
New York Bureau
This message and its attachments may contain legally privileged or confidential information. It is intended
solely for the named addressee. If you are not the addressee indicated in this message (or responsible for
delivery of the message to the addressee), you may not copy or deliver this message or its attachments to
anyone. Rather, you should permanently delete this message and its attachments and kindly notify the sender
by reply e-mail. Any content of this message and its attachments that does not relate to the official business of
Fox News or Fox Business must not be taken to have been sent or endorsed by either of them. No
representation is made that this email or its attachments are without defect.
EFTA00031700


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=== Page 1 ===
From:
To:
Bee:
Subject: SDNY NEWS CLIPS, MONDAY, NOVEMBER 23, 2020
Date: Mon, 23 Nov 2020 20:08:48 +0000
Inline-Images: image001.png
OF
SDNY PRESS CLIPPINGS
DEPARTMENT
JUSTITIA
MAXWELL
LAW&CRIME: https://lawandcrime.com/high-profile/mystery-deposition-in-ghislaine-maxwel-civil-case-will-be-unsealed-on-monday/
MATTERS OF INTEREST
:ps://wwwwashingtopst.om/ocal/repblians-nd-others-oferiso-howto-rebut-millo-letondeiers2020/1/22/b78242e2-2b0-1eb-92b7-6ef17b3e3b4-stary.hm-
NASDAQ: https://www.nasdaq.com/articles/why-macys-stock-is-soaring-today-2020-11-23
AP: https://apnews.com/article/election-2020-donald-trump-pennsylvanio-elections-talk-radio-433b6efe72720d8648221f405c211f97
WSJ: https://www.wsi.com/articles/joe-biden-picks-antony-blinken-for-secretary-of-state-11606100542
POLITICO: https://www.politico.com/newsletters/weekly-cybersecurity/2020/11/23/democrats-want-dhs-changes-791843
YAHOO: https://news.yahoo.com/hilton-bidens-white-house-staff-025206637.html
DAILY BEAST: https://www.thedailybeast.com/isrgeli-spies-arent-exactly-rejoicing-at-jonathan-pollards-releose
EFTA00030008


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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: OPR
Date: Mon, 01 Feb 2021 19:59:54 +0000
Embedded: RE:_OPR.msg
Sender:
Subject: RE: OPR
Message-Id:
<BN3P110MB0339EBCB46F4B44DF2848FD992B69@BN3P110MB0339.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
To:
To:
Cc:
EFTA00029892


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
Subject: FW: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Objections to Gov't Proposed
Redactions in Omnibus Response
Date: Tue, 09 Mar 2021 19:00:37 +0000
Attachments: 2021.03.09_LAM_Letter_to_Nathan_re_redactions_in_Govt_Response.pdf,129-134_187-
188.pdf; Exhibit_5_(Proposed_Redactions).pdf
FYI
From: Laura Menninger
Sent: Tuesday, March 9, 2021 1:08 PM
To:
Cc:
=
is
>;
(USANYS)
is
)
>; 'BOBBI C STERNHEIM'
Jeff Pagliuca
Christian R Everdell - Cohen & Gresser LLP
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Objections to Gov't Proposed Redactions in Omnibus Response
Dear Judge Nathan -
Pursuant to Rule 2(B) of the Court's individual rules, attached is a letter setting forth Ms. Maxwell's objections to the
redactions proposed by the government to their Omnibus Response and Exhibit 5. Also attached are exhibits setting forth
Ms. Maxwell's proposed redactions.
Best regards,
Laura A. Menninger
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
EFTA00029843


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=== Page 1 ===
From:
To:
Subject: Re: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:14:03 +0000
Inline-Images: image001.png
Haha best all day
Sent from my iPhone
On Jul 2, 2020, at 1:52 PM,
wrote:
Why am I just hearing about this case now?
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
<image001.png>
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The
Indictment unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-
conspirator Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting
them for the purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for
young girls, MAXWELL played a critical role in the grooming and abuse of minor victims that took place in
locations 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
EFTA00031523

=== Page 2 ===
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[1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and
participated in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit,
groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims
were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom
knew that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor
victims, MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different
states, which MAXWELL knew and intended would result in their grooming for and subjection to sexual
abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies
or taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's
behavior. Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to
accept offers of financial assistance from Epstein, including offers to pay for travel or educational expenses.
MAXWELL also normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging
them to massage Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately
MAXWELL was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized
massages during which a minor victim was fully or partially nude, as well as group sexualized massages of
Epstein involving a minor victim where MAXWELL was present.
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.
EFTA00031524

=== Page 3 ===
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in
illegal sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a
minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one
count of transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum
sentence of 10 years in prison, one count of conspiracy to transport a minor with the intent to engage in
criminal sexual activity, which carries a maximum sentence of five years in prison, and two counts of perjury,
each of which carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth
herein, constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed
innocent unless and until proven guilty.
UNITED QUI PRO DOMINA JUSTITIA OF JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
OF
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=== Page 1 ===
From: "Stoddart, Allison"
To:
)"
"Sahni, Anjan"
Cc:
)"
)"
Subject: RE: JPMorgan Chase Production
Date: Fri, 08 Nov 2019 20:14:53 +0000
To update you on the wire collection, we anticipate making a production next week. We are trying to confirm now, but we
believe that there are only five JPMC accounts - two for Epstein and three for Maxwell - for which there is wire data.
Separately, we also anticipate producing wire data for transactions related to Epstein, Maxwell, and
where JPMC
acted as a correspondent bank.
We are also making progress on collecting other information, including account opening documents, KYC documents, and
account statements. Per our earlier conversations, we are compiling this information to make a single production rather
than providing it on a rolling basis.
Finally, we also understand that JPM National Subpoena Processing heard from
at the FBI. We called him just
to say that to the extent he has questions, he can direct them to us.
Thanks,
Allison
From:
Sent: Tuesday, October 29, 2019 7:25 PM
To: Sahni, Anjan
>; Stoddart, Allison
Cc:
>;
Subject: RE: JPMorgan Chase Production
EXTERNAL SENDER
Anjan,
Thank you for checking in, and we look forward to receiving the update later this week. Regarding the subpoenas, I think
there was one subpoena served by the FBI just a day or two before we were first in touch, dated September 3, 2019,
relating to
and then it appears we did inadvertently let the FBI serve one after we were in touch with
you, dated October 8, 2019, relating to
If you've received any subpoenas addition to those (other than the
ones we've already previously discussed), please let us know, and otherwise we certainly will send any additional process
directly to you-apologies for any inconvenience or confusion caused by the separate service.
Thanks again, and talk soon.
EFTA00030702

=== Page 2 ===
From: Sahni, Anjan
Sent: Monday, October 28, 2019 23:21
To:
>; Stoddart, Allison
Cc:
is
Subject: RE: JPMorgan Chase Production
Hope all is well. We expect to have an update for you later this week on the timing of the wire production and our other
ongoing collection efforts. On a related note, we learned from JPMorgan's National Subpoena Processing that they
received a couple subpoenas directly from the FBI, which I assume are related to the same investigation we've been
discussing. For any additional subpoenas in this investigation directed to JPMorgan, could you please direct them to us?
That will help us get them to the appropriate team more quickly.
Thanks,
Anjan
From:
Sent: Monday, September 30, 2019 5:25 PM
To: Stoddart, Allison
Cc: Sahni, Anjan
is
is
Subject: RE: JPMorgan Chase Production
EXTERNAL SENDER
Allison,
Received, thank you, and we were able to access the materials.
thanks again,
From: Stoddart, Allison
Sent: Wednesday, September 25, 2019 20:12
To:
Cc: Sahni, Anjan
is
is
Subject: [Not Virus Scanned] [Not Virus Scanned] JPMorgan Chase Production
Attached is a letter on behalf of our client, JPMorgan Chase, along with an encrypted zip. I will send the password in a
separate email. Please let us know if you have any issues accessing the materials.
Thank you,
Allison
Allison Stoddart I WilmerHale
EFTA00030703

=== Page 3 ===
(t)
Please consider the environment before printing this email.
This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not
the intended recipient, please notify us immediately-by replying to this message or by sending an email to postmaster@wilmerhale.com- and destroy all
copies of this message and any attachments. Thank you.
For more information about WilmerHale, please visit us at http://www.wilmerhale.com.
EFTA00030704


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c7: images
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=== Page 1 ===
From:
Subject: Accepted: Epstein/Maxwell FOIA
Date: Wed, 10 Mar 2021 20:20:29 +0000
Importance: Normal
Attachments: unnamed
EFTA00030074


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c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031634.pdf
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=== Page 1 ===
US. GPO: 2004-337-714 90013
FD-597 (Rev 8-11-94)
Page
/ of /
UNITED STATES DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF INVESTIGATION
Receipt for Property Received/Returned/Released/Seized
File #
31E-mm-108062
On (date)
03/17/2011 (Sydamy,Authalia)
item(s) listed below were:
Received From
Returned To
Released To
Seized
(Name)
(Street Address)
(City)
Description of Item(s): 20 PHOTOGRAPHS
NOTHINK
follows
Received By:
Received From:
3501.226-029
Page 1 of 41
EFTA00031634

=== Page 2 ===
3501.226-029
Page 2 of 41
EFTA00031635

=== Page 3 ===
Prince Andres,
(17)
Ghislane Resevell 2001 (JANURAY)
3501.226-029
Page 3 of 41
EFTA00031636

=== Page 4 ===
all
****
IIII
IERI
1821
IIII
1881
3501.226-029
Page 4 of 41
EFTA00031637

=== Page 5 ===
3rd person First (L) in centre.
Jean's $ Grey Sweater
Jeffrey Epstein
20>018)33+00 20>018 33+00 NNNNN-26AU 0072
in France,
Paris
Dec 00'
3501.226-029
Page 5 of 41
EFTA00031638

=== Page 6 ===
RIA

=== Page 7 ===
(From "L" to 1% RF Dec 00'
I. Interior: Designer's Asst.
2. Interior Designer
3. Jeffrey Epstein
4. Architect
5. Ghislane Maxwell
b.
0072 not 00+15 600<6*ON>
3501.226-029
Page 7 of 41
EFTA00031640

=== Page 8 ===
3501.226-029
Page 8 of 41

=== Page 9 ===
E66th - Apartment in N.Y
3501.226-029
Page 9 of 41
EFTA00031642

=== Page 10 ===
I

=== Page 11 ===
Albequegie Minuem i
3501.226-029
Page 11 of 41
EFTA00031644

=== Page 12 ===
will

=== Page 13 ===
Alb. Mueseum
3501.226-029
Page 13 of 41
EFTA00031646

=== Page 14 ===
3501.226-029
Page 14 of 41
EETA00031647

=== Page 15 ===
"Alb, Moeseum
3501.226-029
Page 15 of 41
EFTA00031648

=== Page 16 ===
so

=== Page 17 ===
Alb: Musmir
3501.226-029
Page 17 of 41
EFTA00031650

=== Page 18 ===
ME
/

=== Page 19 ===
J.E's Ranch "Zorro"
3501.226-029
Page 19 of 41
EFTA00031652

=== Page 20 ===
ot
3501.226-029

=== Page 21 ===
J.E's Horse & R.oh "20mo"
3501.226-029
Page 21 of 41
EFTA00031654

=== Page 22 ===

=== Page 23 ===
J.E's Ranch it 20rro"
3501.226-029
Page 23 of 41
EFTA00031656

=== Page 24 ===
N
/
$
3501 226

=== Page 25 ===
20rro" Ranch Entrance
3501.226-029
Page 25 of 41
EFTA00031658

=== Page 26 ===
whin will
YORK VO DRIV
it
EFTA00031659
Page 26 of 41
3501 226-029 3501

=== Page 27 ===
N.Y * Ferrie's
Photo"
3501.226-029
Page 27 of 41
EFTA00031660

=== Page 28 ===

=== Page 29 ===
Indian Artwol: on J.E's
Ranch 2amp"
3501.226-029
Page 29 of 41
EFTA00031662

=== Page 30 ===
3501.226-029
Page 30 of 41
EFTA00031663

=== Page 31 ===
on J.E,'s
(
A
Horse in Zorro"
3501.226-029
Page 31 of 41
EFTA00031664

=== Page 32 ===
NA
X
T

=== Page 33 ===
J.E's Horse is hable " 20m of
3501.226-029
Page 33 of 41
EFTA00031666

=== Page 34 ===
MI

=== Page 35 ===
J.E's Horse $ Simble Zorro"
3501.226-029
Page 35 of 41
EFTA00031668

=== Page 36 ===
WE

=== Page 37 ===
J.E's Ranel "Zamo"
3501.226-029
Page 37 of 41
EFTA00031670

=== Page 38 ===
Page 38 of
3501.226-02

=== Page 39 ===
J.E's Ranch Zorro
3501.226-029
Page 39 of 41
EFTA00031672

=== Page 40 ===

=== Page 41 ===
Ranch Hand 01 Zomo
Married to one of
the Main House
K. -s 3
lived on the
Panch
3501.226-029
Page 41 of 41
EFTA00031674


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Subject: FW: U.S. V. Maxwell
Date: Wed, 02 Dec 2020 00:11:47 +0000
Attachments:BC_-2020-12-01_GM_letter_regarding_defense_request_re_MDC_warden.docx
Are you both ok with these?
From: BOBBI C STERNHEIM
Sent: Tuesday, December 01, 2020 7:07 PM
To:
(USANYS)
Cc:
);
)
; Christian Everdell ; Mark S. Cohen
Subject: Re: U.S. V. Maxwell
The revisions do not change our respective positions.
It merely makes it a "joint" submission.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
On Dec 1, 2020, at 6:46 PM, BOBBI C STERNHEIM
wrote:
We are in the process of reviewing and revising the letter as a "joint submission" per Court order.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
EFTA00030415

=== Page 2 ===
Fax:
*Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
On Dec 1, 2020, at 6:09 PM,
(USANYS)
wrote:
Bobbi,
Attached is a draft of the letter. We will plan to file by 7:30 unless we hear from you before then.
Best,
Lara
From: BOBBI C STERNHEIM
Sent: Tuesday, December 01, 2020 5:50 PM
To:
(USANYS)
)
Cc: Christian Everdell
Mark S. Cohen
Subject: U.S. V. Maxwell
When you might circulate a draft of the joint letter?
Thanks
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
<2020-12-01 GM letter regarding defense request re MDC warden.pdf>
EFTA00030416


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=== Page 1 ===
From:
)"
To:
Subject: Re: Jeffrey Epstein
Date: Fri, 12 Jul 2019 22:24:54 +0000
Importance: Normal
Thanks! Talk soon.
Sent from my iPhone
On Jul 12, 2019, at 6:05 PM,
wrote:
This email was sent via my iPhone using the dictation app. Please understand there may be some
typographical or grammatical errors.
NOTICE: This E-mail (including attachments) is covered by the Electronic Communications Privacy
Act, 18 U.S.C. 2510-2521, is confidential and may be ATTORNEY PRIVILEGED and CONFIDENTIAL
It is intended only for the use of the individual or entity named as recipient. If the reader
of this message is not the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication or any of its contents, is strictly prohibited.
If you have received this communication in error, please notify sender immediately by re-sending
This communication to the sender and delete the original message and any copy of it from your
computer system.
Thank you for your cooperation.
Begin forwarded message:
From:
Date: July 12, 2019 at 11:22:04 AM EDT
To:
Cc:
Subject: Jeffrey Epstein
Mr.
EFTA00030298

=== Page 2 ===
It was great touching base with you this morning. As I mentioned on the phone, the Office of the State Attorney is
interested in any information that could lead to criminal charges from that crimes occurred in Palm Beach County. If
you aware of any victims who would like to make a statement to local law enforcement please advise. Feel free to pass
my contact information on to anyone who might have information.
Regards-
Assistant State Attorney
Special Victim's Unit
Human Trafficking and ICAC
Office Of The State Attorney
15th Judical Circuit
Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records
available to the public and media upon request. Your e-mail communications may therefore be subject to public disclosure.
EFTA00030299


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Epstein search materials for upload and privilege review
Date: Tue, 10 Mar 2020 17:05:40 +0000
From:
Sent: Tuesday, March 03, 2020 12:58
To:
is
Cc:
is
Subject: RE: Epstein search materials for upload and privilege review
Circling back on this, both in terms of moving the documents and de-duping - there are an absolutely insane amount of
repeat docs. Please let us know the status? Thanks.
From:
Sent: Saturday, February 22, 2020 19:25
To:
is
>
Cc:
is
Subject: RE: Epstein search materials for upload and privilege review
Also we really need to get these results de-duped - there are *tons* of repeat documents.
From:
Sent: Saturday, February 22, 2020 19:22
To:
is
>
Cc:
is
Subject: RE: Epstein search materials for upload and privilege review
Totally understand it's voluminous, but we do to need to move it because otherwise our searching process will be all
messed up - we won't be able to run terms through all search warrant returns (instead, we'd have to duplicate literally
every search across two different huge folders). And it doesn't work to just search all materials in the entire file because
the FBI case file is also huge.
If going forward there is any question at all on where things should go in the folder structure, we're more than happy to
provide guidance on that.
From:
Sent: Friday, February 21, 2020 17:04
To:
EFTA00029754

=== Page 2 ===
Cc:
is
>;
Subject: Re: Epstein search materials for upload and privilege review
Moving may be an issue, PAE had trouble releasing the data because they were so voluminous.
On Feb 21, 2020, at 4:55 PM,
)
wrote:
Ah, possibly it's the "2020-01-23" folder under Subpoena Returns? If so,
can we please (1) move that to under the
Search Warrant Returns folder, and (2) if at all possible, combine the 37 different subfolders into one? There doesn't
appear to be any distinction between all of those folders so I don't think there's any utility in having so many subgroups.
But let us know if (2) is a problem and happy to discuss.
From:
Sent: Friday, February 21, 2020 16:53
To:
Cc:
is
>;
Subject: RE: Epstein search materials for upload and privilege review
I think they are in the Subpoena Returns folder, which I thought was strange. I'm heading to
now but will log in
after that to find them.
From:
Sent: Friday, February 21, 2020 4:32 PM
To:
Cc:
is
V.
Subject: RE: Epstein search materials for upload and privilege review
just tried calling but didn't catch you - I don't see where these are located in Relativity? I think they should be
under "Search Warrant Returns" but I don't see them there (or anywhere else under the Epstein overall folder). Let me
know if I've just missed them, which is entirely possible, or if they're not accessible to us yet? Thank you!
From:
Sent: Thursday, February 20, 2020 21:12
To:
>;
Cc:
is
Subject: Re: Epstein search materials for upload and privilege review
The NP folder has been released.
EFTA00029755

=== Page 3 ===
On Feb 20, 2020, at 2:28 PM,
wrote:
Here's the STR and the data should be released soon, it's just taking a while because the load is so large.
From: Korologos,
(USANYS)
Sent: Thursday, February 20, 2020 11:42 AM
To:
>;
Cc:
is
)
Subject: RE: Epstein search materials for upload and privilege review
New data is loaded and we've segregated the PP hits; you should have access to the new data today. Will keep you
posted.
From:
Sent: Wednesday, February 12, 2020 1:04 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
wanted to follow up on this - is the data fully uploaded, or did it get delayed? Thanks.
From:
Sent: Friday, February 07, 2020 11:25
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
Great, thank you!
From:
Sent: Friday, February 07, 2020 09:34
To:
Cc:
is
)
is
Subject: RE: Epstein search materials for upload and privilege review
The data should be ready by Monday morning.
From:
Sent: Tuesday, February 4, 2020 6:58 PM
To:
Cc:
is
is
EFTA00029756

=== Page 4 ===
Subject: RE: Epstein search materials for upload and privilege review
Wanted to quickly check the status of the below - it's only been a couple weeks, so totally understand it may not be
complete, but hopefully we're getting close? If you could please check with the vendor and let us know, we'd be
grateful - and we'll plan to get it to
asap once we have access.
thanks,
From:
)
Sent: Tuesday, January 21, 2020 18:50
To:
Cc:
is
)
is
)
Subject: RE: Epstein search materials for upload and privilege review
We've received a hard drive from FBI CART, which they've processed from devices seized and searched in connection
with the Epstein case. Can we please get those materials uploaded to Relativity, for privilege review by
(copied
here)? I've left the hard drive with the materials on your chair. (And if we could please get that hard drive back once
the materials are uploaded, the FBI has another batch they want to transmit to us for the same process, so that will
also be coming shortly.)
And then
these will be subject to just the exact same privilege review you previously ran in connection with
Epstein search warrant returns.
Please let us know if any questions or issues at all? And
very much as always.
<STR_Epstein_Privilege Terms_02.14.2020.pdf>
EFTA00029757


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=== Page 1 ===
From:
To:
Date: Thu, 06 Aug 2020 13:35:23 +0000
https://www.newsweek.com/prince-andrew-was-club-jeffrey-epstein-young-girl-witness-says-1522580.
EFTA00031409


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=== Page 1 ===
From:
"
(NY) (FBI)"
To:
)"
)"
,
(NY) (FBI)"
Cc:
)"
Subject: RE: financial documents (Epstein)
Date: Tue, 23 Jul 2019 15:06:48 +0000
1:30 works for me. If possible, I would like
to be on the call.
Best
From:
)
[mailto:
Sent: Tuesday, July 23, 2019 10:54 AM
To:
(NY) (FBI)
is
)
>;
V.
(NY) (FBI)
Cc:
Subject: RE: financial documents (Epstein)
Hi
With apologies for the delay in scheduling this, would a call at 1:30 today work? Thanks.
From:
(NY) (FBI)
Sent: Thursday, July 18, 2019 7:33 PM
To:
is
>;
is
(NY) (FBI)
Cc:
Subject: RE: financial documents (Epstein)
Looking forward to working with you as well. My Tuesday is open. Set a time that works for you.
Best
From:
) [mailto:
Sent: Thursday, July 18, 2019 6:58 PM
To:
is
>;
(NY) (FBI)
is
(NY) (FBI)
Cc:
Subject: RE: financial documents (Epstein)
EFTA00030628

=== Page 2 ===
Hi
looking forward to working with you again! Aside from a court conference at 11 on Tuesday, I can make any
time work. Thanks.
From:
)
Sent: Thursday, July 18, 2019 6:56 PM
To:
is
(NY) (FBI)
>;
(NY) (FBI)
Cc:
is
Subject: RE: financial documents (Epstein)
great to have you onboard, welcome - and as of now I don't have anything scheduled for Tuesday.
From:
Sent: Thursday, July 18, 2019 16:49
To: Hamilton,
)
[Contractor]
Cc:
is
(NY) (FBI)
>;
is
i
(NY) (FBI)
Subject: Re: financial documents (Epstein)
I've CC'd the forensic accountant
in our squad who will be assisting in this investigation. Let's try and plan a
day next week to meet briefly and discuss a game plan. Are you guys around Tuesday to chat?
On Jul 18, 2019, at 11:17, Hamilton,
)
[Contractor]
wrote:
I have the discs, where should I bring them?
From:
)
Sent: Wednesday, July 17, 2019 8:47 PM
To: Hamilton,
)
[Contractor]
Cc:
(NY) (FBI)
is
is
)
i
)
Subject: RE: financial documents (Epstein)
Tomorrow morning could you please burn the following folders to a disc:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018SDNY
investigation\Subpoena Express
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#2018 SDNY
investigation\Subpoena Returns\ Deutsche Bank
and put the disc in an envelope addressed to:
Special Agen
Detective
If it's possible to get the disc by 11:30, we'll give the disc to
at the conference, or if not, if you could put
the envelope with security and reply all that it's ready, they can pick up when convenient.
EFTA00030629

=== Page 3 ===
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00030630


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=== Page 1 ===
From:
To:
Subject:
Date: Mon, 03 May 2021 21:54:45 +0000
Attachments: 127129028102.pdf
https://ecf.nysd.uscourts.gov/doc1/1271290281022caseid=539612&de_seq_num=807&magic_num=72704034
EFTA00031697


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=== Page 1 ===
U.S. V. Ghislaine Maxwell
THE CHARGED CONDUCT OCCURRED IN NEW YORK CITY,
PALM BEACH, FLORIDA, SANTA FE, NEW MEXICO, AND
LONDON, ENGLAND.
MAXWELL HAS BEEN ARRESTED FOR ALLEGED
FACILITATING OF SEX ABUSE OF UNDERAGED GIRLS
FOR JEFFREY EPSTEIN.
IF YOU RECOGNIZE EITHER OF THESE PERSONS AND
FEEL YOU MAY BE A VICTIM, PLEASE CALL THE
FOLLOWING NUMBER:
1-800-CALL FBI
SISTETA OF
EFTA00030006

=== Page 2 ===
U.S. V. Ghislaine Maxwell
Properties Owned by Epstein Where Alleged
Grooming and/or Abuse of Minor Victims Occurred:
New York, New York
Palm Beach, Florida
Santa Fe, New Mexico
EFTA00030007


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=== Page 1 ===
From:
"
(USAVI)"
To:
(USAVI)"
,
(USANYS)"
,
(USANYS)"
Subject: Jeffrey Epstein Estate/Southern Country International Bank/USVI
Date: Thu, 02 Apr 2020 12:03:10 +0000
Importance: Normal
Attachments: unnamed
Toll Free Number: 866-421-2611
Passcode: 1950230#
EFTA00030815


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=== Page 1 ===
From:
USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: RE: Maxwell / Transition
Date: Tue, 29 Dec 2020 21:30:09 +0000
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN): In July 2020, Maxwell was charged in a six-count indictment with
facilitating the sexual abuse of three minor victims by Jeffrey Epstein between approximately 1994 and 1997. The charges
resulted from a multi-year investigation by the USAO-SDNY and the FBI into Jeffrey Epstein and his co-conspirators,
including Maxwell. Maxwell played a critical role in the scheme by helping to identify, entice, and groom minor girls to
engage in sex acts with Epstein. Her presence as an adult woman normalized Epstein's abusive behavior, and she even
took part in at least some acts of sexual abuse. 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, resulting in charges related to the enticement and transportation of minors to participate in
illegal sex acts, and conspiracy to do the same, in violation of 18 U.S.C. § 2422, 2423, and 371. Then, in an effort to cover
up her crimes, the defendant lied under oath during a civil deposition, including when asked about her interactions with
minor girls, resulting in two perjury charges, in violation of 18 U.S.C. § 1623. Maxwell has been detained since her arrest,
and the Court has denied two separate bail motions, most recently as of December 28, 2020. Trial is scheduled for July
2021, and pretrial motions are due in January 2021. The most recent press release is located here:
https://www.justice.gov/usao-sdny/pr/ghislaine-maxwell-charged-manhattan-federal-court-conspiring-jefrey-epstein-
sexually
From:
(USANYS)
Sent: Tuesday, December 29, 2020 11:56 AM
To:
(USANYS) ;
(USANYS)
Subject: RE: Maxwell / Transition
Ideally tomorrow? The description of the case / status need be no more than a paragraph or so.
From: Donaleski, Rebekah (USANYS)
Sent: Tuesday, December 29, 2020 11:53 AM
To:
(USANYS)
is
(USANYS)
Subject: RE: Maxwell / Transition
Sure, when do you need this by?
From:
(USANYS)
Sent: Tuesday, December 29, 2020 11:44 AM
To:
(USANYS)
is
USANYS)
Subject: Maxwell / Transition
Hope you are enjoying the holidays! All USAOs have been asked to send a writeup of our two most significant publicly
filed criminal cases (and one civil case) to the transition. We're going to include Maxwell as one of the two. Would you
guys mind putting together a writeup? We have been asked to include the following information:
Case name
Docket number
Brief description of the charges/claims
Current case status
Link to most recent press release (if applicable)
Counsel to the Acting U.S. Attorney
United States Attorney's Office
Southern District of New York
EFTA00031580


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c0:
=== Page 1 ===
From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:27:17 +0000
Inline-Images: image001.png
Thank you!!!
From:
Sent: Thursday, July 02, 2020 13:26
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congratulations guys. Amazing work.
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
UNITED QUI PRO DOMINA JUSTITIA OF SOFFICE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
EFTA00031227

=== Page 2 ===
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
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.
EFTA00031228

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00031229


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c0:
=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: RE: documents for Relativity
Date: Tue, 26 Mar 2019 13:14:25 +0000
Importance: Normal
I am here and around for whenever you are free to chat.
From:
Sent: Monday, March 25, 2019 9:00 PM
To:
Cc:
Subject: RE: documents for Relativity
Yeah, it's
not great for our pending application.
From:
Sent: Monday, March 25, 2019 20:59
To:
Cc:
Subject: Re: documents for Relativity
Oh goodness I just learned judge sweet passed away
Sent from my iPhone
On Mar 25, 2019, at 7:00 PM,
wrote:
Could we please load the documents in the following folder into Relativity for US V. Epstein (USAO # 2018R01618):
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY
investigation\Subpoena Returns\ Boies Schiller\2019-03-04, Boies Schiller first subpoena response
In terms of structure, we'd like to create a folder identified as "Subpoena Returns" (at the same level as "FBI Case File" is
currently), and in a subfolder within Subpoena Returns, a folder titled "BSF returns," and within that a subfolder
identified as "BSF first production" that the docs in the above link can be deposited into (including any additional
subfolders). Does that work?
Please let me know if any questions or if any other information would be helpful, and if you could please let us know
when it's all uploaded?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00030122

=== Page 2 ===
EFTA00030123


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=== Page 1 ===
From:
)"
To:
)"
Cc: "Martin G. Weinberg"
"Miller, Michael"
"Weingarten, Reid"
Subject: Re: U.S. V. Epstein call
Date: Sun, 25 Aug 2019 19:04:28 +0000
Marty,
Following up on our conversation last week, are you able to share with us your thoughts on whether the defense
intends to address the Court beyond noting that there is no objection to the dismissal?
Separately, if you could please let us know the status of the return of discovery materials, we would appreciate it.
We are hopping to be able to tell the Court on Tuesday that this issue is resolved.
Thanks,
Sent from my iPhone
On Aug 22, 2019, at 12:09 PM,
)
wrote:
Marty,
I got your voicemail from this morning regarding follow-up on civil forfeiture-we have a meeting at 12:30 that I expect
will go approximately 15 minutes and will plan to give you (or Mike, to conference you in) a call after that, so
approximately around 12:45 - 1:00.
Separately, based on the expected nolle order, and in connection with the protective order in this case, in advance of the
hearing on Tuesday can you please either return to the Government all discovery you received in this case and certify
that any copies have been security destroyed or deleted, or, alternatively, simply certify that all discovery received has
been security destroyed or deleted? (As to the second option, that is to say that you do not need to make additional
copies of electronic materials to formally "return" them to us if it is more efficient to simply delete and destroy the
existing electronic copies you have.) We want to be able to advise the Court on Tuesday that there are no outstanding
discovery obligations on either side based in connection with the protective order.
Thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00029728


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030543.pdf
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c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To: Michael Bachner
Cc:
(USANYS)"
(USANYS)"
Subject: RE: Epstein investigation /
Date: Wed, 07 Aug 2019 17:45:25 +0000
Mike,
That's fine, though if you prefer a different time - later this evening, tomorrow early morning, tomorrow late evening, etc
- we can accommodate. Let us know if you prefer something like that, or otherwise we'll plan to call you at 2:30.
thanks again,
From: Michael Bachner
Sent: Wednesday, August 07, 2019 13:42
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Re: Epstein investigation /
I can talk at 230
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is not
the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited.
If you have received this communication by error, please immediately notify the sender by e-mail and delete this
email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
On Aug 7, 2019, at 1:40 PM,
(USANYS)
wrote:
Mike,
We don't think it makes sense to put this off for an entire week, particularly since it has been three weeks since we met
and you were otherwise prepared to speak earlier today. We're also continuing to hold in abeyance a grand jury date
that otherwise would have been two weeks ago. We can make ourselves available in an early morning or evening or
EFTA00030543

=== Page 2 ===
night if your schedule is otherwise jammed, if that's helpful? But we would like to get an update sooner rather than
later, even if it's a relatively brief conversation at this stage. Please let us know?
thanks,
From: Michael Bachner
Sent: Wednesday, August 07, 2019 13:31
To:
Cc:
is
Subject: RE: Epstein investigation /
once again my apologies for today. This week is a mess for me. Does Aug 14 work?
<image001.jpg>
<image002.jpg>
https://www.actl.com/
Michael Bachner, Esq.
Bachner & Associates, PC
39 Broadway, Suite 1610
New York, NY 10006
www.bhlawfirm.com
<image003.png>
CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic
Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally
privileged. If you are not the intended recipient, you are hereby notified that any retention,
dissemination, distribution, or copying of this communication is strictly prohibited. Please reply to the
sender that you have received the message in error and then delete it. Thank you.
From:
(USANYS) [mailto:
Sent: Wednesday, August 7, 2019 11:35 AM
To: Michael Bachner
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Epstein investigation
Hi Michael,
We just tried your office-please let us know if we should reschedule. Thanks.
From: Michael Bachner
Sent: Thursday, August 1, 2019 3:41 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Epstein investigation /
EFTA00030544

=== Page 3 ===
11:30?
<image001.jpg>
<image002.jpg>
https://www.actl.com/
Michael Bachner, Esq.
Bachner & Associates, PC
39 Broadway, Suite 1610
New York. NY 10006
www.bhlawfirm.com
<image003.png>
CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic
Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally
privileged. If you are not the intended recipient, you are hereby notified that any retention,
dissemination, distribution, or copying of this communication is strictly prohibited. Please reply to the
sender that you have received the message in error and then delete it. Thank you.
From:
(USANYS) [mailto:
Sent: Thursday, August 1, 2019 3:11 PM
To: Michael Bachner
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Epstein investigation
/
Mike,
That would work -- we could do any time between 11 a.m. and 3 p.m. this coming Wednesday. What time should we
put in the calendar?
thanks,
From: Michael Bachner
Sent: Thursday, August 01, 2019 14:48
To:
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
Subject: RE: Epstein investigation
/
Wednesday ?
<image001.jpg>
<image002.jpg>
https://www.actl.com/
Michael Bachner, Esq.
Bachner & Associates, PC
39 Broadway, Suite 1610
New York, NY 10006
EFTA00030545

=== Page 4 ===
www.bhlawfirm.com
<image003.png>
CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic
Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally
privileged. If you are not the intended recipient, you are hereby notified that any retention,
dissemination, distribution, or copying of this communication is strictly prohibited. Please reply to the
sender that you have received the message in error and then delete it. Thank you.
From:
(USANYS) [mailto:
Sent: Wednesday, July 31, 2019 7:39 PM
To: Michael Bachner
Cc:
in
(USANYS)
Subject: RE: Epstein investigation /
Michael,
We wanted to follow up on our previous discussions and our meeting the week before last. Is there a good time for you
early next week to discuss status?
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00030546


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=== Page 1 ===
Event: Accepted: Epstein NY property
Start Date: 2020-07-16 17:30:00 +0000
End Date: 2020-07-16 18:00:00 +0000
Location: Skype Meeting; Conference ID: 612 758 867;
Class: X-PERSONAL
Comment:
Date Created: 2020-07-16 15:12:14 +0000
Date Modified: 2020-07-16 15:12:14 +0000
Priority: 5
DTSTAMP: 2020-07-16 14:51:48 +0000
Attendee: Weinstein, Marc A. <marc.weinstein@hugheshubbard.com>
EFTA00031303


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c0:
=== Page 1 ===
From:
To:
Subject: RE: Epstein/Maxwell Upload
Date: Fri, 09 Oct 2020 21:08:10 +0000
Inline-Images: image001.jpg
We will need to export the data from the database, but we will need to send a hard drive to the vendor as the file size of
the production will be too large to place on a FTP site for download. I would also suggest getting a hard drive from counsel
so you can copy the data on the hard drive. I can have the vendor start the export on Monday. Can you please see if you
can get a 1 TB drive to send to PAE so they can copy the production on the drive.
Thank you.
From:
=
Sent: Friday, October 9, 2020 4:59 PM
To:
;
Subject: RE: Epstein/Maxwell Upload
Thanks everyone. I would like to produce all the native files-are they all bates stamped and ready to go?
From:
>
Sent: Friday, October 9, 2020 4:57 PM
To:
is
is
is
is
Subject: RE: Epstein/Maxwell Upload
Hey
I leave it up to the AUSAs on your question regarding native files. The productions look good to me but I do have one
question. The drive that we sent to be uploaded contained about 41,000 files. In these two productions I only see a total
of about 22,000. Is that because there are some natives that couldn't be imaged and are thus not viewable on the
database?
Thanks,
From:
Sent: Friday, October 9, 2020 3:10 PM
To:
i
>;
is
is
Subject: RE: Epstein/Maxwell Upload
Hello,
All of the documents from this production has been bates stamped an is now available in Relativity for review. Please use
the following links below to review the production:
US V Epstein - SDNY_PROD008 - VOL-008 - https://d1pe.nss.pae.com/Relativity/go?id=1420850-2720682
US V Epstein - SDNY_PROD009 - VOL-009 - https://d1pe.nss.pae.com/Relativity/go?id=1420850-2731891
Please let me know if there are any issues with the production. Also, for this production please let me know if you would
like to produce all of the native files or only the native files that could not be imaged. Please note that for the native files
that could not be imaged there is a slip-sheet that says document produced natively and the file will be provided in native
format. Please let me know if there are any questions.
Thank you.
EFTA00030592

=== Page 2 ===
From:
Sent: Monday, October 5, 2020 10:20 AM
To:
>;
Subject: RE: Epstein/Maxwell Upload
Oh and would you also please save them here once they're exported
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Discovery\GM\05 Fifth Production\TO BE
PRODUCED
Thank you.
From:
Sent: Monday, October 5, 2020 9:43 AM
To:
is
Subject: RE: Epstein/Maxwell Upload
Thank you
Would you please start at bates number SDNY_GM_00328864 and mark all the documents confidential.
Thanks,
From:
Sent: Monday, October 5, 2020 9:37 AM
To:
is
Subject: RE: Epstein/Maxwell Upload
The below data has been loaded to Relativity and is available for review:
US V Epstein
FBI Case File
Images Seized During Search
2020-09-18
Evidence Images
Can you please let me know what bates number you want to use for this production and let me know if there will be a
confidential stamp placed on these documents.
Thank you.
From:
Sent: Tuesday, September 29, 2020 4:09 PM
To:
is
Subject: RE: Epstein/Maxwell Upload
Hey
Is there a timeframe for when these materials will be uploaded? And in turn, stamped and downloaded? Maurene is
looking for an update.
Thanks,
From:
Sent: Monday, September 21, 2020 9:25 AM
To:
is
Subject: RE: Epstein/Maxwell Upload
EFTA00030593

=== Page 3 ===
The data will be loaded to Relativity. I will take care of everything from this point forward regarding the drive and let you
know if I have any questions.
Thank you.
From:
Sent: Monday, September 21, 2020 9:22 AM
To:
is
Subject: RE: Epstein/Maxwell Upload
Hi
I hope you had a wonderful weekend! I was wondering if you had a chance to look over the hard drive that Brian made on
Friday. Do you have any ideas for how we should best proceed for producing? Is Relativity still our best bet?
Thanks so much!
From:
Sent: Friday, September 18, 2020 10:26 AM
To:
Cc:
>;
>;
is
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:
Sent: Friday, September 18, 2020 10:10 AM
To:
Cc:
>;
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.
Thank you.
From:
Sent: Thursday, September 17, 2020 4:54 PM
To:
Cc:
is
i
>;
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,
EFTA00030594

=== Page 4 ===
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
EFTA00030595


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=== Page 1 ===
From:
(USANYS)"
To: Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc: Mark Steward <Mark.Steward@fca.org.uk>
(USANYS)"
>, Kelly Eldred
<Kelly.Eldred@fca.org.uk>, Harry Caldecott <Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Date: Thu, 28 Nov 2019 15:57:25 +0000
To allow a few of my colleagues to join, can we instead use a dial in:
Thanks, and talk soon.
Sent from my iPhone
On Nov 28, 2019, at 10:31 AM, Kate Tuckley <Kate.Tuckley@fca.org.uk> wrote:
Great much appreciated thanks
From:
(USANYS) [mailto:
Sent: 28 November 2019 15:30
To: Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc: Mark Steward <Mark.Steward@fca.org.uk>;
(USANYS)
>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Okay, please call my cell:
Sent from my iPhone
On Nov 28, 2019, at 10:25 AM, Kate Tuckley <Kate.Tuckley@fca.org.uk> wrote:
Hi
I have spoken to Mark's business support and he is available at 4.15pm (UK time) today (ie in just
under an hour's time). It is quite urgent so if we could speak then it would be greatly appreciated.
If that does work please let us know what number to call you on?
Many thanks
From:
(USANYS) [mailto:
Sent: 28 November 2019 14:53
To: Mark Steward <Mark.Steward@fca.org.uk>
Cc:
(USANYS)
>; Kate
Tuckley <Kate.Tuckley@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
EFTA00030654

=== Page 2 ===
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Hi Mark - Thanks for reaching out. We do have an active investigation and would be happy to talk. As you likely know,
today is a holiday in the US. Is this something we could discuss on Monday or is it more urgent than that? Thanks, Ted
Sent from my iPhone
On Nov 28, 2019, at 9:28 AM, Mark Steward <Mark.Steward@fca.org.uk> wrote:
Dear
,
Can I ask whether this is still an active matter ? if so, I wonder if we could speak
when it is convenient.
Cheers
Mark Steward
Executive Director
Enforcement and Market Oversight
<image001.png>
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
<image002.png>
<image003.png>
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
From:
Sent: 28 November 2019 14:25
To: Mark Steward <Mark.Steward@fca.org.uk>;
(USANYS)
is
(USANYS)
Cc: Kate Tuckley <Kate.Tuckley@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Looping in
They run our
unit and oversee the Epstein case.
Sent from my iPhone
On Nov 28, 2019, at 8:30 AM, Mark Steward <Mark.Steward@fca.org.uk> wrote:
Hi
Can you let me know, urgently, whether anyone in your office is handling the investigation into
Jeffery Epstein, especially anything in relation to JP Morgan (he was a client of their private wealth
EFTA00030655

=== Page 3 ===
division) and, if so, who, as we need to have a chat. If this is not in SDNY, do you know who is
handling ongoing work into Mr E's world ?
Cheers
Mark Steward
Executive Director
Enforcement and Market Oversight
<image001.png>
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
<image002.png>
<image003.png>
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
This communication and any attachments may contain personal information. For more information about how and
why we use personal information and who to contact with any queries about this, please see our privacy notices:
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This communication and any attachments contain information which is confidential and may be subject to legal
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The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
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This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
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Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
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This communication and any attachments may contain personal information. For more information about how and
why we use personal information and who to contact with any queries about this, please see our privacy notices:
EFTA00030656

=== Page 4 ===
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
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This communication and any attachments contain information which is confidential and may be subject to legal
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email in error please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further
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The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
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communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
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Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
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This communication and any attachments may contain personal information. For more information about how and
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privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
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rely on or otherwise use it without our consent. Some of our communications may contain confidential information
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please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further information on
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info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email
has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
EFTA00030657

=== Page 5 ===
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how
and why we use personal information and who to contact with any queries about this, please see our privacy
notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have
received this email in error please notify postmaster@fca.org.uk immediately and delete the email from your
computer. Further information on the classification and handling of FCA information can be found on the FCA
website (http://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the
Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor
all email communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships.
This email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No.
8970864. Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
EFTA00030658


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c0:
=== Page 1 ===
From:
)"
To:
)"
)"
Subject: FW: travel approval request
Date: Thu, 13 Feb 2020 06:24:16 +0000
Embedded: Booking_Confirmation
--Beverly_Hills,_Feb_25.msg
Team, just as an FYI, no obligation at all for anybody else to do this, but I switched my L.A. hotel to a different spot for our
upcoming visit - at least through our booking systems, the DoubleTree in Santa Monica during that time is over our
allowable daily price for whatever reason - but even more importantly, last time we were there the front desk told me
that construction there was going to be a complete nightmare from January through at least March (i.e., all the drilling
from last time, but much worse). And I didn't see any other normal / decent business hotels in that area that were within
our per diem (with the possible exception of the Le Meridien).
However, for the first time in any of the trips we've ever been out there, the Beverly Hilton is listed within our per diem
($181 for the AUSAs), and it's less than a ten minute drive from both
attorney's office and
attorney's
office (and we could of course get a conference room there for
). It's not the fanciest hotel in the world, but it's a
normal Hilton, the location is perfect, and no drilling (!), so I went for it and wanted to recommend it and let everybody
know. No worries if people prefer elsewhere, but it's an option.
From:
Sent: Thursday, February 13, 2020 01:15
To:
Cc:
in
Subject: FW: travel approval request
just FYI, in connection with this trip to Los Angeles, I just made a reservation for a hotel on E2 (see attached) - if I
did anything wrong, it can be changed, but it's a hotel that is almost never available for us so I wanted to make the
reservation tonight just in case. And will follow up with flights in the coming days. Happy to chat if that's useful, and
thanks very much.
From:
Sent: Wednesday, February 12, 2020 22:55
To:
Cc:
is
is
(
Subject: Re: travel approval request
Approved
Sent from my iPad
On Feb 12, 2020, at 9:14 PM,
)
wrote:
EFTA00029670

=== Page 2 ===
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for three interviews in Los Angeles on February 26, 27, and 28 (we have at
least one interview on each of those days). We expect to be traveling, respectively, some combination of the 25th to the
29th. Also similar to prior trips, we'd like to request approval to get a conference room for one of those dates (the
26th).
thank you,
EFTA00029671


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=== Page 1 ===
From:
Subject: Title documents
Date: Fri, 20 Dec 2019 14:28:40 +0000
Attachments:(NY_Residence_Title_Transfer)_Title_Documents_Jade_Data_Research_9_EAST_71ST_S
TREET,_NEW_YORK,_NY.pdf;
(VI_Residence_Title_Transfer)_2011009441_Deed_12232011_Little_St_James_LSJ_LLC
and_Nautilus_Inc.pdf;
(Palm_Beach_Residence_Title_Transfer)_nv_162_18854529_img_12232011_Deed_Epstein
_to_Laurel_Inc.pdf;Maple_Inc.pdf; Nautilus_Inc_USVI_Corporation_Records.pdf;
Laurel_Inc.pdf; NY_Dept_St_Corp_Recs_Nine_East71.pdf;Nine_East71.pdf
As discussed, attached are the title transfer documents we have for Epstein's New York, Palm Beach, and Virgin Islands
residences. I've also included the articles of incorporation for four of the relevant entities referenced in the transfer
documents. It appears that we obtained at least some of these documents pursuant to grand jury subpoenas. Let me
know if you need us to distinguish between the documents that we found through without a subpoena and those we
obtained via subpoena.
We do not have documents for the New Mexico property, as far as I can tell, but I'll chat with the team about tracking
those down. Please let us know if there are any other materials you need us to find as well.
Thanks,
EFTA00030125


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=== Page 1 ===
From:
"
)"
To: "Weinstein, Marc A." <marc.weinstein@hugheshubbard.com>
Subject: Accepted: Epstein NY property
Date: Thu, 16 Jul 2020 15:43:22 +0000
Importance: Normal
Attachments: unnamed
EFTA00031304


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=== Page 1 ===
From:
"
)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: RE: Epstein
Date: Sun, 10 Feb 2019 00:16:14 +0000
Importance: Normal
Received, thanks - l'll reach out to them first thing Monday.
thanks again,
From:
(USANYS)
Sent: Friday, February 08, 2019 13:04
To:
)
Cc:
(USANYS)
is
(USANYS)
Subject: Fwd: Epstein
,
see below re the POC's at OPR for the Epstein case.
Thanks
Sent from my iPad
Begin forwarded message:
From:
"
(OPR)"
Date: February 8, 2019 at 12:43:39 PM EST
To:
(USANYS)"
Cc:
(OPR)"
i
(OPR)"
Subject: RE: Epstein
Thanks,
,
for reaching out and the contact info. Copying the primary attorneys handling the OPR matter.
Best,
Director and Chief Counsel
Office of Professional Responsibility
U.S. Department of Justice
Original Message
From:
(USANYS)
Sent: Friday, February 8, 2019 12:08 PM
To:
(OPR)
EFTA00031013

=== Page 2 ===
Subject: Epstein
Thanks for the chat today,
The SDNY point of contact for Epstein is AUSA
-
he can
be contacted at
and his number is
Thanks again
Sent from my iPad
EFTA00031014


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Subject: Re: Epstein investigation, prosecution memo
Date: Tue, 25 Jun 2019 02:57:28 +0000
Importance: Normal
Thanks
Sent from my iPhone
10,
EFTA00030159

=== Page 2 ===
V V V V V V V V VVVVVVVV
EFTA00030160


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=== Page 1 ===
From:
To:
Subject: Travel Authorization 10586231 approved by
, now awaiting further
approval
Date: Thu, 29 Aug 2019 22:11:35 +0000
Importance: Normal
Dear
Travel authorization 10586231 has been approved by
, now awaiting further approval.
Trip ID: 10586231
Traveler name:
Purpose: R19NYS13780 - U.S. V. Epstein - Witness Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-09-03 - 2019-09-04
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.
EFTA00031719


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
)"
Subject: Re: New Investigation
Date: Thu, 06 Dec 2018 23:04:05 +0000
Importance: Normal
Sorry I missed this. I am super annoyed. Just got out of mag court. Running home to feed the baby. But I am
around later tonight or tomorrow afternoon when I come back from white plains.
Sent from my iPhone
> On Dec 6, 2018, at 5:46 PM,
)
wrote:
>
>
Thanks for taking the time to meet today-attached are the documents we mentioned.
V
> From:
,
N. (NY) (FBI)
> Sent: Thursday, December 6, 2018 1:40 PM
> To:
i
> Cc:
)
(USANYS)
>
Subject: Re: New Investigation
>
>
I am still in NJ. I have everything we have downloaded to CD.
at the office. I can bring it when we meet.
>
>
>
V
>
>
V
Original message
> From:
> Date: 12/6/18 1:38 PM (GMT-05:00)
> To:
)"
<mailto:
> Cc:
)"
<mailto:
(USANYS)"
<mailto:
N. (NY) (FBI)"
<mailto:
> Subject: Re: New Investigation
>
> I'm in the proffer and do not have the disc with me. If I'm not mistaken
may still be in NJ. If I finish up
over here earlier then expected I'll ran back and grab it.
>
V
On Dec 6, 2018, at 12:59,
<mailto:
wrote:
> Hi all-looking forward to meeting this afternoon. If you're able to bring over a copy of the files on this case
(we'll take as much stuff as possible!), we'd really appreciate it. CD or drive are both fine.
V
> Thanks!
>
> From:
)
<mailto:
EFTA00031378

=== Page 2 ===
> Sent: Tuesday, December 4, 2018 7:19 PM
> To:
(USANYS)
<mailto:
N. (NY) (FBI)
<mailto:
> Cc:
)
<mailto:
> Subject: RE: New Investigation
>
> No worries at all, and I'll make 4:30 work.
>
>
> From:
,
> Sent: Tuesday, December 04, 2018 19:16
> To:
)
<mailto:
(USANYS)
<mailto:
N.
(NY) (FBI)
<mailto:
> Cc:
)
<mailto:
> Subject: Re: New Investigation
>
>
> I have child care issues in the mornings typically, and getting in by 11:00 is often difficult as I live in Suffolk
County. 4:30 works better for me. Sorry about that!
>
>
>
> Detective
V
> NYPD / FBI
>
>
Child Exploitation Human Trafficking Task Force
V
>
V V V V V
> From:
)
<mailto:
> Sent: Tuesday, December 4, 2018 7:06:28 PM
> To:
;
,
(USANYS);
N. (NY) (FBI)
> Cc:
)
> Subject: RE: New Investigation
I unfortunately have calls at 4:00 and 4:30. Could we do earlier before 11:00? I'm also concerned that if the
proffer ends up going late we'll be out of luck. Or I can move the 4:30 if
preferable for everybody. Sorry
about that.
V
V
V
V
V
> From:
EFTA00031379

=== Page 3 ===
> Sent: Tuesday, December 04, 2018 19:04
> To:
)
<mailto:
(USANYS)
<mailto:
>>;
N.
(NY) (FBI)
<mailto:
> Cc:
)
<mailto:
> Subject: Re: New Investigation
>
V
>
> 11:00 will not work for me. Me and
are good for 4:00 on Thursday though. The proffer should be done
by then.
V
>
V
> Detective
>
> NYPD / FBI
>
>
Child Exploitation Human Trafficking Task Force
V
>
V
V
V
> From:
)
<mailto:
> Sent: Tuesday, December 4, 2018 6:34:53 PM
> To:
;
,
(USANYS);
,
N. (NY) (FBI)
> Cc:
)
> Subject: RE: New Investigation
V
V
>
> Let's do Thursday, particularly since schedules seem to be tough next week.
would it make sense to meet
,
before your proffer, so we can have a specified time? We could meet at 11:00.
V V V V V V V V V
thanks,
> From:
,
> Sent: Tuesday, December 04, 2018 15:54
> To:
(USANYS)
<mailto:
>>;
,
N. (NY) (FBI) <
<mailto:
> Cc:
<mailto:
)
<mailto:
EFTA00031380

=== Page 4 ===
> Subject: Re: New Investigation
V
V
V
> Hey guys,
V
V
V
> Thursday I have a proffer at SNDY with SA
at 12:00. I can meet after that if you guys want depending
on how long this proffer goes. That may be the best option for us because Monday-Wednesday of next week we
may be tied up with a take down in the office.
>
>
V
> Detective
V
> NYPD / FBI
V
> Child Exploitation Human Trafficking Task Force
V
V
>
> From:
(USANYS)
<mailto:
,
> Sent: Tuesday, December 4, 2018 3:30:14 PM
> To:
N. (NY) (FBI);
> Cc:
);
)
> Subject: RE: New Investigation
>
V
>
> Thursday works for me.
V
V
V
V
Next week I am good Monday-Tuesday and Thursday-Friday.
V
V
V
> From:
N. (NY) (FBI)
<mailto:
> Sent: Tuesday, December 04, 2018 3:23 PM
> To:
(USANYS)
<mailto:
(
> Cc:
<mailto:
)
<mailto:
> Subject: RE: New Investigation
V
V
V
EFTA00031381

=== Page 5 ===
> Hey
V
V
V
> The only day I'd be free this week would be Thursday. Next Wednesday is not good, but any other day next
week I should be ok right now.
V
>
>
> I'm also working on putting everything we currently have onto a disk for you, so I should have that for you
when we meet.
>
>
V
> From:
(USANYS) [mailto:
> Sent: Tuesday, December 04, 2018 2:14 PM
> To:
N. (NY) (FBI)
<mailto:
,
W. (NY)
(OGA)
> Cc:
<mailto:
)
<mailto:
> Subject: RE: New Investigation
V
>
>
V
good speaking with you. I understand that you and
were just assigned the case yesterday and are
just starting to dig in. As we discussed I think it makes sense for us all to get into a room together son and chat.
>
V
V
>
When works for you guys?
V
>
>
> From:
(USANYS)
> Sent: Monday, December 03, 2018 5:51 PM
> To:
N. (NY) (FBI)
<mailto:
>;
W. (NY)
(OGA) (FBI)
> Cc:
<mailto:
>;
<mailto:
Subject: New Investigation
V V V V V V V V V V V V V
and
,
We got the package you dropped off today. Thank you. CC'ing the other members of the team on this email.
> Best,
EFTA00031382

=== Page 6 ===
> > > > > > > > > > > > > > > > > > > > >
Assistant United States Attorney
Human Trafficking Co-Coordinator
Violent & Organized Crime
Southern District of New York
<Palm Beach Police Reports.pdf>
<Epstein Blackbook.pdf>
> <Flight Logs.pdf>
EFTA00031383


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
Subject: RE:
Date: Mon, 20 Jan 2020 21:04:37 +0000
Attachments: Fed_Complaint.pdf
Yeah, we saw this on Friday and were a little frustrated not to have gotten the advance notice we had anticipated prior to
them filing. We contacted counsel on Friday and he apologized and said they've been particularly busy. So, yeah. But he
did send the complaint, which also has been filed on the docket, which presumably is where the Daily News found it (her
attorney was surprised there was media about it, so I think they didn't cause the story). Complaint is fairly bare-bones,
though it includes the Trump interaction she had with Epstein, and is attached here. No judge assigned yet.
From:
(USANYS)
Sent: Saturday, January 18, 2020 15:09
To:
is
is
Cc:
(USANYS)
Subject:
Looks like she filed a civil suit:
https://www.nydailynews.com/new-york/ny-epstein-trump-victim-suit-20200118-
m6sqsa2h7venpf5uewjrkvigo4-story.html
Sent from my iPhone
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From:
(USANYS)"
To:
)"
Subject: Vanity Fair: Just "Him and Epstein" and "28 Girls": Florida Man Drops a Dime on Trump
Date: Wed, 10 Jul 2019 16:43:57 +0000
Importance: Normal
Just "Him and Epstein" and "28 Girls": Florida Man Drops a Dime on Trump
Florida businessman George Houraney told the New York Times that the president's relationship with Jeffrey
Epstein involved at least one "calendar girl" party at Mar-a-Lago.
Read in Vanity Fair: https://apple.news/Awefdq1DmSzCEGW6gern3VQ.
Shared from Apple News
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From:
To: Sigrid McCawley
Subject: RE: Deposition Subpoena/Notice
Date: Mon, 13 Apr 2020 19:09:12 +0000
Thank you.
From: Sigrid McCawley
Sent: Monday, April 13, 2020 15:06
To:
Subject: FW: Deposition Subpoena/Notice
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
From: Daniel J. Kaiser [mailto
Sent: Monday, April 13, 2020 2:35 PM
To: Sigrid McCawley
Cc: Josh Schiller
; Sabina Mariella
Andrew Villacastin
Subject: Re: Deposition Subpoena/Notice
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
Her criminal lawyers have told me that until the criminal proceedings are done she is asserting her fifth amendment
rights. So if you want substantive testimony you will have to wait. Out of curiosity have any of your clients been criminally
pursued for their role in recruiting for Epstein? My client never did any recruiting which is far worst than anything she is
accused of. And in any event, mid-May given the current crisis will not work.
Dan
Daniel J. Kaiser
Kaiser Saurborn & Mair, P.C.
EFTA00030316

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On Apr 13, 2020, at 1:13 PM, Sigrid McCawley
wrote:
Hello Daniel,
Thank you for accepting service of the subpoena for
We will consider any suggestion you have with
respect to date and location of the deposition if you make them promptly, but we do not accept that you have the
unilateral right to dictate anything about the deposition-your client has an obligation to appear unless the Court
decides otherwise in response to a prompt motion by you.
Let me know if you have a different date in early to mid-May that you would like to propose.
Thanks,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
From: Daniel J. Kaiser [mailto]
Sent: Friday, April 10, 2020 5:31 PM
To: Sigrid McCawley
Cc: Josh Schiller
; Sabina Mariella
>; Andrew Villacastin
Subject: Re: Deposition Subpoena/Notice
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
I will accept service subpoena. I take no position at this time regarding the assertion of her Fifth Amendment rights. The
place and timing of any deposition must be coordinated with me and agreed to by me.
Dan
Daniel J. Kaiser
Kaiser Saurborn & Mair, P.C.
On Apr 10, 2020, at 5:03 PM, Sigrid McCawley
wrote:
EFTA00030317

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Hello Daniel,
It is my understanding that you now represent
and are willing to accept service of a subpoena on her
behalf. If I am incorrect, kindly let me know. It is also my understanding that she will no longer be asserting her 5th
Amendment Privilege. Accordingly, I am attaching a subpoena for her deposition and a Schedule A for documents that
we will need from Ms
in advance of her deposition.
Thank you,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information
that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of
this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication
in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1
08201831BSF
<2020-04-10 Depo Notice
May 7.pdf>
<2020-04-10 Subpoena & Schedule A to
Subpoena May 7.pdf>
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From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Re: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Order
Date: Mon, 03 May 2021 21:35:17 +0000
On May 3, 2021, at 5:31 PM,
(USANYS)
wrote:
Sent: Monday, May 3, 2021 5:31 PM
To:
(USANYS)
is
(USANYS)
Subject: Fwd: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Order
Begin forwarded message:
From:
Date: May 3, 2021 at 5:08:35 PM EDT
To:
Subject: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Order
This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-
mail because the mail box is unattended.
***NOTE TO PUBLIC ACCESS USERS*** There is no charge for viewing opinions.
U.S. District Court
Southern District of New York
Notice of Electronic Filing
The following transaction was entered on 5/3/2021 at 5:07 PM EDT and filed on 5/3/2021
Case Name:
USA V. Maxwell
Case Number:
1:20-cr-00330-AJN
Filer:
Document Number: 266
EFTA00031690

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Docket Text:
ORDER as to Ghislaine Maxwell: The Court concludes that the interests of justice justify
granting a short continuance. The Court deems an adjournment until fall 2021 to be
reasonable. Such an adjournment would plainly give the defense team sufficient time to
prepare for trial in light of the additional charges contained in the S2 indictment while also
ensuring that the trial proceeds without undue delay. No additional delay is necessary or in
the interests of justice. The parties are hereby ORDERED to meet and confer and by May 10,
2021, they shall jointly propose a trial start date for the Court to request of the Clerk's Office
(as is required by COVID protocols). The Court urges counsel to agree to the earliest
possible date this fall and to seek adjustments to other schedules in order to facilitate an
early fall trial start date. The parties shall also discuss and propose any adjustments
necessary to the pre-trial schedule in place. Dkt. No. 250. The Government may move in the
letter for any requested exclusion of time under the Speedy Trial Act. (Signed by Judge
J. Nathan on 5/3/2021) (See ORDER set forth) (ap)
1:20-cr-00330-AJN-1 Notice has been electronically mailed to:
David Boies, Il
Jeffrey S. Pagliuca
Laura A. Menninger
Bobbi C Sternheim
Christian R. Everdell
Mark Stewart Cohen
Sigrid S. McCawley
1:20-cr-00330-AJN-1 Notice has been delivered by other means to:
The following document(s) are associated with this transaction:
Document description:Main Document
Original filename:n/a
Electronic document Stamp:
[STAMP dcecfStamp_ID=1008691343 [Date=5/3/2021] [FileNumber=25827857-0
][4a307480cc7e6f2f2020ff660a38bbcba7c529e0be766a8787508885e07c744a8ea
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7502d615ae9675ee71d31cad1835f2b03d5c2dc9d22e6ed2c37398e757ac8]]
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=== Page 1 ===
From:
Subject: FW: FW: Requests
Date: Fri, 26 Jun 2020 14:39:46 +0000
Attachments: DOJ_Ethics_Handbook.pdf,July_2019_ICTpdf
Ah, some clarity. Do you think we should produce the DOJ Ethics Handbook, attached? Foy asked for the BOP Employee
Code of Conduct, which we now have and will be producing, and the (presumably BOP) Code of Ethics.
From:
Sent: Thursday, June 25, 2020 6:21 PM
To:
Subject: Re: FW: Requests
All,
I hope my responses below serve to clear up some of the issues you had with the documentation that was provided. I
continue to work to obtain the missing items and will send them as I receive any additional documents. Please let me
know if you have further questions and I'll be happy to address anything that is still unclear.
Many of the requests made, such as ICT agenda, cellmate policies and SHU policies are not one-stop-shops.
These issues are covered in a number of different policies, therefore I tried to include all policies that
reference those topics.
1. We received unsigned Word versions of Program Statements 5511.08 and 5500.13. Are there finalized versions?
Executive Assistant Lee Plourde handles the finalizing of the supplements. He's on leave and will
address this upon his return on Monday, June 29, 2020.
2. Why were we given the BOP Correctional Services Procedures Manual? Which of our requests is this responsive
to? Section 310 of this policy covers inmate accountability in the SHU. You requested 5511.08 and
this section in the CSPM overlaps some of those same policies.
3. Why were we given the BOP Suicide Prevention Program Statement? Which of our requests is this responsive to?
This policy covers staff training requirements for ICT and Quarterly SHU training. I included the
policy because it directly correlated with other requests.
4. We were also given a Powerpoint entitled Suicide Prevention for Inmates. Which of our requests is this responsive
to? When is this document from? The slide show is the Psychology portion of the SHU Training you
requested. It is dated 1/2/2014. I have requested an updated version that would have been used
more closely to the time of
assignment to SHU. I'm just waiting for Psychology staff to
provide me whatever it is they used at that time.
5. We were provided a document titled Introduction to Correctional Techniques from January 2020. Which of our
requests is this responsive to? Is it the MCC institutional familiarization training outline? If so, we would request
one from a time when the defendants were actively employed at MCC (so before August 2019). This is the
Institutional Familiarization (IF) outline you requested. It hasn't been called IF for a few years. It
is now Introduction to Correctional Techniques (ICT). An earlier version is attached here.
6. We were provided with an undated slide presentation about the MCC SHU. Which of our requests is this
responsive to? When is this document from? The slide show was created 1/2/2014 as a part of
quarterly SHU training. The quarterly SHU training is primarily conducted through the BOP's online
training platform that is a self-guided course that covers a number of topics related to SHU. The
official SHU training course is not something I can send or save due to the nature of the course
being automated by the training platform and not a hard file.
7. The BOP Code of Ethics is highlighted below. Which document is this? Program Statement 3420.11 is the
Standards of Employee Conduct, which covers the dos and don'ts of employment in the BOP. I've
attached the DOJ Ethics Handbook here. If there is something specific you're looking for, please let
me know.
8. We received digital lieutenant's logs. Is there also a hard copy book? There is no hard copy book of these
logs. The logs are saved to a shared folder at the end of each shift. Although I have worked at
EFTA00030777

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places that print each log, the Lieutenant's here at NYM reported that that is not the practice here.
The LTs here email their logs to the executive staff at the conclusion of each 24 hour period for
review purposes. Thus, eliminating a hard copy record system.
9. We were provided with a document called "SHU Logs MW" and a document called "SHU Logs." Can we confirm
what these are? Our requests were for SHU Watch Call Logs and SHU Control Center Logs. Those are the
digital log books from SHU for the Evening and Morning Watch shifts during the requested time
period. I am working on obtaining the actual Watch Call tracking sheets from the main Control
Center at MCC which is something different. However, the officer should be logging their watch
calls into the digital log book every 30 minutes between 6a - 6p each day.
10. Which document contains the BOP and MCC policy on SHU quarterly training, which is highlighted below as
having been provided? PS 5270.11 as well as the Suicide Prevention policy covers the SHU quarterly
training requirement. There is not a separate policy for that.
11. We asked for P.S. 5270.10, but got P.S. 5270.11. Was P.S. 5270.10 provided to us in error? Or was our request
incorrect? 5270.10 does not exist. 5270.11 is the policy covering SHU.
12. Which document contains the BOP and MCC policy on cellmates? I am not aware of any such policy and
have struggled to find even a mention of it in the policies I've reviewed. I will continue to search
for a policy that references cellmate assignments.
13. In the second email, there is a document called "Hot Lists" dated August 30, 2019. Which of our requests is this
responsive to? The "Hot List" is the high risk list. Any inmate on that list who goes to SHU requires
immediate notification to Psychology. This is the only "high risk" list the BOP has and I provided it
in response to your request for "All High Risk Lists reviewed during weekly SHU meetings..."
14. In the second email, Cody mentioned that most of the control center paperwork was seized by FBI and/or OIG.
Do you or FBI have that paperwork? Has it been provided to us?
15. Finally, what is the status of the remaining requests? As I continue to work from home, I have not
personally been able to physically search for the Watch Call sheets. As I previously mentioned,
those logs were reportedly seized early on in this investigation. I continue to follow up on this.
With regard to the SROs, those reviews are only electronically available for inmates who are
currently in SHU and only for the period of their most recent admission to SHU. SROs, assuming
they were completed, would then be printed and filed in the inmate's central file. I am currently
trying to figure out where Epstein's file is to see if any SROs are in it. If you really want ALL SROs
for the period of
assignment to SHU, that will be an extremely lengthy process of tracking
down inmate files, many of whom have released from the BOP or been transferred to any number
of institutions across the country, and then requesting any SROs from the specified period of time
that are contained in those files be scanned to us. I'm guessing Epstein's file was taken along with
all of the other documentation shortly after his death, but I have not confirmed that yet.
Special Investigative Agent
MCC New York
150 Park Row
New York, NY 10007
06/25/20 12:35 PM
Cody:
Can you please address the questions/discrepancies noted below. Much appreciated.
From:
Sent: Thursday, June 25, 2020 12:30 PM
To: Daza,
Subject: RE: Requests
/
EFTA00030778

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Some follow up questions related to these materials:
1. We received unsigned Word versions of Program Statements 5511.08 and 5500.13. Are there finalized versions?
2. Why were we given the BOP Correctional Services Procedures Manual? Which of our requests is this responsive
to?
3. Why were we given the BOP Suicide Prevention Program Statement? Which of our requests is this responsive to?
4. We were also given a Powerpoint entitled Suicide Prevention for Inmates. Which of our requests is this responsive
to? When is this document from?
5. We were provided a document titled Introduction to Correctional Techniques from January 2020. Which of our
requests is this responsive to? Is it the MCC institutional familiarization training outline? If so, we would request
one from a time when the defendants were actively employed at MCC (so before August 2019).
6. We were provided with an undated slide presentation about the MCC SHU. Which of our requests is this
responsive to? When is this document from?
7. The BOP Code of Ethics is highlighted below. Which document is this?
8. We received digital lieutenant's logs. Is there also a hard copy book?
9. We were provided with a document called "SHU Logs MW" and a document called "SHU Logs." Can we confirm
what these are? Our requests were for SHU Watch Call Logs and SHU Control Center Logs.
10. Which document contains the BOP and MCC policy on SHU quarterly training, which is highlighted below as having
been provided?
11. We asked for P.S. 5270.10, but got P.S. 5270.11. Was P.S. 5270.10 provided to us in error? Or was our request
incorrect?
12. Which document contains the BOP and MCC policy on cellmates?
13. In the second email, there is a document called "Hot Lists" dated August 30, 2019. Which of our requests is this
responsive to?
14. In the second email, Cody mentioned that most of the control center paperwork was seized by FBI and/or OIG. Do
you or FBI have that paperwork? Has it been provided to us?
15. Finally, what is the status of the remaining requests?
Please work on this as quickly as you can. Thanks!
From: Daza,
Sent: Tuesday, June 23, 2020 3:59 PM
To:
is
Cc:
Subject: FW: Requests
fyi
From:
Sent: Tuesday, June 23, 2020 3:53 PM
To: Daza,
Cc:
Subject: Re: Requests
I've attached all the documentation I have pertaining to the below request. I am waiting for a few things from HR and
Psychology but wanted to send you what I have right now. I highlighted the items below that are attached in this email.
Let me know if you have any questions.
Special Investigative Agent
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=== Page 4 ===
MCC New York
150 Park Row
New York, NY 10007
06/12/20 1:54 PM >>>
Hi Cody:
Hope you and fam have been well, as well as MCC staff.
Can you please provide the following information concerning the Epstein suicide investigation:
The BOP and MCC Employee Code of Conduct, Code of Ethics, and corresponding employee acknowledgement
forms for Defendant Noel.
The MCC institutional familiarization training outline.
The BOP and MCC policy on cellmates and local Institutional Supplement on Special Housing Unit Regulations,
including Institutional Supplement/Program Statement Number P.S. NYM 5270.10.
The BOP and MCC policy on SHU quarterly training.
The Inmate Accountability Institutional Supplement/Program Statement, Number I.S. NYM 5511.08.
The Security Inspections Institutional Supplement/Program Statement, Number I.S. NYM 5500.13.
SHU Watch Call Logs from August 9, 2019 and August 10, 2019.
All SHU Watch Call Logs completed during Defendant
assignment to the SHU post which began on June 26,
2019.
All SHU Control Center Logs completed during Defendant
assignment to the SHU post which began on
June 26, 2019.
All SHU Operations Lieutenant Log Books completed during Defendant
assignment to the SHU post which
began on June 26, 2019.
All High Risk Lists reviewed during weekly SHU meetings during Defendant
assignment to the SHU post
which began on June 26, 2019.
All SHU reports and SRO reviews completed by the SHU Lieutenant during Defendant
assignment to the SHU
post which began on June 26, 2019.
Many thx!
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=== Page 1 ===
From: Jean James
To:
Cc: washington field
, newyork
Subject: JEFFREY EPSTEIN et al
Date: Wed, 17 Jul 2019 13:08:25 +0000
Dear Mr. Berman
Further to my email of yesterday, I have come across some notes that someone sent me in February
regarding North Yorkshire Police and child procurer for the elite, Jimmy Savile. The informant mentions
ex Surrey Police officer, Mark Williams-Thomas, who is now a well-respected and reputable
investigative journalist who has written several books.
http://www.williams-thomas.co.uk/
https://www.mirror.co.uk/news/uk-news/jimmy-savile-investigator-claims-two-13510102
As a police officer, he specialized in major crime and child abuse. I am told that Surrey police DID
investigate allegations against Jimmy Savile but they could not pin anything on him, partly due to
North Yorkshire Police not disclosing the information that they had on him. Mr. Williams-Thomas might
be a helpful contact, particularly with regard to North Yorkshire Police obstruction in child abuse
investigations.
Also, if you managed to listen to the YOUTUBE interview with ex MI5 operative and now barrister,
Michael Shrimpton, he alleges that Thames Valley Police, whom I believe also obstructed the
international Project Spade, Toronto-led investigation, has (or had), German operatives (or spies)
embedded in Thames Valley Police. Peter and Barbara Hofschroer, were seriously abused by the
criminal activities of North Yorkshire Police. There are strong indications that North Yorkshire Police
have close allies at extremely senior levels, in both the Austrian and German police, and the Austrian
judiciary. I cannot say what, exactly, but have seen the results of obvious transnational criminal
collusion.
Regards,
Yours sincerely,
Jean James
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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
(USANYS)"
Subject: Re: Jeffrey Epstein/FOIA matters
Date: Tue, 16 Mar 2021 22:09:03 +0000
Hi
,
Just following up to see if you found out anything from the civil clerks. Thanks for your help with this.
Best,
On Mar 12, 2021, at 11:22 AM,
)
wrote:
Thanks,
Much appreciated.
From:
(USANYS)
Sent: Friday, March 12, 2021 11:18 AM
To:
Cc:
>;
(USANYS)
>;
(USANYS)
Subject: Re: Jeffrey Epstein/FOIA matters
Hi
I am copying
who is handling the main matter before Judge Engelmayer and who likely
would know if there are related FOIAs. I will also ask our civil clerk.
Sent from my iPhone
On Mar 12, 2021, at 10:59 AM,
)
wrote:
Hi
In connection with a criminal discovery matter,
and
and I are trying to find a list of all Jeffrey Epstein-
related FOIA lawsuits that the Civil Division has handled (either pending or historical). Our chiefs suggested that you
might be able to help us generate that list - if you have any guidance or information on how we could track this down,
we'd really appreciate your help. Or if there's someone else we should reach out to in the Civil Division instead, please
let us know.
Thanks so much-
EFTA00031587

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Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
U.S. V. Ghislaine Maxwell
MAXWELL HAS BEEN ARRESTED FOR ALLEGED
FACILITATING OF SEX ABUSE OF UNDERAGED GIRLS
FOR JEFFREY EPSTEIN.
THE CHARGED CONDUCT OCCURRED IN NEW YORK CITY,
PALM BEACH, FLORIDA, SANTA FE, NEW MEXICO, AND
LONDON, ENGLAND.
IF YOU RECOGNIZE EITHER OF THESE PERSONS AND
FEEL YOU MAY BE A VICTIM, PLEASE CALL THE
FOLLOWING NUMBER:
1-800-CALL FBI
SISTETIA OF
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U.S. V. Ghislaine Maxwell
Properties Owned by Epstein Where Alleged
Grooming and/or Abuse of Minor Victims Occurred:
New York, New York
Palm Beach, Florida
Santa Fe, New Mexico
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=== Page 1 ===
FINANCIAL INTELLIGENCE UNIT
To:
Law Enforcement Agent Requesting SAR Backup Documentation
From:
Raymond Duncan, Vice President - Financial Intelligence Unit
Cc:
Scott McFarland, Director - Financial Intelligence Unit
Subject:
Supporting Documentation for Cardholder/Merchant Data Prepared for
Law Enforcement
*Disclaimer: the information provided in the accompanying spreadsheets and described below is
provided solely for aiding investigation purposes and does not represent official American
Express data from the respective systems of record. Official documents are maintained and have
been/will be provided upon request.
1) TABLE OF CONTENTS
American Express Card Account Organization
1
Card Data Format
2
Prepaid Card Account Organization
3
Reloadable Card Data Format
3
Prepaid Gift Card Data Format
5
Merchant Account Organization
6
Merchant Data Format
6
Personal Savings Account Organization
8
Personal Savings Account Data Format
8
2) AMERICAN EXPRESS CARD ACCOUNT ORGANIZATION
Every American Express credit and charge card has a unique fifteen-digit number ("Card
Number"). The first eleven digits of this number identify the credit card account ("Card Member
Account") to which this card belongs. For each Card Member Account there is a primary card
member who is responsible for paying the balance on all of the supplemental cards associated
5/14/2019
AXP Restricted
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with the account. Up to 99 supplemental cards may be associated with a single account. If a
primary card member has 10 supplemental cards, all 11 cards would have the same first 11
numbers. The last four digits of the 11 respective card accounts would be different.
3) CARD DATA FORMAT (EXCEL SPREADSHEET TABS)
For investigation purposes only, the Financial Intelligence Unit divides internal data on card
members into several major categories: Demographic Information ("Demo"), Address,
Telephone, Record of Charges ("ROC"), Payment, Wire Payments, Returned Payment, Airline,
and IP Address. This data is displayed in the accompanying Excel spreadsheets with each
category occupying its own tab. Within each tab, the relevant information is organized by
labeled columns. If there is no information to report in a particular category, the tab will simply
not appear on the spreadsheet. A general overview of the information within each tab is provided
below.
A. DEMO
The Demo tab identifies account details and demographic information for both charge and/or
credit card accounts, listing (where available) the cardholder's name, date of birth, and social
security number as well as information about the particular credit card product (Gold, Platinum,
etc.).
B. ADDRESS
The Address tab identifies all the addresses that have been associated with each credit card and
identifies the type of address (home, business, etc.).
C. TELEPHONE
The Telephone tab identifies all the telephone numbers that have been associated with each
credit card and identifies the type of number (Home, Business, ANI). An ANI number is a
phone number from which the card member or another individual called an American Express
customer service center about the subject account. The number is captured automatically and the
date on which the call was made is provided.
D. ROC (Record of Charges or Spend)
The ROC tab identifies all completed charges (including credits/returns) a credit card has made
over the past five years. The tab identifies the date and amount, in U.S. Dollars, of the charge.
In addition, the tab identifies the merchant at which the charge was made (the unique merchant
account number, legal and d/b/a name as well as address and industry type).
E. AUTHORIZATION REQUEST ("CAS")
The CAS tab identifies all the credit requests a credit card has made over the past one year.
Every time a card is swiped or keyed into a card reader, a request for credit is sent to American
Express and an approval code is returned. The request may be approved, denied, or pended. It is
important to remember that while 90% of all credit requests are charged exactly as requested,
some credit requests are not charged in the same amount or on the same day. For example, when
booking a hotel room for four nights, your credit card is swiped and the amount of a four-night
5/14/2019
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stay is requested; however, your card is not charged at that time but rather at the time of check-
out, at which time your bill might be for more or less than the original credit request. This tab
also identifies whether the payment attempt was made by swiping or keying the card (keying
includes internet and phone charges).
F. PAYMENT
The Payment tab identifies all the payments that have been made against a credit card balance,
including dates and amounts, and (where available) information on the bank account on which
the payment was drawn.
G. RETURNED PAYMENT
The Returned Payment tab identifies payments that have been posted against a credit card
balance and subsequently returned to the payment source.
H. AIRLINE
The Airline tab identifies airline ticket charges incurred on a credit card account and contains
information provided at the time of purchase, including the passenger's name, departure date,
origin airport, and destination airport. Connecting flight information, if applicable, is generally
available in the "Itinerary" column.
I. IP ADDRESS
The IP Address tab identifies internet protocol address information captured by American
Express systems during online account activity (including some purchases, payments, and
account changes). If an e-mail was sent through the American Express website, the e-mail and
the IP address from which the customer logged in may have been captured. If a customer
purchased an item online using an American Express card and provided the merchant with an e-
mail address as the point of contact, that address may also appear in this tab.
4) PREPAID CARD ACCOUNT ORGANIZATION
Every American Express prepaid card has a unique fifteen-digit number ("Card Number" or
"CM15"). Reloadable prepaid card products allow a cardholder to add funds to the account, and
some may be used to make ATM withdrawals, transfer money, and write checks. Prepaid card
products also include gift cards, which are predenominated and not reloadable. Some prepaid
products offer sub-accounts, which are established under the primarily, or "master" account for
another person age 13 or older. The sub-account is linked to, funded by, and controlled by the
master accountholder.
5) RELOADABLE PREPAID DATA FORMAT (EXCEL SPREADSHEET TABS)
For investigation purposes only, the Financial Intelligence Unit divides internal data on prepaid
members into several major categories: Demographic Information ("Demo"), Address,
Telephone, Peer to Peer Transactions ("P2P"), IP Address, Card Transactions, BillPay
Transactions, Airline Transactions, Funds Load, Withdrawals, Disputes, and Customer Service
Notes.
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=== Page 4 ===
The Financial Intelligence Unit divides internal data on other prepaid card members into several
major categories: Sale Info, Demographic Information ("Demo"), Redemptions ("OR_REDE"),
Authorizations ("OR_AUTH"), Web Balance Inquiry ("OR_WEBBAL"), Direct Deposits, IVR
Inquiry, and Airlines.
This data is displayed in the accompanying Excel spreadsheets with each category occupying its
own tab. Within each tab, the relevant information is organized by labeled columns. If there is no
information to report in a particular category, the tab will either be blank or not appear on the
spreadsheet. A general overview of the information within each tab is provided below.
A. DEMO
The Demo tab for prepaid accounts associates an account with an individual, listing (where
available) their name, date of birth, social security number, and email address, as well as
information about the specific product, account status, and account type (Master, Sub, or
PurposeDriven (a savings account, which is linked to a master account)).
B. ADDRESS
The Address tab identifies all addresses that have been associated with each account, and
identifies the type of address (home, business, etc.).
C. TELEPHONE
The Telephone tab identifies all telephone numbers that have been associated with each account,
and identifies the type of number (Home, Mobile, Business, ANI, etc.). An ANI number is a
phone number from which the card member called an American Express customer service center.
The number is captured automatically and the date on which the call was made is provided.
D. P2P
The P2P tab provides information on all P2P transfers (transfers between prepaid accounts) sent
and received by a particular prepaid account, including account information for all senders and
recipients.
E. IP
The IP Address tab identifies internet protocol address information captured by American
Express systems during online account activity.
F. CARD TRANSACTIONS
The Card Transactions tab provides information (amount, date, time, and location) on all
transactions conducted using a prepaid account, including purchases, refunds, and ATM
withdrawals. For purchases, the tab identifies the merchant where the card was redeemed.
G. BILLPAY TRANSACTIONS
The BillPay tab provides information on bills (e.g. credit cards, utilities, rent, etc.) paid by a
customer using their prepaid account, including the date, transaction amount, and payee name.
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=== Page 5 ===
H. AIRLINE TRANSACTIONS
The Airline tab identifies airline ticket charges and contains information provided at the time of
purchase relating to the departure date, originating airport, destination airport, and passenger
names.
I. FUNDS LOAD
The Funds Load tab provides information on when, where, and how a prepaid account was
funded (e.g. cash, direct deposit, credit/debit card load, etc.). Note - because in some instances
the data is maintained by a third party, some credits labeled "cash" may not actually have been
made via cash payment. For additional questions, please reach out to the Financial Intelligence
Unit.
J. WITHDRAWALS
The Withdrawals tab provides information on money withdrawn from a prepaid account via
check or ACH transfer, including the date, transaction amount, and transaction status, as well as
the bank name, account number, and routing number (where applicable).
K. DISPUTES
The Disputes tab includes information on transactions disputed by the prepaid accountholder,
including the dispute date, amount, reason, and resolution.
L. CUSTOMER SERVICE NOTES
The Customer Service Notes tab consists of notes recorded by customer service representatives,
and often includes information regarding customer phone calls, promotional offers, changes to
demographic information, and changes in account status.
6) PREPAID GIFT CARDS DATA FORMAT (EXCEL SPREADSHEET TABS)
A. DEMO
The Demo tab for prepaid gift cards associates a prepaid card with an individual, and may, in
limited circumstances, list their name, date of birth, social security number, address, phone
number, and email address, as well as information about the product type (e.g. reloadable or
single load) and the card status.
B. SALE INFO
The Sale Info tab explains when and where each prepaid card was purchased, as well the original
load value.
C. TRANSACTIONS
The Transactions tab identifies transactions conducted using a prepaid card, including purchases,
refunds, value loads, promotional credits, and maintenance fees. When money is added to a
prepaid card, the amount will appear under "redeem amount" as a negative number (for example,
a value load of $500.00 would be notated as -$500.00).
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=== Page 6 ===
D. AUTHORIZATIONS
The Authorizations tab identifies authorization requests submitted by prepaid cards, and whether
these requests were approved or denied (due to insufficient funds, for example). This tab also
identifies whether the payment attempt was made by swiping or keying the card (keying includes
internet and phone charges).
E. DIRECT DEPOSIT
The Direct Deposit tab provides additional information regarding value loads to the account
made via direct deposit, including the business name and the employee name associated with the
deposit.
F. WEB BALANCE INQUIRY AND IVR INQUIRY
The Web Balance and IVR ("Interactive Voice Response") Inquiry tabs indicate when a
customer logs in online to review their account and when customer calls in to review their
account, respectively.
G. AIRLINES
The Airline tab identifies airline ticket charges and contains information provided at the time of
purchase relating to the departure date, originating airport, destination airport, and passenger
names.
7) AMERICAN EXPRESS MERCHANT ACCOUNT ORGANIZATION
Merchant accounts are established for businesses that accept American Express cards, and each
established merchant account is issued a unique ten-digit number ("merchant account number" or
"SE10"). Please note that "SE" is frequently used as a synonym for "merchant"; SE stands for
"Service Establishment." Merchant accounts are associated with an authorized signer and a
corresponding bank account. The authorized signer serves as the point of contact for the
merchant account, and that individual's identifying information is stored in internal American
Express systems, along with the bank account number provided to American Express at account
opening.
8) MERCHANT DATA FORMAT (EXCEL SPREADSHEET TABS)
For investigation purposes only, the Financial Intelligence Unit divides internal data on merchant
accounts into several major categories: Demographic Information ("SE Demo"), Record of
Charges ("SE ROC"), Authorization Request ("SE CAS"), Merchant Fraud ("SE Fraud"),
Merchant Billed ROC ("SE Billed Roc"), Merchant IP ("SE IP"), and Merchant Disputes ("SE
Disputes"). This data is displayed in the accompanying Excel spreadsheet with each category
occupying its own tab. Within each tab, the relevant information is organized by labeled
columns. If there is no information to report in a particular category, then the tab will simply not
appear on the spreadsheet. A general overview of the information within each tab is provided
below.
I The availability of bank account information varies for international merchants.
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=== Page 7 ===
A. MERCHANT DEMO (SE DEMO)
The Merchant Demo tab lists the unique merchant account number, the legal name of the
business, as well as a Doing Business As name (where available). In cases where the merchant
relationship is not proprietary (i.e., a Seller or Location merchant), additional merchant data will
be provided in the tab. If the merchant is a Seller Merchant (that is, a third-party merchant
account that contracts with an "aggregator merchant" that contracts directly with American
Express to bring merchants to the American Express network), then "Seller" will appear under
the "Searched Merchant Type" field. If the merchant is a sub-merchant (i.e., acquired under a
third party payment processor such as Paypal or Square), then "Location" will appear under the
"Searched Merchant Type." The Merchant Demo tab also provides the reported address and
telephone number for the business, as well as the name and social security number of the
authorized signer(s) on the account. This tab further provides a correspondence address for the
business, a general industry description of the business, and an indication of whether the account
is open or closed.2 Finally, the bank account number (if available based on merchant type3) and
corresponding routing number for each merchant account is listed in the last column to the right
in the Merchant Demo tab of each spreadsheet.
B. MERCHANT ROC (SE ROC - RECORD OF CHARGES OR SPEND AT THE
MERCHANT)
The Merchant ROC ("Record of Charge") tab identifies all completed American Express charges
processed by the merchant. The tab identifies the timestamp and amount, in U.S. dollars as well
as the local amount (if outside of the U.S.) of each charge processed by the merchant. In
addition, the tab lists the card number and the name of the cardholder that made the purchase, as
well as some demographic information regarding that cardholder and card (including, but not
limited to, the cardholder's name, the card type and issuer).
C. MERCHANT AUTHORIZATION REQUEST (SE CAS)
This tab lists all credit authorizations sent by the merchant over the past two years. Every time a
card is swiped or keyed into a card reader, a request for credit is sent to American Express and an
approval code is returned. The request may be approved, denied, or pended. This tab identifies
whether the merchant processed the transaction by swiping or keying the card (keying includes
internet and phone charges, while swiping typically indicates that the cardholder was physically
present at the merchant at the time of the transaction).
D. MERCHANT FRAUD (SE FRAUD)
This tab identifies all transactions processed by the merchant that were ultimately reported as
fraudulent by a respective American Express cardholder.
E. DISPUTES (SE DISPUTES)
The Disputes tab identifies all initiated charge disputes against a given merchant and the status of
individual disputes.
F. MERCHANT BILLED ROC (SE BILLED ROC)
2 In the case of Seller and Location merchants, the status information reflects that of the Submitting merchant, and
not the sub-merchants.
3 Bank account information is not available for Seller and Location merchants.
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EFTA00030213

=== Page 8 ===
The Merchant Billed ROC tab identifies all completed American Express charges processed by
the merchant over the past five years. The tab identifies the date and amount, in U.S. dollars, of
each charge processed by the merchant. In addition, the tab identifies the date and amount of the
transaction, the card number and the name of the cardholder that made the purchase, as well as
information regarding that cardholder (In the case of the merchant accounts pulled for the Texas
Attorney General's Office, please note that due to the size of some of the spreadsheets, the
BILLED_ROC tab was not included. The majority of transactions will appear in the ROC tab).
G. IP ADDRESS (SE IP)
The IP tab identifies internet protocol address information captured by American Express
systems during online account activity.
9) PERSONAL SAVINGS ACCOUNT ORGANIZATION
American Express National Bank issues High-Yield Savings accounts ("HYSAs") and
Certificates of Deposit ("CDs") to individuals. HYSAs and CDs are both referred to as Personal
Savings Accounts ("PSAs"). Every PSA has a unique ten-digit or twelve-digit account number
and may have up to two account holders - a primary account holder and a secondary account
holder. Each account holder has a unique customer identification number ("Customer ID") and
has equal access to the PSA.
10) PERSONAL SAVINGS ACCOUNT DATA FORMAT (EXCEL SPREADSHEET
TABS)
For investigation purposes only, the Financial Intelligence Unit divides internal data on PSA
account holders into several major categories: Demographic Information ("Demo"), Address,
Notes, Stop-Holds, Transactions, IP Address, and Linked Accounts.
This data is displayed in the accompanying Excel spreadsheets with each category occupying its
own tab. Within each tab, the relevant information is organized by labeled columns. If there is no
information to report in a particular category, the tab will either be blank or not appear on the
spreadsheet. A general overview of the information within each tab is provided below.
A. DEMO
The Demo tab for PSAs associates an account holder with the Customer ID, account number,
account type, name, date of birth, social security number, employer, job title, income, as well as
the account status, open and close dates, and maturity or renewal dates for CDs, as applicable.
B. ADDRESS
The Address tab lists all addresses, phone numbers, and email addresses that have been
associated with each account holder, and identifies the types of addresses (e.g., mailing,
permanent, etc.) and phone numbers (e.g., home, cell, etc.).
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EFTA00030214

=== Page 9 ===
C. NOTES
The Notes tab consists of notes recorded by customer service representatives, and often includes
information regarding customer phone calls, changes to demographic information or account
status, information regarding wire transfers, and returned transactions.
D. STOP-HOLDS
The Stop-Holds tab identifies deposits made to a PSA and their applicable hold period before the
funds are available for withdrawal.
E. TRANSACTIONS
The Transactions tab provides information and dates for deposits, withdrawals, earned interest,
internal transfers, account balance of the PSA(s), the method used to make the transactions, and
external account numbers where available.
F. IP
The IP Address tab identifies internet protocol address information captured by American
Express systems during online account activity.
G. LINKED ACCOUNTS
The Linked Accounts tab includes information for external bank accounts currently or previously
linked to the PSA(s), including the routing number and bank account number. Each account
holder is authorized to link up to three external bank accounts to their PSA(s). Of note the
column "Expiration Date" identifies the date any test transactions are to be conducted for
verification purposes. Further, the column "Bank Name" displays the account name as chosen
by the account holder for their own recordkeeping purposes.
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EFTA00030215


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c0:
=== Page 1 ===
Event: Accepted: Epstein call
Start Date: 2019-01-11 16:00:00 +0000
End Date: 2019-01-11 16:30:00 +0000
Organizer:
Class: X-PERSONAL
Comment:
Date Created: 2019-01-09 15:40:20 +0000
Date Modified: 2019-01-09 15:40:20 +0000
Priority: 5
DTSTAMP: 2019-01-09 15:29:04 +0000
EFTA00031835


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=== Page 1 ===
MOUNTAIN
2nd Battalion,
15th Field Artillery Regiment
Certificate of Achievement
ALLONS
SGT MICHAEL A. THOMAS
FOR MERITORIOUS ACHIEVEMENT DURING THE BATTALION GUNNERS
TESTING FROM 22 JANUARY 2003 TO 24 JANUARY 2003. SGT THOMAS' HARD
WORK AND COMMITMENT TO EXCELLENCE SET THE EXAMPLE FOR FIELD
ARTILLERYMEN EVERYWHERE, AND REFLECTS GREAT CREDIT UPON
HIM, THE 2ND BATTALION, 15ᵀᴴ FIELD ARTILLERY AND THE UNITED
STATES ARMY,
DranA.Tul
MICHAEL J. LOPEZ
FROM 22 JAN 03 TO 24 JAN 03
DREW A. TURINSKI
CSM, USA
LTC, FA
Command Sergeant Major
Commanding
EFTA00031447


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=== Page 1 ===
Event: Accepted: Epstein Oral Argument-- Second Circuit
Start Date: 2019-02-06 15:00:00 +0000
End Date: 2019-02-06 17:00:00 +0000
Organizer:
)
Class: X-PERSONAL
Comment:
Date Created: 2019-01-09 19:42:46 +0000
Date Modified: 2019-01-09 19:42:46 +0000
Priority: 5
DTSTAMP: 2019-01-09 19:22:03 +0000
EFTA00031331


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c0:
=== Page 1 ===
From:
)"
To:
)"
"
,
Cc:
(
)"
Subject: FOIA
Date: Fri, 25 Jan 2019 20:02:19 +0000
Attachments: 1424728.pdf
Embedded: FW: Pending FOIA 1424728 - JEFFREY EPSTEIN --- UNCLASSIFIED.msg;
RE: Pending FOIA 1424728_-_JEFFREY_EPSTEIN_--_UNCLASSIFIED.msg
See attached.
Special Agent
EFTA00030110


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=== Page 1 ===
DOUBLETREE SUITES BY HILTON SANTA MONICA
1707 FOURTH STREET
SANTA MONICA, CA 90401
DOUBLETREE
United States of America
BY HILTON
TELEPHONE 310-395-3332 FAX
Reservations
www.doubletree.com or 1-800-222-TREE
Room No:
629/NKXI
Arrival Date:
11/13/2019 7:43:00 PM
Departure Date:
11/15/2019 12:22:00 PM
Adult/Child:
1/0
Cashier ID:
VDLT
Room Rate:
247.00
AL:
HH #
992288328 SILVER
VAT #
Folio No/Che
879282 A
Confirmation Number: 90447796
DOUBLETREE SUITES BY HILTON SANTA MONICA 11/15/2019 12:21:00 PM
DATE
REF NO
DESCRIPTION
CHARGES
11/13/2019
6336280
GUEST ROOM
$247.00
11/13/2019
6336280
OCCUPANCY TAX
$35.06
11/13/2019
6336280
TMD ASSESSMENT
$4.50
11/14/2019
6337005
GUEST ROOM
$247.00
11/14/2019
6337005
OCCUPANCY TAX
$35.06
11/14/2019
6337005
TMD ASSESSMENT
$4.50
11/15/2019
6337280
($573.12)
REF=0000879282-01477708 CHIP
05
Application Label: CHASE VISA
TC: 902AEFA3AAFC308E
TVR: 0080008000
**BALANCE**
$0.00
CREDIT CARD DETAIL
APPR CODE
075761
MERCHANT ID
150557
CARD NUMBER
VS *6964
EXP DATE
01/22
TRANSACTION ID
6337280
TRANS TYPE
Sale
Page:1
EFTA00030429


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=== Page 1 ===
From:
To:
Subject: RE: Notes from call with Tartaglione counsel
Date: Wed, 27 Nov 2019 16:28:16 +0000
Sure. I'm around now if you want to chat.
From
Sent: Wednesday, November 27, 2019 11:19 AM
To:
Subject: Re: Notes from call with Tartaglione counsel
Thanks for writing this up. Do you want to discuss later today or Friday or Monday?
Co-Chief, Narcotics Unit
On Nov 27, 2019, at 10:25,
wrote:
Call on November 27, 2019 with NT defense team
Bruce B, Aida, Bruce K, Tony, Michael
EFTA00029642

=== Page 2 ===
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=== Page 1 ===
From:
)"
To:
"
(USANYS) 2"
Subject:
302
Date: Fri, 30 Apr 2021 00:07:22 +0000
Attachments: 2020-04-10,
Interview_302.pdf
Attached. Once you're ready to set up an interview, let me know. I know C-20 wants
to sit in, but she is totally
swamped, so it may take a while to find a day when she's available.
EFTA00031608


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
)"
(USANYS)"
Subject: Re: Jeffrey Epstein/FOIA matters
Date: Tue, 16 Mar 2021 22:15:52 +0000
I just emailed her again, sorry for the delay.
Sent from my iPhone
On Mar 16, 2021, at 6:09 PM,
)
wrote:
Hi
,
Just following up to see if you found out anything from the civil clerks. Thanks for your help with this.
Best,
On Mar 12, 2021, at 11:22 AM,
)
wrote:
Thanks,
Much appreciated.
From:
(USANYS)
Sent: Friday, March 12, 2021 11:18 AM
To:
Cc:
is
(USANYS)
;
(USANYS)
Subject: Re: Jeffrey Epstein/FOIA matters
Hi
I am copying
who is handling the main matter before Judge Engelmayer and who likely
would know if there are related FOIAs. I will also ask our civil clerk.
Sent from my iPhone
On Mar 12, 2021, at 10:59 AM,
wrote:
Hi
EFTA00030099

=== Page 2 ===
In connection with a criminal discovery matter,
and
and I are trying to find a list of all Jeffrey Epstein-
related FOIA lawsuits that the Civil Division has handled (either pending or historical). Our chiefs suggested that you
might be able to help us generate that list - if you have any guidance or information on how we could track this
down, we'd really appreciate your help. Or if there's someone else we should reach out to in the Civil Division
instead, please let us know.
Thanks so much-
Assistant United States Attorney
Southern District of New York
EFTA00030100


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=== Page 1 ===
From:
"
)"
To:
)"
(USANYS)"
Subject: Politico piece
Date: Fri, 14 May 2021 13:59:07 +0000
Just making sure you guys saw this new piece in Politico:
The Women Who Enabled Jeffrey Epstein - POLITICO
EFTA00029693


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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
i
Subject: Re: Media Inquiry from
- Daily Mail - - Jeffrey Epstein inquiry
Date: Fri, 31 Jul 2020 17:32:50 +0000
Gotcha, just thought you might be tracking. Thanks!
Sent from my iPhone
> On Jul 31, 2020, at 1:16 PM,
)
wrote:
>
> Hi
,
>
> We don't have this document - it sounds like it's an unsealed filing from a civil suit, and those filings are
voluminous, so we don't know which document that is (we're not tracking the unsealed documents).
V
> Thanks,
V
V
>
>
Original Message
> From:
)
> Sent: Friday, July 31, 2020 12:45 PM
> To:
)
> Subject: FW: Media Inquiry from
- Daily Mail - Jeffrey Epstein inquiry
>
> Rather than ask this reporter for a copy of the doc (below), would you happen to have it? Main is asking.
Thanks.
>
V
Original Message
> From:
> Sent: Friday, July 31, 2020 12:43 PM
> To: Press <Press@jmd.usdoj.gov>; NPO@ic.fbi.gov;
)
>
Subject: RE: Media Inquiry from
- Daily Mail - Jeffrey Epstein inquiry
>
> +SDNY team. If you don't have copy of this civil litigation filing reporter is referencing, can you ask reporter
for copy of doc?
>
V
Original Message
> From: no-reply@usdoj.gov <no-reply@usdoj.gov>
> Sent: Friday, July 31, 2020 12:21 PM
> To: Press <Press@jmd.usdoj.gov>
> Subject: Media Inquiry from
- Daily Mail - Jeffrey Epstein inquiry
>
> Date Friday, July 31, 2020 - 12:21 pm EDT
V
EFTA00031215

=== Page 2 ===
> Name:
V
> Email Address:
)
V
> Media Outlet: Daily Mail - Jeffrey Epstein inquiry
>
> Deadline: ASAP
>
> Inquiry:
> Hello, I'm a journalist with the Daily mail and am looking to find out if you have any comment on the claim in
newly unsealed court documents that Prince Andrew and Alan Dershowitz put pressure on the DOJ to give
Jeffrey Epstein a favorable plea deal in 2007. The documents were unsealed in a civil case brought by
an Epstein victim, against Ghislaine Maxwell, his alleged madam. Please email or call me on
V
>
EFTA00031216


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=== Page 1 ===
From:
)"
To:
)"
=
Subject: Epstein
Date: Fri, 29 May 2020 17:35:20 +0000
Started watching the new Netflix doc yet?
Sent from my iPhone
EFTA00030455


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=== Page 1 ===
From:
To:
)"
)"
(NY) (FBI)"
)"
(NY) (FBI)"
Subject: Re:
Checks
Date: Tue, 02 Jul 2019 18:32:04 +0000
Attachments:
Attached is
flight history since November of last year.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
Sent: Monday, July 1, 2019 9:16:24 PM
To:
;
);
,
(NY) (FBI);
)
Subject: RE:
Checks
Hi
Thanks, we'll take a look-if you could send over a summary of her flights with him over the past 6 months, that would be
helpful. Have you guys looked at the phone numbers associated with the email accounts we got subscriber info for? Let us
know if you think any of those numbers are live.
Thanks,
From:
,
Sent: Monday, July 1, 2019 8:53 PM
To:
)
is
)
>;
(NY) (FBI)
>;
Subject:
Checks
See attached phone records for
As per our conversation her cell phone number may be
relevant to her recent travels with Epstein.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
EFTA00030827


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c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: RE: Epstein Sharing Order Part II
Date: Mon, 29 Jun 2020 22:44:44 +0000
Perfect, thanks.
From:
Sent: Monday, June 29, 2020 6:42 PM
To:
(USANYS)
Subject: RE: Epstein Sharing Order Part Il
Yep, no problem - order is attached (along with the application and order, in case that's useful too).
From:
(USANYS)
Sent: Monday, June 29, 2020 16:02
To:
Subject: FW: Epstein Sharing Order Part Il
Remember way back in late January/early February when we got a second sharing order so we could send all of the trust
agreements over to Civ Div? From emails I know it was signed on 2/4 but can't seem to find the actual signed order. Do
you by any chance have it?
From:
(USANYS)
Sent: Friday, January 31, 2020 11:43 AM
To:
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
OK, I made some idiosyncratic changes, plus a few things highlighted in green for you to verify. I have one Q set
forth in the footnote.
From:
Sent: Friday, January 31, 2020 11:29 AM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
is out, but the clerk's office says to use the same miscellaneous number because the applications are related. The
prior misc number was: 19 Misc. 0586
And attached for reference in case that's helpful.
From:
(USANYS)
Sent: Friday, January 31, 2020 10:32
To:
(USANYS)
is
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
EFTA00031102

=== Page 2 ===
Working on it right now.
please check with
to see if we should use the same docket no as was
assigned to the first 6e order.
From:
(USANYS)
Sent: Friday, January 31, 2020 9:54 AM
To:
>;
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
Great, thanks for catching.
let us know if you have any comments/thoughts. Thanks
From:
Sent: Friday, January 31, 2020 9:53 AM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part II
Yes, this looks good, thanks - I made one more typo correction in the attached (in the new Trust Two language, "and
revocations" got repeated in the footnote and the order) but otherwise no changes.
From:
(USANYS)
Sent: Friday, January 31, 2020 09:48
To:
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
Thanks for flagging,
I made a few small changes (which I highlighted since we've got a fair bit of track already) which
I think should make this broad enough to cover the Trust II stuff. Can you take a quick look and if everyone is okay with
this, perhaps we can plan to get this to CM on Monday morning? Thanks
From:
Sent: Thursday, January 30, 2020 7:22 PM
To:
(USANYS)
in
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
I apologize for the delay on this - I've added the relevant language about revocations to both the application and the
order, and corrected a stray typo, so that stuff is good to go. But two quick things to note, not to belabor this, but - it
doesn't look like there's any reference to the Trust Two documents - that may be because they're not referenced in any
will? At a glance I don't see Trust Two in any of the wills, but I'd want to go back and look more thoroughly unless
somebody already made the decision on that basis. And second, it references a 2019 Trust but I don't see any documents
on that? I have to run out tonight but can certainly circle up with
and/or
tomorrow on any of this, or just ignore
it if I've misread.
thanks,
From:
(USANYS)
Sent: Thursday, January 30, 2020 12:05
To:
is
(USANYS)
EFTA00031103

=== Page 3 ===
Cc:
is
Subject: RE: Epstein Sharing Order Part II
Just wanted to circle back on this -
are you signed off? Is this something we could get over to Part I today or
tomorrow? Thanks
From:
Sent: Wednesday, January 29, 2020 3:56 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
is it the intent to share those? If so, l'll just add it to every mention of each document, but if not then it's
unnecessary. I don't think those are substantive docs but I defer.
From:
(USANYS)
Sent: Wednesday, January 29, 2020 15:55
To:
>;
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part II
Please add it in the right place and send me the order. Remember, I'm not a T&E lawyer. But you are getting to
be
From:
Sent: Wednesday, January 29, 2020 3:22 PM
To:
(USANYS)
in
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
Yes, I think this document accurately describes the materials we've received, with just a note that it doesn't appear to
include revocations, so to the extent those are intended to be shared, I think that word may need to be added.
thanks,
From:
(USANYS)
Sent: Wednesday, January 29, 2020 10:40
To:
(USANYS)
is
Subject: Epstein Sharing Order Part Il
- I've updated the sharing order application to be one to share the additional trust and will documents we have now
received. Would you take a look when you can?
— I've tried to describe the various materials we have gotten from the estate attorneys over the last two weeks.
Would you mind taking a look (or asking a paralegal to take a look) to make sure I've accurately described/characterized
the new stuff we're looking to share?
Thanks,
EFTA00031104


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=== Page 1 ===
From:
(ODAG)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Epstein/Maxwell
Date: Wed, 19 Aug 2020 21:57:15 +0000
Great. Thank you!
From:
(USANYS)
Sent: Wednesday, August 19, 2020 5:52 PM
To:
(ODAG)
Cc:
(USANYS)
Subject: RE: Epstein/Maxwell
Thanks very much,
We will reach out.
On the victim meeting, the FBI witness coordinator who we have been working with is
And as I mentioned, the SDNY victim services coordinator is
Thanks again,
From:
(ODAG)
Sent: Wednesday, August 19, 2020 5:08 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein/Maxwell
,
Thanks again for all of the valuable information you provided this morning. I will keep you informed as
we finalize plans for the victim meeting.
As for your request, you should reach out to
in the SDFL. Ms.
is the Criminal
Chief and is prepared to assist you in locating all criminal files still located in the District. She can be
reached at
or
She is awaiting your reach out. Please let me
know if I can be of further assistance.
From:
(USANYS)
Sent: Tuesday, August 18, 2020 12:03 PM
To:
(ODAG)
Cc:
(USANYS)
Subject: RE: Epstein/Maxwell
- Thanks again for your help on this a few weeks ago. We've since had a number of productive conversations with
the folks at OPR you pointed us to, and we think it would be helpful to also make contact with someone at SDFL purely for
the purpose of ascertaining what hard-copy materials they still have related to the case down there and how we could
EFTA00030484

=== Page 2 ===
best arrange to obtain and review copies. We have had very limited contact with
an AUSA in the SDFL civil
division who we understand was the primary point of contact on issues related to the CVRA litigation. Do you know, does
he remain the best point of contact for the issues we hope to discuss, or is there someone else in that office we should
reach out to?
Thanks so much,
From:
(ODAG)
Sent: Wednesday, July 22, 2020 2:33 PM
To:
(USANYS)
is
(ODAG)
Cc:
(USANYS)
Subject: RE: Epstein/Maxwell
Thursday at noon is perfect. Should I give you a call?
From:
(USANYS)
Sent: Wednesday, July 22, 2020 1:39 PM
To:
(ODAG)
is
(ODAG)
Cc:
(USANYS)
Subject: RE: Epstein/Maxwell
Thanks,
Would 12pm tomorrow (Thursday) work for you? If not, we also have availability Friday morning, from
10-12:30 if anything in there works for you. Best,
From:
(ODAG)
>
Sent: Wednesday, July 22, 2020 1:03 PM
To:
(ODAG)
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein/Maxwell
Hi
,
I'm happy to assist you. I'm available Thursday or Friday to discuss what documents you are trying to
locate. Please let me know if you have availability on either of those days.
Thanks,
From:
(ODAG)
Sent: Wednesday, July 22, 2020 12:49 PM
To:
(USANYS)
Cc:
(USANYS)
is
(ODAG)
Subject: RE: Epstein/Maxwell
Thanks. OPR and
may have a better sense on document custodians than do I.
From:
(USANYS)
Sent: Wednesday, July 22, 2020 12:41 PM
EFTA00030485

=== Page 3 ===
To:
(ODAG)
Cc:
(USANYS)
in
(ODAG)
Subject: RE: Epstein/Maxwell
Thanks,
Among our questions was who, whether at ODAG, SDFL, or NDGA we should be in touch with at this point
regarding documents. I also know OPR did a significant document collection last year.
We will reach back to OPR, but if there is a particular point of contact at SDFL or NDGA on issues related to document
collection, in particular, please let us know. And if a call on those issues would be helpful, happy to set one up.
Thanks very much,
From:
(ODAG)
Sent: Wednesday, July 22, 2020 10:56 AM
To:
(USANYS)
Cc:
(USANYS)
is
(ODAG)
Subject: RE: Epstein/Maxwell
Happy to talk, but my only real role related to recusal issues and consequences. Now that the CVRA litigation is over, you
probably are best going directly to SDFL, as I don't have any of their documents. Thanks,
Associate Deputy Attorney General
Office:
Cell:
From:
(USANYS)
Sent: Tuesday, July 21, 2020 6:23 PM
To:
(ODAG)
Cc:
(USANYS)
Subject: Epstein/Maxwell
- Hope all is well. We had spoken last summer, after the Epstein case was charged, about some potential
document/discovery requests related to the SDFL investigation and the NPA, in particular. Those conversations were
largely at mooted at the time by Epstein's death, but as I'm sure you know, we've recently charged Ghislaine Maxwell and,
anticipating potentially similar issues, we were hoping to revisit those conversations. Do you have time later this week
for a quick call? If so, please let us know what might work for you.
Thanks very much,
Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00030486


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=== Page 1 ===
Event: Accepted: Epstein Meeting
Start Date: 2020-01-06 17:30:00 +0000
End Date: 2020-01-06 18:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-01-08 02:26:51 +0000
Date Modified: 2020-01-08 02:26:51 +0000
Priority: 5
DTSTAMP: 2020-01-06 16:16:51 +0000
Attendee:
EFTA00031911


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: any of you have vouchers for Epstein victims.
Date: Fri, 15 Nov 2019 21:44:16 +0000
She was paid.
secretary, sent me an email apologizing. It was no big deal.
From:
Sent: Friday, November 15, 2019 4:37 PM
To:
Cc:
Subject: RE: any of you have vouchers for Epstein victims.
I don't either
From:
Sent: Thursday, November 14, 2019 1:56 PM
To:
Cc:
Subject: Re: any of you have vouchers for Epstein victims.
I don't
Sent from my iPhone
On Nov 14, 2019, at 09:50,
wrote:
Victim Witness Coordinator
United States Attorney's Office
Southern District of New York
1 St. Andrews Plaza
New York, New York 10007
Tel.
EFTA00029804


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=== Page 1 ===
From:
Subject: Mark Epstein Emails
Date: Tue, 26 May 2020 14:29:00 +0000
Saved here: \\usa.doj.gov\cloud\nys\StAndrews\Shared\InReEpsteinDeath-2019R01059\Mark Epstein
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00030978


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=== Page 1 ===
Date: 9/01/06
PALM BEACH POLICE DEPARTMENT
Page:
1
Time: 13:38:06
Incident Report
Program: CMS301L
Case Number . : 1-03-001498
SPECIAL NOTES :
Occur From Date: 10/05/03 0824
Occur To Date : 10/05/03 0824
Report Date : 10/05/03 0845
Day Of Week . : Sunday
Common/Location: 358 EL BRILLO WY
City
.....
:
PALM BEACH, FL
Location Type : RESIDENCE-SINGLE FAMILY
Beat Assignment: SHIFT 2
Map Reference : 10
Dept Class
:
BURGLARY RESIDENCE
Report Officer :
Case Status : EXCEPTIONALLY CLEARED Case Status Dt : 10/15/03
Supervisory Dt.:
10/05/03
Entry Date
:
10/06/03
Names? .....
Property? :
Vehicles? :
Offenses? :
Narrative?
Related Cases? :
Interfaces? :
********* PROPERTY INFORMATION # 1
Case number : 1-03-001498
Category
...:
**MISC OR UNFOUNDED PROP **
Description : PISTOL
Color
Serial number :
Make
.....
:
GLOCK
Model .....
UCR Prop Type : FIREARMS
Property type : HANDGUN
Insured? :
Insured by
:
NCIC number :
(
Value .... : 1,000.00
Recovered by :
Recovered Date : 0/00/00
Recovery value : 0.00
Street number :
City ......
Drug?
Document? :
Property Meg - :
Property Seq :
********* PROPERTY INFORMATION # 2
Case number : 1-03-001498
Category
*STOLEN/RECOVERED*
Description : S.CURRENCY
Color
Serial number :
Make
Model .... :
UCR Prop Type : CURRENCY, NOTE, ETC.
Property type : CURRENCY/NEGOTIABLE
Insured? :
Insured by
:
NCIC number :
Value .... : 2,700.00
Recovered by :
Recovered Date : 10/13/03
Recovery value : 2,700.00
Street number :
City .....
Drug?
Document? :
Property Msg :
Property Seq :
********* PERSON REPORTING INFO - # 1 *********
Case Number . : 1-03-001498
Last Name ..:
Street Number : 301 E 66TH ST 10N
City
:
Birth Date/Age :
Employer? ..:
Occupation
Oper Lic No. :
Home Phone No. :
Race .. .... White
Sex ..... : Female
Height
....
: 508
Weight 0
Other Phone Nbr:
03/25/2015
Page 53 of 95
Public Records Request No.: 16-268
EFTA00029761

=== Page 2 ===
Date: 9/01/06
PALM BEACH POLICE DEPARTMENT
Page:
2
Time: 13:38:06
Incident Report
Program: CMS301L
1-03-001498 (Continued)
********* PERSON REPORTING INFO #
Case Number - : 1-03-001498
Last Name
:
Street Number : 358 EL BRILLO WY
City
.....
:
PALM BEACH, FL 000033480
Birth Date/Age :
Employer?
Occupation : HOUSE MANAGER
Oper Lic No. :
Home Phone No. :
Race
.....
White
Sex ..... : Male
Height : 601
Weight .... : 190
Other Phone Nbr:
********* PERSON REPORTING INFO # 3 *********
Case Number - : 1-03-001498
Last Name
..:
Street Number : 358 EL BRILLO WY
City
: PALM BEACH. FL 000033480
Birth Date/Age :
Employer? :
Occupation : HOUSE MANAGER
Oper Lic No. :
Home Phone No. :
Race :
Sex
.... .
:
Female
Height
.....
Weight
....
: 135
Other Phone Nbr:
********* PERSON REPORTING INFO # 4 *********
1
Case Number - : 1-03-001498
Last Name :
Street Number : 22 AVENUE FOCH
City
.....
:
PARIS,
Birth Date/Age : 0/00/0000 0
Employer? :
Occupation :
Oper Lic No. :
Home Phone No. : 561/000-0000
Race
......
Sex
:
Height : 0
Weight : 0
Other Phone Nbr: 561/000-0000
VICTIM
INFORMATION - #1
Case Number . : 1-03-001498
Prompt valid in: EPSTEIN, JEFFREY EDWARD
Street Number : 358 EL BRILLO WY
City
.....
: PALM BEACH, FL 000033480
Birth Date/Age :
Employer? :
Occupation :
BANKER/SELF
Oper Lic No. :
Home Phone No. : 561/655-7626
Race ...... White
Sex ..... : Male
Height .... : 600
Weight : 0
Misc. ID#
:
Be On Look Out?:
Other Phone Nbr:
Victim Type . :
Residency Type :
Residency Sts :
File Charges :
Can Identify . :
Victim Sobriety:
Injury Extent :
Injury Type 1 : .
Injury Type 2 :
Hospital ID
:
Med Treatment :
Phys First Name:
Phys Last Name :
***EMPLOYER INFORMATION***
Case Number . : 1-03-001498
Employer Name :
Address :
03/25/2015
Page 54 of 95
Public Records Request No.: 16-268
EFTA00029762

=== Page 3 ===
Date: 9/01/06
PALM BEACH POLICE DEPARTMENT
Page:
3
Time: 13:38:06
Incident Report
Program: CMS301L
1-03-001498 (Continued)
City/State/Zip : PALM BEACH, FL 000033480
Phone Number : 212/750-9895
********* OTHER PERSON
INFORMATION #
Case Number . : 1-03-001498
Last Name :
Street Number : 1515 so FLAGLER DR. #1901
City
.....
:
WEST PALM BEACH, FL 33407
Birth Date/Age :
Employer?
Occupation :
Oper Lic No.
:
Home Phone No. : 561/000-0000
Race
. ....
:
White
Sex
......
:
Female
Height : 0
Weight : 0
Person Type : OTHER PERSON
Other Phone Nbr: 561/000-0000
OTHER PERSON
INFORMATION # 2
*********
Case Number . : 1-03-001498
Last Name
Street Number : 525 so SEQUOIA APT. A
City
. .....
:
WEST PALM BEACH, FL 33409
Birth Date/Age :
Employer?
Occupation :
Oper Lic No.
:
Home Phone No. : 561/000-0000
Race
.....
:
White
Sex
: Male
Height : 0
Weight
: 0
Person Type : OTHER PERSON
Other Phone Nbr: 561/000-0000
NARRATIVE # 1
Original Report
LO
Reported By:
10/05/03
Entered By.:
10/06/03
On Sunday 10/5/03 at approximately 0824 hours, I
was dispatched to a burglary at 358 El Brillo Way. Upon
arrival, I met with reporting party/victim Jeffrey Epstein, white
male, dob/012053. Epstein advised he and his
arrived in
the residence on Friday evening, 10/3/03. Epstein advised
that on Saturday evening 10/4/03, he left his briefcase at his
desk and went to bed at approximately 1230 am. Epstein
said when he left his briefcase, it contained approximately
$5000 U.S. currency.
advised the case was in $100
bills and kept in a white envelope inside the briefcase.
Epstein stated at approximately 0715 hours on Sunday,
10/5/03, while sitting at his desk, he noticed the briefcase had
been opened and some of the cash was missing. Epstein
believed approximately $3500 was taken from the briefcase.
Epstein advised that he did not know if the cash was
sequential or recorded. Epstein further advised a black
Glock handgun was taken from the bookshelf located behind
his desk. Epstein advised he suspected cash had been
taken from his briefcase on two other occasions while he was
in town for the weekend. The first was over Labor Day
weekend Aug. 30-Sept 1, 2003. The second time was a
weekend in mid September, 2003. Epstein stated he did not
03/25/2015
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EFTA00029763

=== Page 4 ===
Date: 9/01/06
PALM BEACH POLICE DEPARTMENT
Page:
4
Time: 13:38:06
Incident Report
Program: CMS301L
1-03-001498 (Continued)
report these incidents because he was not sure the money
was accounted for. Possible footage of the incident may
exist. I next met with
who advised
went to bed at
approximately 1130 pm on 10/4/03 and did not hear or see
anything unusual through the night or on the morning of
10/5/03.
advised that
went to
bed at approximately 1030 pm on 10/4/03 and began work at
approximately 6:20 am on 10/5/03.
stated that
did
not see or hear anything unusual from the staff residence
locate don the east side of the property. I next spoke to
who are the house managers.
stated that ne went to the staff residence at approximately
8:30 hours on 10/4/03 and got up at approximately 11:30 pm
same night to move the Mercedes into the garage.
said
returned to the residence at approximately 6:20 am on
10/5/03 but did not notice anything unusual.
stated
that
checked the exterior of the residence at
approximately 7:30pm on 10/4/03 as part of
duties.
stated at that time,
saw no one and everything
appeared in order.
stated
left the main house at
approximately 11:30 pm and returned at approximately 8:30
on 10/5/03. It should be noted that
have been employed as the house managers since
9/24/03. Prior to them, the live on site house managers were
Epstein was unsure of the last name.
employed at 358 El Brillo approximately
9 months. Prior to the house manager was
who
was employee at 358 El Brillo approximately 10 years.
Epstein signed an affidavit of prosecution, it is attached to
this report. Crime Scene manager
responded and
processed the scene. Det.
also responded. See
Det.
report for further information. Officer
responded and conducted a neighborhood canvas which is
also attached to this report. It should be noted that Epstein
will contact Palm Beach Police Department with the serial
number of the stolen handgun so that it may be entered into
FCIC.
NARRATIVE # 2
Reported By:
10/06/03
Entered By.:
10/06/03
On 10/05/03, at 1000 hours, I responded to 358 El Brillo Way
reference a burglary that had occurred at the residence during
the night. Upon my arrival, I met with the homeowner who
verbally identified himself as Jeffrey Epstein, DOB 01/20/53.
Epstein told me that over the last couple of months, when he
has come into town, he has money he had left in his carry on
bag, has turned up missing. Epstein said he wasn't sure of the
amount of money in the carry on bag on any specific incident
and thought that he possibly had misplaced the money. Epstein
03/25/2015
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EFTA00029764

=== Page 5 ===
Date: 9/01/06
PALM BEACH POLICE DEPARTMENT
Page:
5
Time: 13:38:06
Incident Report
Program: CMS301L
1-03-001498 (Continued)
told me that he had purchased a
spy camera from a store on
Okeechobee Blvd. and had set up the camera which was in a
clock in his office facing the briefcase with the money in it.
Epstein then placed $4,000. in U.S. currency, one hundred dollar
bill increments and left the bag on his desk as he always does
when he is in town. Epstein said that he went to bed with the
camera system monitoring the bag and desk area, only to wake up
and twice to have $100. missing from the bag and the suspects
image on his computer hard drive. It should be noted that there
were thirteen one hundred dollar bills still in the white envelope
and that nothing else in the house appeared to be disturbed by the
suspect.
Epstein took me to the computer room where he showed me a computer
monitor that was displaying a still frame of the suspect. The
computer indicated a time of 0428 a.m., when the suspect came into
the office area, walked behind the desk, opened the hand bag, and
then opened the center drawer to the desk. It appeared as though
the suspect was familiar with the house and the desk. Epstein
told me that he did not know who the suspect in the photo was
but thought it might be his former houseman because of his size
and shape. Epstein also pointed out that the suspect in the
video was wearing moccasin type shoes like his former houseman
did due to his back injury. The suspect was a white male who
was 5'10" in height, 250 lbs., wearing tan pants, white shirt,
and a hat. Epstein provided me with the former houseman's
information which was
I advised Epstein that I would need to obtain a copy of the
surveillance video from his computer hard drive in order to
have in hands. Epstein told me that he had limited working
knowledge of the system but he would contact the company who
had installed the system and have them make a copy by Monday.
Epstein told me he would call when he had more information.
Epstein took me to the desk where the carry on bag was and told
me that he believed that the suspect might have gained entry
into the house from the sliding glass doors on the south side
of the house but not the west side of house because he had
personally locked all the sliders on that side of the house.
It is believed that the suspect also left the house by the
same sliding door that was unlocked as there were no pry marks
or indication of forced entry into the house. Epstein also showed
me the bookcase behind the desk where he kept his Glock 9 mm
handgun between the books which was now missing. Epstein could
not supply me with the serial number for the handgun at this
time but advised he would contact Gator Gun on Okeechobee
Blvd. to obtain the information.
Crime Scene Manager
processed the crime scene and
collected the envelope that the
money had been taken out of.
03/25/2015
Page 57 of 95
Public Records Request No.: 16-268
EFTA00029765

=== Page 6 ===
Date: 9/01/06
PALM BEACH POLICE DEPARTMENT
Page:
6
Time: 13:38:06
Incident Report
Program: CMS301L
1-03-001498 (Continued)
Officer
conducted a neighborhood canvas and failed to
produce any new information as most of the neighbors were not
home at this time.
Officer
collected the names of the house guests which
included
who is from
who 18 a massage therapist from
All the subjects advised that they hadn't heard
anything during the night.
Officer
also collected the names of the live in employees
were
and Chef
All the subjects
advised that they hadn't heard anything during the night.
The criminal history search of
revealed no criminal history
other than being a naturalized United States citizen and that
full name was
ATTN POLICE CLERKS; Please show a stolen value for the U.S.
currency as **$2,700.** Please show a stolen value for the Glock
9 mm handgun as $1,000.**
Invest.Cont.
NARRATIVE # 3
Reported By:
10/08/03
Entered By.:
10/08/03
At 8:42 a.m., Sunday morning, 10/05/03, I was notified at home
by the communication unit of the Palm Beach Police Dept. that a
burglary had been reported at 358 El Brillo. I responded to the
scene and proceeded directly to headquarters where I picked up
the necessary equipment and the crime scene vehicle to process
the crime scene.
I went in service at 9:32 a.m. and arrived on the scene at 9:33 a.m.
Upon arrival I noted that the house is located at the extreme west
end of the street and is located on the south side of the street with
the front of the house facing north. The house is basically a two
story CBS type of structure having a white flat tile roof. The trim
is painted white and there are walls approximately 8' tall with
metal closing gates which are controlled with a electronic touch
pad on the outside. There are white gargoyle figures on the tops
of the entrance of the gate as well as black numerals
approximately 6" high indicating the address numerics of 358.
The east most drive way is a large flagstone type of drive way
leading to a three car garage.
The dwelling has in addition to the main entrance to the garage
two other gated entrances which have black floral lighted tops on
them. These gates were metallic. The central gate which leads
03/25/2015
Page 58 of 95
Public Records Request No.: 16-268
EFTA00029766

=== Page 7 ===
Date: 9/01/06
PALM BEACH POLICE DEPARTMENT
Page:
7
Time: 13:38:06
Incident Report
Program: CMS301L
1-03-001498 (Continued)
into a circular flagstone drive way was in the open position. The
western most gate was in the closed position. The front was
locked on my approach and I continued traveling to the west
where there is a small double gate which has a sign, "Please keep
gate closed". This gate was opened and leads to a large patio with
a swimming pool. To the west of the swimming pool is a walk
way leading to a dock which then leads directly across to the intra
coastal waterway. The dock was examined and checked for any
signs of a boat tying up or the presence of anyone that may have
left either debris such food containers, cigarettes, cigars etc. None
was found. It should be noted that the exterior temperature was
79 degrees and the humidity was 63 percent. There is a small
cabana at the southern end of the pool which had computer
equipment as well as exercise equipment. None of this had been
touched or tampered with.
On the south side of the residence in the southwest corner Mr.
Epstein indicated that he believed this was the area that the
intruder made entry to the residence. The room is a computer
room and Florida type room and has three double sliding glass
windows present. The eastern most and western most are
identical in shape having two glass panels. The central one has
three glass panels and is the only one of the three that has a set of
14 flagstones leading directly into the room. The flooring is a
wood type of flooring and the western set of sliding doors was
found ajar, however the sandy area directly outside of the door did
not indicate the presence of shoe prints or barefoot prints. The
central window was found ajar and still had the lock mechanism
in the extended outward position. The two windows believed to
have been entered were processed and no latent fingerprints were
found on the western most, no fingerprints were found on the
eastern most. There was one mark that was found that was not a
fingerprint but could have been made from either a cloth or a
rubber glove and this was found on the interior of the central
window.
Once inside the residence, the person went over to a desk which is
a veneer covered desk and there was a black bag underneath. The
black bag is approximately 2' long by 1' high and was placed on
the southern side of the interior of the desk by the pedestal. The
individual knelt down and pulled the case open and removed cash
from a white envelope. There were thirteen one hundred dollar
bills left, still in the envelope when I examined it. The thirteen
one hundred dollar bills were removed in the presence of Det.
Melnichok and Mr. Epstein and they were counted and turned
directly over to Mr. Epstein for security purposes. The top of the
desk, sides of the desk and bottom of the desk was processed for
latent fingerprints and no latent fingerprints of value were found
on those areas. The envelope will be transported to headquarters
and processed chemically for latent fingerprints. There will be a
supplement to that effect that will follow.
03/25/2015
Page 59 of 95
Public Records Request No.: 16-268
EFTA00029767

=== Page 8 ===
Date: 9/01/06
PALM BEACH POLICE DEPARTMENT
Page:
8
Time: 13:38:06
Incident Report
Program: CMS301L
1-03-001498 (Continued)
NARRATIVE # 4
Reported By:
10/09/03
Entered By.
10/09/03
On 10/06/03, at 1100 hours, Det.
and I went to
358 El Brillo and met with Mr. Epstein's personal
assistant
in regards to obtaining the video
footage of the suspect burglar.
Det.
obtained a video of the footage starting at
0426 hrs, and ending at 0430 hours. The before
mentioned video shows a white male inside the Epstein
residence moving a duffle bag and opening a desk
drawer. A copy of this video footage was captured onto
a compact disk and was placed into evidence via a
property receipt.
At 1400 hours, Det.
and I went to the
in West Palm
Beach, where the suspect currently resides. I observed
several video cameras on the outside of the building and
a doorman at the main entrance on the south side of the
building.
At 1550 hours, I was advised by Crime Scene Manager
that he had located fingerprints for the
suspect
from a Town of Palm Beach
identification card application.
At 1630 hours, I called the
and
spoke with the manager of the condominium who
verbally identified himself to me as
gave me his direct business number
and his home phone number
told me that he was familiar
with the name
but he advised he wouldn't
recognize him. Dement told me that they had several
video cameras and that they did record the surveillance
camera but the recording system had broken on Sunday
night and he didn't have anything on the tapes.
told me that the condo does have a midnight
doorman who stands duty at the desk in the lobby and
anyone coming in the building regardless of what door
they come in, would have to pass the doorman.
told me that the desk man for Sunday morning, 2300 CO
0700 hours was
and he next worked on
Wednesday, 10/08/03.
was not familiar with
what
drives or which parking spot was his but he
advised that he would check and call me back in the
morning.
03/25/2015
Page 60 of 95
Public Records Request No.: 16-268
EFTA00029768

=== Page 9 ===
Date: 9/01/06
PALM BEACH POLICE DEPARTMENT
Page:
9
Time: 13:38:06
Incident Report
Program: CMS301L
1-03-001498 (Continued)
A Palm Beach County property search revealed that,
one
and has resided there since 2001.
Invest.Cont.
NARRATIVE # 5
Reported By:
10/15/03
Entered By.:
10/15/03
On Monday, 10/13/03, at 2:00 p.m., Mr. Jeffrey Epstein came into
the police department and informed me that earlier today he met
with his former houseman
at Green's Pharmacy in Palm
Beach. Epstein stated that he presented
with a photograph
obtained off the video surveillance system, whereby
admitted to breaking into the house and taking the money.
told Epstein that he broke into the house to take a gun that
Epstein usually keeps behind his desk. He could not find the
gun so he took the money.
are having
problems and they no longer live together. He wanted the gun
because he was contemplating suicide.
Epstein stated that
has already returned $2,000. of the
stolen money and that he will be making arrangements with
to pay off the remaining funds. I asked Epstein if he knew of
B current address or phone number and Epstein said that
was going to call him at 5:00 p.m. today and he would
make arrangements for
to come into the police station to
be interviewed. Epstein stated he no longer wants to prosecute
but is concerned over the fact that the gun
said
he broke into the house to steal is still missing, yet
said he does not have it.
ATTN POLICE CLERKS: As
as returned $2,000. to Epstein
and arrangements have been made for the return of the rest of
the money, please show a full recovery of the $2700. cash. **
NARRATIVE # 6
Reported By:
10/15/03
Entered By.:
10/15/03
On Monday, 10/13/03, Det.
and I responded to
where we met with
stated
does not know
current address and
provided us with a cell phone for him. While speaking to
Det.
made telephone contact with
and
made arrangements to meet with him back at the Palm Beach Police
Department. According to
the last time she saw
was today, 10/13/03.
According to
was at Ross Department Store located
on Okeechobee Blvd. when
saw
drive by.
stated
received a telephone call from him on
cell phone
03/25/2015
Page 61 of 95
Public Records Request No.: 16-268
EFTA00029769

=== Page 10 ===
Date: 9/01/06
PALM BEACH POLICE DEPARTMENT
Page:
10
Time: 13:38:06
Incident Report
Program: CMS301L
1-03-001498 (Continued)
at which time
did not talk to
per instructions by
stated prior to that
last saw
on 10/08/03, in which
responded to the apartment
building,
at approximately 2:00 a.m.
stated
contacted West Palm Beach Police Department
via 911, and officer's responded. I contacted the West Palm Beach
Police Department which queried their CAD system and confirmed
Officer
responded to that address in reference to a
911 phone call. There is no report on file and list said CAD
entry only that Juan P. Alessi was in the building reference to a
civil matter. They have no current information for
This concludes my involvement in the matter.
NARRATIVE # 7
Reported By:
10/15/03
Entered By.:
10/15/03
On 10/13/03, Det.
and I went to
in an
attempt to locate suspect
As we were
getting into the elevator on the ground floor, we came in
contact with
I explained to
why we were there and
agreed to speak to us.
said
have been
for approximately two months and they are
going through
said on this date, at approximately 1100 hours,
drove by
as
was walking out of the Ross
Department Store located on the southeast corner of
Okeechobee Blvd. and Military Trail.
said
waved at
and that was the extent of their contact.
said
does not know where
is living.
said
is driving a white Caravan.
supplied me
with
cell phone number,
advised
has been depressed lately, due to their
I advised
to be aware of
surroundings and be on the lookout for Juan and if she
comes in contact with
to call the police
immediately.
also supplied me with
phone number,
I called
on
cell phone.
agreed to
come to the Palm Beach Police Station for an interview.
Juan arrived at the police department and I placed
in the interview room in the Detective Bureau. I read
Miranda Rights from a prepared rights card in
stated
understood and signed .
I asked
what
connection was with Mr. Epstein,
03/25/2015
Page 62 of 95
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EFTA00029770

=== Page 11 ===
Date: 9/01/06
PALM BEACH POLICE DEPARTMENT
Page:
11
Time: 13:38:06
Incident Report
Program: CMS301L
1-03-001498 (Continued)
lives at 358 El Brillo.
said
worked for Mr.
Epstein from January 1991 to until September 2002, as
the house manager.
said
was very familiar with
Epstein's schedule and the lay out of the house.
I
asked
took money and a gun from Epstein in the
past weeks and
said
did not take the gun but did
take money from Epstein's house.
explained
approximately six weeks ago
became very depressed
about
advised
became suicidal and decided to steal a gun from Mr.
Epstein in order to kill
said
knew Mr.
Epstein had a gun in
office because
helped Mr.
Epstein put it there.
described the gun as a silver
revolver with a medium barrel that was holstered.
did not know the exact date, but
said it was
approximately six weeks ago at about 0500 hours on a
Sunday morning,
decided to enter Mr. Epstein's
house at 358 El Brillo Avenue, in an attempt to steal the
gun.
drove
white Caravan and parked it
in the driveway of the house.
entered the
house through an unlocked sliding glass door located
near Epstein's office.
entered the office
and attempted to locate the gun.
searched
the office but could not find the gun.
then
went into Epstein's briefcase and removed
approximately $1900. in one hundred dollar bills from a
white envelope.
said after taking the money
immediately left the house
said on Sunday morning, 10/05/03, at
approximately 0500 hours,
decided to return to 358
El Brillo in order to steal money once again from
Epstein.
said
once again drove
white
Caravan to the house and parked in the driveway.
entered the house through the sliding glass door and
entered the office.
opened the briefcase
and removed $5600. in one hundred dollar bills from a
white envelope.
left through the same
glass door and drove away.
believed
wore a creme colored loafers, light colored pants a
short sleeve shirt, and a baseball hat.
did
not wear gloves on
hands.
said
needed the
money to pay for
immigration papers.
I asked
if
was still suicidal.
was
not and that
was seeing a psychologist on a weekly
basis. (this was verified by
once again denied taking a gun from Epstein's house.
had a talk with Mr. Epstein on 10/12/03,
and they agreed
would pay Epstein back for all the
money that was taken.
03/25/2015
Page 63 of 95
Public Records Request No.: 16-268
EFTA00029771

=== Page 12 ===
Date: 9/01/06
PALM BEACH POLICE DEPARTMENT
Page:
12
Time: 13:38:06
Incident Report
Program: CMS301L
1-03-001498 (Continued)
I placed the Miranda Rights card along with the VCR
tape of
admission, into evidence.
ATTN POLICE CLERKS: Please add the following
names and their information into the system.
NARRATIVE # 8
Reported By:
11/12/03
Entered By.:
11/12/03
On 10/08/03, Officer
advised me that he had located
the vehicle parked in parking space #6, at the
Condominium. Officer
further advised that
vehicle was a Ford Explorer, dark in color, bearing Florida tag
On 10/13/03, I was advised by Sgt.
that Epstein had met
with
and had reached an agreement to pay back the money
taken and subject Epstein did not wish to prosecute at this time.
I was also advised that Det.
had interviewed
and
had obtained a full confession on the theft of the money but had
denied taking the Glock hand gun.
In previous conversations, Epstein was not sure of the location
of the hand gun but believed it had possibly been between the
books behind his desk. The surveillance video does not show
taking the hand gun and
denies taking the gun.
On 10/15/03, at 1400 hours, I faxed the affidavit of prosecution
to Epstein asking that he complete the document indicating that
he does not wish to prosecute and fax it back to me along with
mailing the original back to me for my case file.
At 1500 hours, Det.
removed the video surveillance
equipment from Epstein's residence located at 358 El Brillo.
Several attempts to obtain the affidavit of prosecution
indicated that Epstein did not wish to prosecute were met
with no response from his staff. It should be noted that
Epstein had personally met with Capt.
and at
that time advised he no longer wished to prosecute
for the burglary and theft from his residence.
ATTN POLICE CLERKS: Please show a full recovery of the U.S.
Currency. Please do not show the Glock hand gun as stolen.
03/25/2015
Page 64 of 95
Public Records Request No.: 16-268
EFTA00029772

=== Page 13 ===
Date: 9/01/06
PALM BEACH POLICE DEPARTMENT
Page:
13
Time: 13:38:06
Incident Report
Program: CMS301L
1-03-001498 (Continued)
Please show this case as **Except.Cleared** as the identity
of the suspect was established, there was enough information
to support an arrest, the exact location of the offender is
known and the victim declines to prosecute.
END OF REPORT
*
03/25/2015
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=== Page 1 ===
From:
To:
)"
)"
)"
Subject: FW: Jeffrey Epstein Victim; Ms
,
17 years old
Date: Fri, 22 Nov 2019 18:16:50 +0000
Can you send to FBI.
From:
Sent: Thursday, November 21, 2019 8:12 PM
To:
Subject: Jeffrey Epstein Victim; Ms
17 years old
I am a very close friend of Ms.
and her guardian, Ms.
of Calderitas, Mexico. Ms.
was abused by
Jeffrey Epstein on numerous occasions at his townhome in New
York and his caribbean island home in the Virgin Islands. They
both have expressed their interest in asking me to register her claim
as a victim in any case involving Mr. Epstein's estate, which she
believes she may have a claim.
She does not have legal representation yet, but is in negotiations to
retain and attorney soon.
Regards,
EFTA00029639


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=== Page 1 ===
Event:
counsel call
Start Date: 2019-07-09 14:00:00 +0000
End Date: 2019-07-09 14:30:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2019-07-08 02:33:57 +0000
Date Modified: 2019-07-08 02:33:57 +0000
Priority: 5
DTSTAMP: 2019-07-08 02:20:23 +0000
Attendee:
)
i
;
)
Alarm: Display the following message 15m before start
Reminder
EFTA00030820


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=== Page 1 ===
From:
To:
Subject: RE: Epstein review
Date: Wed, 04 Sep 2019 15:58:59 +0000
Importance: Normal
I think it was only 3 or 4 GB of data.
Original Message
From:
Sent: Wednesday, September 4, 2019 11:58 AM
To:
Subject: RE: Epstein review
Looping in
he will know better.
,
Thanks,
Original Message
From:
Sent: Wednesday, September 04, 2019 11:03 AM
To:
Subject: Epstein review
Hi
,
Do you happen to know how much data was on the drive we gave you last week? Just trying to get a sense of the
scale of the anticipate review.
Thanks!
Sent from my iPhone
EFTA00030452


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: Re: Epstein VNS
Date: Fri, 31 Jul 2020 01:23:47 +0000
Thank you!
On Jul 30, 2020, at 9:15 PM,
(USANYS)
wrote:
Will do
Sent from my iPhone
On Jul 30, 2020, at 12:20 PM,
)
wrote:
Hi
When you are back from leave, would you please check to see what, if any, VNS notifications have been sent out to the
below individuals for the Epstein case?
EFTA00030794

=== Page 2 ===
Thanks very much,
EFTA00030795


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=== Page 1 ===
From:
)"
To:
)
Cc:
)"
)"
Subject: RE: Continued investigation into possible collaborators of Jeffrey Epstein
Date: Tue, 17 Sep 2019 21:30:51 +0000
Perfect, thank you!
From
Sent: Tuesday, September 17, 2019 5:30 PM
To:
)
>; Hamilton,
)
Cc:
is
)
Subject: RE: Continued investigation into possible collaborators of Jeffrey Epstein
Yes! Saved here:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018801618\Investigation\Attorney General Files
From:
)
Sent: Tuesday, September 17, 2019 5:19 PM
To: Dunbar, Madison (USANYS) [Contractor]
>; ; Hamilton,
)
Cc:
is
)
Subject: FW: Continued investigation into possible collaborators of Jeffrey Epstein
Hi guys,
Would one of you please download the files referenced in the below email and save them on the Epstein share?
Thanks,
From:
Sent: Tuesday, September 17, 2019 2:05 PM
To:
)
Cc: Clara Moran
Subject: Continued investigation into possible collaborators of Jeffrey Epstein
Ms.
Please see the attached correspondence from Chief Deputy Attorney General Clara Moran.
You can access the materials referenced in the letter by following this link and entering this password:
NMAG files
Password (without quotes) -- "7e4DzyfvYC"
Note that this link will expire on October 16, 2019.
EFTA00030745

=== Page 2 ===
A CD containing this correspondence and the attached materials will also be arriving shortly via U.S. Mail.
Have a good day.
Assistant Attorney General
EFTA00030746


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=== Page 1 ===
From:
To:
Subject: RE: GM
Date: Wed, 01 Jul 2020 13:19:15 +0000
We could also unseal but not have the press office blast it out to the world until tomorrow morning. It's, of course,
possible word gets out that she's been arrested and folks start asking for it (at which point I assume we could then give it
to them), although I don't think the Epstein arrest did get out immediately, somewhat surprisingly.
That said, I also don't have any problem putting out the indictment this afternoon and announcing there will be a press
conference first thing tomorrow morning. I know Audrey has some concerns about that, but subject to the views of the
press office, I would think a little delay teased with the details in the indictment would heighten, not diminish, interest in
the press conference.
From
Sent: Wednesday, July 1, 2020 9:15 AM
To:
Subject: Re: GM
We did. The difference is that the courthouse was closed. I think we would do that if it were after business hours. The
question is whether the same thing applies if she is arrested at 2 p.m. today.
On Jul 1, 2020, at 9:11 AM
wrote:
I just looked back at what we did on Epstein, because we obviously dealt with the same issue of him being arrested a
day or two before the press conference. It looks like we kept it under seal (but gave his lawyers a copy) until Monday
morning, and did the press conference shortly thereafter.
That said, I don't feel strongly, particularly if she's arrested late this afternoon, and we plan to do press conference early
tomorrow morning.
From:
Sent: Wednesday, July 1, 2020 9:07 AM
To:
Subject: Re: GM
Even 1 pm is sort of late to do a conference today. What are your thoughts about unsealing if she is arrested during
business hours while our clerk's office is open, but isn't presented until tomorrow?
On Jul 1, 2020, at 9:03 AM,
wrote:
FYI, the presentment cut off in DNH is 1pm, and if we miss it, she'll get held in a local jail until tomorrow morning.
Consistent with your views this morning, I might propose that we suggest to Audrey and the press office that if we
don't have her by 1, we plan to put off the press conference until tomorrow morning, since at that point she won't be
presented until tomorrow in any event.
EFTA00031105

=== Page 2 ===
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=== Page 1 ===
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
April 14, 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 number SDNY_GM_02753398.
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:
Bates Start
Bates End
Summary Description
Confidential
Designation
SDNY GM 02753398
SDNY_GM_02753398
Photograph
Confidential
EFTA00031440

=== Page 2 ===
Page 2
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
EFTA00031441


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 11164814(1) approved by
now awaiting further approval
Date: Wed, 03 Jun 2020 14:34:24 +0000
Importance: Normal
Dear
Final voucher 11164814(1) has been approved by
, now awaiting further approval.
Trip ID: 11164814
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13444 - Epstein Investigation - Witness interview
Destination: Santa Monica, CA, United States
Dates: 2019-12-15 - 2019-12-18
Current status: Pending Voucher Approval
Voucher total expenses: 308.30
Estimated trip cost: 574.30
E2 Single Sign On Login (within DOJ Network Only):
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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.
EFTA00031832


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 12, 2020
VIA EMAIL
Jeffrey S. Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, CO 80203
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Mr. Pagliuca:
The Government writes in response to your letter dated August 9, 2020 requesting to use
discovery materials produced by the Government in the above-referenced criminal case bearing
Bates Nos. SDNY_GM_00000834 through SDNY_GM_00000962 (the "Unsealing Materials") to
litigate a civil lawsuit.
As an initial matter, the Government notes that it remains unclear whether you make this
request in your capacity as defense counsel to Ms. Maxwell in the above-referenced criminal case,
or in your capacity as her attorney in a separate civil matter. If the former, the Government
maintains that the "Confidential" designation of the Unsealing Materials is appropriate because
Chief Judge Colleen McMahon and Magistrate Judge Sarah Netburn have ordered that the
Unsealing Materials remain under seal. The only exceptions to those sealing orders are the
production of Chief Judge McMahon's April 9, 2019 Order (Bates Nos. SDNY_GM_00000904
through SDNY_GM_00000905) to Boies Schiller & Flexner LLP, and production of the entirety
of the Unsealing Materials to Ms. Maxwell as discovery in the above-referenced criminal case.
The Unsealing Materials relate to an ongoing criminal investigation, and their public disclosure at
this stage risks interference with that investigation. Moreover, the Protective Order issued by
Judge Alison J. Nathan in the above-referenced criminal case expressly provides that any and all
discovery material produced to the defendant by the Government, regardless of designation,
"[s]hall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this
criminal action, and not for any civil proceeding or any purpose other than the defense of this
action." (Protective Order, ECF No. 36, dated July 30, 2020, 11 1(a), 10(a), 14(a)). The
Government notes that counsel for Ms. Maxwell expressly consented to that limitation when
negotiating the Protective Order in the criminal case. Accordingly, regardless of designation, the
Protective Order expressly prohibits use of any discovery materials produced by the Government
in the above-referenced criminal case in any civil case.
EFTA00030904

=== Page 2 ===
Page 2
To the extent you make this request in your capacity as counsel to Ms. Maxwell in civil
litigation, you are welcome to avail yourself of requests for records through the Freedom of
Information Act or through a Toughy request, in the same manner as any other litigant seeking to
use records from a federal criminal investigation in a civil case. If you wish to make such a request,
the undersigned can refer you to the appropriate Assistant United States Attorney in our office's
Civil Division, who will process your request.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
By:
/
/
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324
EFTA00030905


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=== Page 1 ===
From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:12:12 +0000
Inline-Images: image001.png
Thank you!
From:
Sent: Thursday, July 02, 2020 13:38
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Great work team!
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
UNITED QUI PRO DOMINA JUSTITIA OF SOFFICE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
EFTA00031491

=== Page 2 ===
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
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.
EFTA00031492

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
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=== Page 1 ===
From:
Subject: RE: Epstein/JPM
Date: Mon, 02 Dec 2019 15:17:31 +0000
On scheduling, I'm free this morning as well.
From:
Sent: Monday, December 2, 2019 10:10 AM
To:
Subject: Re: Epstein/JPM
On Dec 2, 2019, at 10:03 AM,
wrote:
From:
Sent: Monday, December 2, 2019 9:57 AM
To:
is
>;
Subject: Fwd: Epstein/JPM
Other than a 10:15am call, I'm free this morning.
Begin forwarded message:
From:
Date: December 2, 2019 at 9:45:41 AM EST
To:
Cc:
(USANYS)"
Subject: RE: Epstein/JPM
Hope everyone had a good Thanksgiving. Whenever at least some of you are free, can we chat briefly on this
at some point this morning?
Original Message
From:
Sent: Thursday, November 28, 2019 1:21 PM
To:
Cc:
i
EFTA00029645

=== Page 2 ===
i
(USANYS)
Subject: Re: Epstein/JPM
And happy to chat
in more detail tomorrow or early next week (or today or this weekend too if that's helpful). Thanks.
Sent from my iPhone
Also happy to chat by phone if that's easier.
Sent from my iPhone
EFTA00029646


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=== Page 1 ===
From:
"
)"
To:
"
(NY) (FBI)"
Subject: FW:
)
- Epstein
Date: Fri, 14 May 2021 19:26:46 +0000
Attachments:
Proffer_Letter.PDF
Hi
When you have a chance, could you please initial the proffer agreement and send it back to me? Thanks!
From: Joe Nascimento
Sent: Friday, May 14, 2021 2:56 PM
To:
Cc:
(USANYS)
is
)
Subject: Re:
)
- Epstein
Hi
,
Thanks again for your time today. Attached, please find a copy of the proffer agreement with updated initials.
Have a nice weekend,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
EFTA00029694


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: Premises SW
Date: Thu, 02 Jul 2020 10:21:53 +0000
Attachments: SDNY_Premises_Search_Warrant_Bundle_(revised).pdf
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
0007
EFTA00031518


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=== Page 1 ===
Subject: RE: Epstein Passport Photos
Date: Wed, 17 Jul 2019 20:36:03 +0000
Got it, thanks.
Subject: RE: Epstein Passport Photos
Yes nine total.
On Jul 17, 2019 3:23 PM,
rote:
thanks very much for these. To confirm, we've received three emails, with nine photos total -- let us know if that's
everything or if we should have received (or should be expecting) more? And thanks again.
Sent: Wednesday, July 17, 2019 14:48
Subject: Epstein Passport Photos
Please let me know if there are issues opening and I can resend. Due to size, had to send multiple emails.
Thanks,
FBI New York - C20
VCAC/Human Trafficking
EFTA00030613


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=== Page 1 ===
From:
"
N. (NY) (FBI)"
To:
)"
Subject: Manifests and notes
Date: Mon, 17 Jun 2019 13:53:41 +0000
Attachments: Passenger_manifest_N908JE_9.2004.pdf; Passenger_Manifest_N909JE_9.2004.pdf;
interview_notes_5.29.19.pdf
Special Agent
FBI New York
VCAC/Human Trafficking
C:
O:
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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Epstein Victim Impact Statements
Date: Wed, 30 Oct 2019 17:22:40 +0000
Attachments: 2019-08-27,_nolle_conference.pdf
For the first question, the AUSAs contacted the attorneys we were aware of who represented victims to tell them that
their clients were welcome to attend and to make a statement. I believe
also sent out notifications, and hopefully
she can tell us how many she sent.
For the second question, based on my review of the transcript (attached), a total of 17 victims were present at the hearing
and either spoke at the hearing or had someone read a statement for them. An additional 7 did not attend the hearing
but had someone else speak for them or read a statement from them. It is possible there were others present who were
not referenced on the record.
I don't think we can answer the third question. I don't recall anyone off the top of my head who wanted to attend but
was unable to, but it's possible there were some in that position.
From:
(USANYS)
Sent: Wednesday, October 30, 2019 1:06 PM
To:
is
is
is
(USANYS)
Cc:
(USANYS)
Subject: FW: Epstein Victim Impact Statements
Importance: High
Are we able to answer these questions for ODAG quickly? I am sure we can answer the second, and maybe the first - not
sure about the third.
From:
(ODAG)
Sent: Wednesday, October 30, 2019 12:53 PM
To:
(USANYS)
Cc:
(ODAG)
Subject: Epstein Victim Impact Statements
Importance: High
,
The Petitioner in the Epstein CVRA case has filed an appeal to the 11th Circuit. One of their issues is the
District Court's refusal to hold a hearing allowing the Epstein victims to "have their day in court." The
Court's ruling is, in part, on the basis that a hearing held in SDNY satisfied this request. The Petitioner has
alleged that not all of the Epstein victims who wanted to speak were able to do so at the New York hearing
because they did not have sufficient notice and were unable to travel to NY.
EFTA00031395

=== Page 2 ===
Can your office provide us some details about the following: 1) how many victims were contacted about
making a victim impact statement; 2) how many victims were able to travel and make an in-person victim
impact statement; and 3) how many victims indicated they wanted to make a victim impact statement but
were unable to do so given the notice/timing of the hearing?
Please provide as much of this information as possible today. I'm very sorry for the quick turnaround but
the Department's response to the mandamus petition is due tomorrow.
I really appreciate your assistance.
National Coordinator for Child Exploitation Prevention & Interdiction
Office of the Deputy Attorney General
EFTA00031396


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=== Page 1 ===
From:
To:
Subject: F W: Onisiame Maxwen
Date: Wed, 14 Apr 2021 03:00:55 +0000
Hi
See below from Maxwell's attorney. I have no problem with Maxwell being able to read her legal paperwork while she's
sitting in the cell block if the Marshals are ok with it.
Thanks,
From: BOBBI c STERNHEIM
Sent: Tuesday, April 13, 2021 7:38 PM
To:
Cc: Christian Everdell
Subject: Ghislaine Maxwell
Good evening-
Might you have any sway in persuading the Marshal permit Ms. Maxwell
to have her legal materials while in the cell block?
She arrived today at ~ 5:15 am and remained idle in the cell block
until ~ 8:30 am when she was brought to the fifth floor.
Otherwise, any opposition to me contacting the Court for an order
(per the Marshal)?
Enjoy the evening. See you tomorrow.
Best-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
EFTA00031432

=== Page 2 ===
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.
EFTA00031433


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE:
Date: Fri, 26 Jun 2020 15:34:35 +0000
I know this is a sensitive subject with the team, but do you think we have enough in the indictment to support the
interstate travel component necessary to both sets of charges? We certainly allege that the victims were abused in
multiple states which give rise to an inference of travel, but in terms of the enticing/causing to travel, this is about all we
have:
GHISLAINE MAXWELL, the defendant, and Jeffrey 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.
That is probably sufficient to survive a motion to dismiss, but do you think it is worth pushing the team to try to add
more?
From:
(USANYS)
Sent: Friday, June 26, 2020 10:30 AM
To:
(USANYS)
Subject:
Should we actually be including
name in the indictment as we do?
EFTA00030504


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=== Page 1 ===
From: "Berman, Geoffrey (USANYS)"
To:
"
(USANYS)"
(USANYS)"
>, ,
(USANYS)"
Subject: Ghislaine Maxwell seeks court delay due to Epstein probe - New York Daily News
Date: Wed, 20 May 2020 03:10:28 +0000
https://www.nydailynews.com/new-york/ny-maxwell-delay-criminal-investigation-epstein-20200519-
zxtbjulbuvgdzixkyi7ly3j6um-story.html
EFTA00030976


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=== Page 1 ===
From:
To:
Subject: RE: Epstein -- travel approval form
Date: Fri, 31 Jan 2020 18:47:31 +0000
I haven't heard anything - I would email
and see who it's with on 8.
From:
Sent: Friday, January 31, 2020 13:47
To:
Subject: RE: Epstein -- travel approval form
Any updates on the signed memo?
said I need to email it to EOUSA this afternoon.
From:
Sent: Friday, January 31, 2020 12:53 PM
To:
Cc:
Subject: RE: Epstein -- travel approval form
Already signed and sent upstairs
I will do my best to ensure signature immediately.
Re: this afternoon: it may be best to kick it to next week. If some time develops before 3, I'll let you know, but right now
it is iffy.
From:
Sent: Friday, January 31, 2020 12:21 PM
To:
Cc:
Subject: Epstein -- travel approval form
We dropped off the Sweden travel memo for you - we were unexpectedly significantly delayed in getting OIA approval,
but it finally came this morning, so with apologies for the short turnaround, hoping to get Office and final DOJ approval
this afternoon. Thank you!
And separately, if you still wanted to meet up today, l'll be around until about 3:00, but I'm also flexible next week if that's
easier.
thanks again,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
Event: Epstein estate call
Start Date: 2019-12-02 15:30:00 +0000
End Date: 2019-12-02 16:00:00 +0000
Organizer: Weinstein, Marc A. <marc.weinstein@hugheshubbard.com>
Location: Skype Meeting; Conference ID: 169 269 771;
Class: X-PERSONAL
Date Created: 2019-11-25 14:54:20 +0000
Date Modified: 2019-11-25 14:54:20 +0000
Priority: 5
DTSTAMP: 2019-11-25 14:30:58 +0000
Attendee:
)
i
i
)
>; Tomback, Andrew
<andrew.tomback@whitecase.com>
Alarm: Display the following message 15m before start
Reminder
Dial-In Information (for meetings with no presentations or video)
Dial-In Number:
+1 (201) 630-0824
Conference ID:
169269771
One touch dial-in from mobile phone (via cellular service)
Additional Dial-In Numbers
Brazil
+55 11 3181-5692
Canada
+1 647-749-1240
China
+86 400 842 8305
France
+33 1 73 24 04 53
Germany
+49 69 667737017
India
+91 22 6001 6148
Ireland
+353 1 566 1143
Israel
+972 3 3762055
Japan
+81 3-4510-7259
Singapore
+65 3157 0147
United Kingdom
+44 20 3443 6288
United States
+1 (201) 630-0824
EFTA00029637

=== Page 2 ===
Full list of dial-in numbers
Meetings with a presentation or video
Connect from computer or mobile device (via network/internet connection)
Help
Try Skype Web App if you are having trouble joining
Joining from a computer using the "Connect from computer or mobile device" link provides
additional capabilities, however you can simply call in from your telephone using the number
provided above if your meeting will not include video or a presentation. Click the "Help" link for
additional information if you are a guest joining a Skype for Business meeting from your
computer or mobile device for the first time.
For meeting organizers: Reset your dial-in PIN?
+12016300824
[!OC([CUSTOMINVITE]):)
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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: protective order and draft affidavit
Date: Tue, 28 Jul 2020 19:04:29 +0000
Attachments: : 2020-07-25,_GM,_protective_order_clean_version.docx;2020-07-
28,GM,_affidavit_of_certification,_Rule_16,_protective_order.docx
As promised. I've never done one of these affidavits before, so very happy for any suggestions on that in particular.
EFTA00029876


c1: EFTA00029713
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029713.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: 3 phone call came in on our 800 line
Date: Thu, 15 Aug 2019 15:38:52 +0000
She wants to talk to an agent about a coconspirator. She dated him and he was friends with Epstein.
A concerned
that would like to see the evidence in Epstein case be made public. He asked a lot of questions wants
to know who is getting indicted next and said if they are high profile people like the news is reporting are you going to do
anything about it. Really pushy wants to know what evidence we have against people and when we are going to indict
some of these people. Wants to know what was in the safe. (Really)
vanted to tell us that Epstein gave money to
children's home in
and that place is a
training children in child pornography and trafficking children.
Victim Witness Coordinator
United States Attorney's Office
Southern District of New York
1 St. Andrews Plaza
New York, New York 10007
EFTA00029713


c1: EFTA00030852
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030852.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
FedEx.
Invoice Number: 4-397-85573
Invoice Date:
Oct 14, 2002
Account Number:
1144-2081-6
Page:
1 of 9
FedEx Tax ID: 71-0427007
JEFFREY E EPSTEIN
457 MADISON AVE
NEW YORK NY 10022-6843
Billing Account Shipping Address:
Invoice Questions?
JEFFREY E EPSTEIN
457 MADISON AVE
FedEx Account Services
NEW YORK NY 10022-6843 US
Phone:
(800) 622-1147 M-F 7-6 (CST)
Fax:
(800) 548-3020
Internet: www.fedex.com
Invoice Summary Oct 14, 2002
FedEx Express Services
Transportation Charges
301.70
Base Discount
-33.94
Special Handling Charges
36.58
Total Charges
USD.$
304.34
TOTAL THIS INVOICE
USD $
304.34
You saved $33.94 in discounts this period!
The FedEx Ground accounts referenced in this invoice have been transferred and assigned to, are owned by, and are payable to FedEx Express.
To ensure proper credit, please return this portion with your payment to FedEx.
Please do not staple or fold. Please make your check payable to FedEx.
For change of address, check here and complete form on reverse side
Invoice
Account
Amount
Number
Number
Due
Remittance Advice
Your payment is due by Oct 29, 2002
4-397-85573
1144-2081-6
USD $ 304.34
114420814397855737800003043454
SP 01 000001 97702 A 1 ASNGLP
JEFFREY E EPSTEIN
FedEx
457 MADISON AVE
P.O. Box 371461
NEW YORK NY 10022-6843
Pittsburgh PA 15250-7461
EFTA00030852

=== Page 2 ===
FedEx.
Invoice Number: 4-397-85573
Invoice Date:
Oct 14, 2002
Account Number:
1144-2081-6
Page:
2 of 9
Adjustment Request
FAX TO (800) 548-3020
Tracking No./Airbill No.
Reason Code
Explanation
BEFORE YOU FAX
REASON CODE KEY
Reason
Please include detailed explanation for each adjustment request.
Code
Description
DUP
Duplicate Billing
Remember to include recipient's account number or third party's
PND
Shipment Never Sent
account number if applicable.
RATE
Incorrect Rates or Pieces
RRA
Rebill Recipient Include
From:
Recipient's Account No.
RSA
Rebill Sender
RTA
Rebill Third Party Include
Third Party's Account No.
Name
Date
SUR
Incorrect Surcharge
Please Explain
(
)
(
)
OTHR
Other - Please Explain
Business Phone
Business Fax
This form cannot be used to request Invoice Adjustments due to Service Failures or lack of a POD.
To request adjustments for Service Failures or lack of a POD, please call 1-800-622-1147,
visit our internet site at www.fedex.com or register for FIO.
FedEx
Federal Express
Please indicate change in address for the account # listed below:
Physical Address
Billing Address
Mailing Address
Account Number: 1144-2081-6
Name:
Address:
Apt. Suite:
City:
State:
Zip:
Phone: (
)
Fax: (
}
Authorizing Signature:
EFTA00030853

=== Page 3 ===
FedEx.
Invoice Number: 4-397-85573
Invoice Date:
Oct 14, 2002
Account Number:
1144-2081-6
Page:
3 of 9
FedEx Express Payment Type Summary
Original
Shipper
Number of Airbills
11
Transportation Charges
256.70
Base Discount
-29.44
Special Handling Charges
35.57
TOTAL
USD $
262.83
Number of Airbills
11
Total Charges
USD $
262.83
Recipient
Number of Airbills
1
Transportation Charges
45.00
Base Discount
-4.50
Special Handling Charges
1.01
TOTAL
USD $
41.51
Number of Airbills
1
Total Charges
USD $
41.51
TOTAL AIRBILLS
12
TOTAL CHARGES
USD $
304.34
EFTA00030854

=== Page 4 ===
FedEx.
Invoice Number: 4-397-85573
Invoice Date:
Oct 14, 2002
Account Number:
1144-2081-6
Page:
4 of 9
FedEx Express Payment Type Detail (Original)
Dropped off: Oct 02, 2002
Payor: Shipper
Reference: NO REFERENCE INFORMATION
FedEx Internal Use: 423530768/01574/
Fuel Surcharge FedEx has applied a fuel surcharge of 2.50% to this shipment.
Package sent from: 33461 zip code
Distance Based Pricing. Zone 6
InternetShip
Sender
Recipient
Tracking ID 790606208535
Service Type FedEx Priority Overnight
JEFFREY E EPSTEIN
EPSTEIN INTERESTS
Package Type FedEx Box
457 MADISON AVE
457 MADISON AVE.
Zone
6
NEW YORK NY 10022-6843 US
NEW YORK NY 10022 US
Pieces
1
Weight
2.0 lbs, 0.9 kgs
Transportation Charge
27.50
Delivered
Oct 03. 2002 09:47
Discount
-2.75
Service
Fuel Surcharge
0.62
Area Code
A1
Signed by
Total Transportation Charges
USD $
25.37
Bundle ID
000
Picked up: Oct 03, 2002
Payor: Shipper
Reference: NO REFERENCE INFORMATION
FedEx Internal Use: 281229300/06112/_/08
Fuel Surcharge FedEx has applied a fuel surcharge of 2.50% to this shipment.
The delivery commitment for FedEx 2day to homes or private residences (Including home offices) is 7 P.M. the second business day for A1, A2, AA, A3, AM, PM, 01 and RM service areas.
Package sent from: 10021 zip code
1st attempt Oct 07. 2002 at 01:34 PM.
Recipient not in/business closed.
Distance Based Pricing, Zone 8
Tracking ID 835377097329
Sender
Recipient
Service Type FedEx 2Day
J EPSTEIN
Package Type FedEx Pak
JEFFREY E EPSTEIN
Zone
8
457 MADISON AVE
Pieces
1
NEW YORK NY 10022-6843 US
Weight
3.0 lbs, 1.4 kgs
Delivered
Oct 08, 2002 09:36
Transportation Charge
13.00
Service
Discount
-1.30
Area Code
2R
Declared Value Charge
2.50
Signed by
Fuel Surcharge
0.29
Dec. Value
USD 400.00
Courier Pickup Charge
0.00
Bundle ID
000
Residential Delivery
1.35
Total Transportation Charges
USD $
15.84
EFTA00030855

=== Page 5 ===
FedEx.
Invoice Number: 4-397-85573
Invoice Date:
Oct 14, 2002
Account Number:
1144-2081-6
Page:
5 of 9
FedEx Express Payment Type Detail (Original)
Dropped off: Oct 04, 2002
Payor: Shipper
Reference: NO REFERENCE INFORMATION
FedEx Internal Use: 523069950/01574
Fuel Surcharge FedEx has applied a fuel surcharge of 2.50% to this shipment.
Distance Based Pricing. Zone 6
FedEx has audited this airbill for correct pieces, weight, and service. Any changes made are reflected in the invoice amount.
InternetShip
Sender
Recipient
Tracking ID 791950635390
JEFFREY E. EPSTEIN
Service Type FedEx Priority Overnight
JEFFREY E EPSTEIN
358 EL BRILLO WAY
Package Type FedEx Pak
457 MADISON AVE
PALM BEACH FL 33480 US
Zone
6
NEW YORK NY 10022-6843 US
Pieces
1
Weight
2.0 lbs, 0.9 kgs
Transportation Charge
27.50
Delivered
Oct 05, 2002 11:37
Discount
-2.75
Service
Saturday Delivery
10.00
Area Code
AA
Fuel Surcharge
0.62
Signed by
Residential Delivery
1.35
Bundle ID
000
Total Transportation Charges
USD $
36.72
Dropped off: Oct 04, 2002
Payor: Shipper
Reference: NO REFERENCE INFORMATION
FedEx Internal Use: 523073600/00244/
Fuel Surcharge FedEx has applied a fuel surcharge of 2.50% to this shipment.
Distance Based Pricing, Zone 6
InternetShip
Sender
Recipient
Tracking ID
791950795116
Service Type FedEx Standard Overnight
JEFFREY E EPSTEIN
Package Type FedEx Envelope
457 MADISON AVE
Zone
6
NEW YORK NY 10022-6843 US
Pieces
1
Weight
1.0 lbs. 0.5 kgs
Transportation Charge
14.20
Delivered
Oct 07. 2002 14:23
Discount
-2.27
Service
Fuel Surcharge
0.30
Area Code
Signed by
Total Transportation Charges
USD $
12.23
Bundle ID
000
Dropped off: Oct 04, 2002
Payor: Shipper
Reference: NO REFERENCE INFORMATION
FedEx Internal Use: 523097400/00252/
Fuel Surcharge FedEx has applied a fuel surcharge of 2.50% to this shipment.
Distance Based Pricing. Zone 8
InternetShip
Sender
Recipient
Tracking ID
792113466464
Service Type FedEx Priority Overnight
JEFFREY E EPSTEIN
Package Type FedEx Envelope
457 MADISON AVE
Zone
8
NEW YORK NY 10022-6843 US
Pieces
1
Weight
1.0 lbs, 0.5 kgs
Transportation Charge
17.25
Delivered
Oct 07. 2002 08:48
Discount
-2.76
Service
Fuel Surcharge
0.36
Area Code
A1
Signed by
Total Transportation Charges
USD $
14.85
Bundle ID
000
EFTA00030856

=== Page 6 ===
FedEx.
Invoice Number: 4-397-85573
Invoice Date:
Oct 14, 2002
Account Number:
1144-2081-6
Page:
6 of 9
FedEx Express Payment Type Detail (Original)
Picked up: Oct 04, 2002
Payor: Shipper
Reference: NO REFERENCE INFORMATION
FedEx Internal Use: 282108790/01574
Fuel Surcharge FedEx has applied a fuel surcharge of 2.50% to this shipment.
Package sent from: 10021 zip code
Distance Based Pricing. Zone 6
Tracking ID 835377097318
Sender
Recipient
Service Type FedEx Priority Overnight
Package Type FedEx Box
JEFFREY E EPSTEIN
Zone
6
457 MADISON AVE
PALM BEACH FL 33480 US
Pieces
1
NEW YORK NY 10022-6843 US
Weight
7.0 lbs, 3.2 kgs
Delivered
Oct 05, 2002 11:37
Transportation Charge
41.50
Service
Discount
-4.15
Area Code
AA
Saturday Delivery
10.00
Signed by
Fuel Surcharge
0.93
Bundle ID
000
Courier Pickup Charge
0.00
Residential Delivery
1.35
Total Transportation Charges
USD $
49.63
Picked up: Oct 07, 2002
Payor: Shipper
Reference: NO REFERENCE INFORMATION
FedEx Internal Use: 523187550/01596/_/02
Fuel Surcharge FedEx has applied a fuel surcharge of 3.00% to this shipment.
Distance Based Pricing. Zone 7
Release signature on file.
InternetShip
Sender
Recipient
Tracking ID
790099789349
Service Type FedEx Priority Overnight
JEFFREY E EPSTEIN
Package Type Customer Packaging
457 MADISON AVE
Zone
7
NEW YORK NY 10022-6843 US
Pieces
1
Weight
4.0 lbs. 1.8 kgs
Transportation Charge
34.25
Delivered
Oct 08, 2002 12:20
Discount
-3.43
Service
Fuel Surcharge
0.92
Area Code
RM
Residential Delivery
1.35
Signed by
7279326
Delivery Area Surcharge
1.50
Bundle ID
000
Total Transportation Charges
USD $
34.59
Picked up: Oct 07, 2002
Payor: Shipper
Reference: NO REFERENCE INFORMATION
FedEx Internal Use: 523233530/00230/
Fuel Surcharge FedEx has applied a fuel surcharge of 3.00% to this shipment.
Distance Based Pricing, Zone 6
InternetShip
Sender
Recipient
Tracking ID
791952200365
Service Type FedEx Priority Overnight
JEFFREY E EPSTEIN
Package Type FedEx Envelope
457 MADISON AVE
Zone
6
NEW YORK NY 10022-6843 US
Pieces
1
Weight
1.0 lbs. 0.5 kgs
Transportation Charge
16.00
Delivered
Oct 08. 2002 09:23
Discount
-2.56
Service
Fuel Surcharge
0.40
Area Code
AA
Signed by
Total Transportation Charges
USD $
13.84
Bundle ID
000
EFTA00030857

=== Page 7 ===
FedEx.
Invoice Number: 4-397-85573
Invoice Date:
Oct 14, 2002
Account Number:
1144-2081-6
Page:
7 of 9
FedEx Express Payment Type Detail (Original)
Picked up: Oct 07, 2002
Payor: Shipper
Reference: NO REFERENCE INFORMATION
FedEx Internal Use: 282080050/00208/_/_
Fuel Surcharge FedEx has applied a fuel surcharge of 3.00% to this shipment.
Package sent from: 10001 zip code
Distance Based Pricing. Zone 4
Tracking ID 828694902046
Recipient
Service Type FedEx Priority Overnight
Package Type FedEx Envelope
JEFFREY E EPSTEIN
Zone
4
457 MADISON AVE
Pieces
1
NEW YORK NY 10022-6843 US
Weight
0
Delivered
Oct 08, 2002 08:57
Transportation Charge
15.25
Service
Discount
-2.44
Area Code
A1
Fuel Surcharge
0.38
Signed by
Bundle ID
000
Total Transportation Charges
USD $
13.19
Picked up: Oct 07, 2002
Payor: Shipper
Reference: NO REFERENCE INFORMATION
FedEx Internal Use: 283152360/01415/_/_
Fuel Surcharge - FedEx has applied a fuel surcharge of 3.00% to this shipment.
Package sent from: 10021 zip code
Distance Based Pricing, Zone 8
FedEx has audited this airbill for correct pieces, weight, and service. Any changes made are reflected in the invoice amount.
Tracking ID 835377097307
Sender
Recipient
Service Type FedEx Standard Overnight
GHISLAINE MAXWELL
Package Type FedEx Pak
JEFFREY E EPSTEIN
Zone
8
457 MADISON AVE
Pieces
1
NEW YORK NY 10022-6843 US
Weight
1.0 lbs. 0.5 kgs
Delivered
Oct OB. 2002 09:39
Transportation Charge
22.75
Service
Discount
-2.28
Area Code
A1
Fuel Surcharge
0.61
Signed by
Courier Pickup Charge
0.00
Bundle ID
000
Total Transportation Charges
USD $
21.08
Dropped off: Oct 08, 2002
Payor: Shipper
Reference: NO REFERENCE INFORMATION
FedEx Internal Use: 283080110/01574/_
Fuel Surcharge FedEx has applied a fuel surcharge of 3.00% to this shipment.
Package sent from: 33404 zip code
Distance Based Pricing. Zone 6
Tracking ID 837574509142
Sender
Recipient
Service Type FedEx Priority Overnight
Package Type FedEx Pak
JEFFREY E EPSTEIN
Zone
6
457 MADISON AVE
Pieces
1
NEW YORK NY 10022-6843 US
Weight
2.0 lbs, 0.9 kgs
Delivered
Oct 09. 2002 09:16
Transportation Charge
27.50
Service
Discount
-2.75
Area Code
A1
Fuel Surcharge
0.74
Signed by
Bundle ID
000
Total Transportation Charges
USD $
25.49
Payment Type Detail Subtotal
USD $
262.83
EFTA00030858

=== Page 8 ===
FedEx.
Invoice Number: 4-397-85573
Invoice Date:
Oct 14, 2002
Account Number:
1144-2081-6
Page:
8 of 9
FedEx Express Payment Type Detail (Original)
Dropped off: Oct 03, 2002
Payor: Recipient
Reference: NO REFERENCE INFORMATION
FedEx Internal Use: 278013420/01574/
Fuel Surcharge FedEx has applied a fuel surcharge of 2.50% to this shipment.
Package sent from: 33404 zip code
Distance Based Pricing. Zone 6
Tracking ID 837574511646
Sender
Recipient
Service Type FedEx Priority Overnight
Package Type FedEx Box
358 EL BRILLO WAY
Zone
6
PALM BEACH FL 33480 US
457 MADISON 4TH FL
Pieces
1
NEW YORK NY 10022 US
Weight
8.0 lbs, 3.6 kgs
Delivered
Oct 04, 2002 09:24
Transportation Charge
45.00
Service
Discount
-4.50
Area Code
A1
Fuel Surcharge
1.01
Signed by
Bundle ID
000
Total Transportation Charges
USD $
41.51
Payment Type Detail Subtotal
USD $
41.51
EFTA00030859

=== Page 9 ===
FedEx.
Invoice Number: 4-397-85573
Invoice Date:
Oct 14, 2002
Account Number:
1144-2081-6
Page:
9 of 9
FedEx Ground Reference Chart
SERVICE CODES
FEDEX HOME DELIVERY SERVICE CODES
ZONE DEFINITIONS
FedEx Ground
800
AutoPOD Prepaid
2-8
Ground Service 48 contiguous states
804
Prepaid
9
Service to Hawaii
808
Signature, Prepaid
10
Service to Puerto Rico
015
AutoPOD Prepaid, Domestic
810
Evening AutoPOD Prepaid
14
Service to Oahu
016
COD, Prepaid, Domestic
814
Evening. Prepaid
17
Service to Alaska
017
ECOD. Prepaid Domestic
818
Evening Signature Prepaid
22
Service within Alaska
018
FedEx Ground, PRP. Prepaid Domestic
820
Date Certain AutoPOD Prepaid
23
Service from Alaska
019
Prepaid, Domestic
824
Date Certain Prepaid
25
Service from Alaska
020
AutoPOD Collect, Domestic
828
Date Certain Signature, Prepaid
51 54 Service to Canada
021
Collect Domestic
830
Appointment AutoPOD, Prepaid
92 & 96 Service from Hawaii (Deferred)
030
COO. Collect, Domestic
834
Appointment Prepaid
031
ECOD, Collect, Domestic
835
Adult AutoPOD. Prepaid
032
Cash COD, Collect Domestic
836
Adult Signature, Prepaid
033
Guaranteed Funds COD. Collect, Domestic
837
Evening AdultPOD Prepaid
136
Ground Prepaid Net Return
838
Evening Adult Signature, Prepaid
408
Guaranteed Funds COD. Prepaid, Domestic
839
Date Certain, Adult AutoPOD. Prepaid
OTHER CHARGE CODE DEFINITIONS
409
Cash COD, Prepaid, Domestic
840
Date Certain, Adult Signature, Prepaid
410
AutoPOD COD, Prepaid Domestic
841
Appointment Adult Signature, Prepaid
411
AutoPOD. COD. Collect, Domestic
842
Appointment, AdultPOD Prepaid
412
AutoPOD ECOD, Prepaid, Domestic
(1)
C.O.D. (Collect on Delivery)
850
Bill 3rd Party
413
AutoPOD ECOD, Collect Domestic
(2)
A.O.D. (Acknowledgement of Delivery)
851
Bill 3rd Party, Auto POD
414
(3)
AutoPOD PRP, Prepaid, Domestic
Cal Tag
852
Bill 3rd Party, Signature
415
AutoPOD. Guaranteed Funds COD, Ppd. Dom
(4)
Oversize > 84" Combined Length and Girth
853
Evening Bill 3rd Party
416
AutoPOD, Cash COD. Prepaid, Domestic
(5)
Declared Value
854
Evening Bill 3rd Party, AutoPOD
417
Bill 3rd Party, Domestic
(6)
Address Correction
855
Evening Bill 3rd Party, Signature
418
3rd Party, AutoPOD Domestic
(7)
Hazardous Material
856
Date Certain Bill 3rd Party
419
Bill 3rd Party, COD. Domestic
(8)
Automatic Proof of Delivery
857
Date Certain, Bill 3rd Party, AutoPOD
420
Bill 3rd Party, Guaranteed Funds COD. Dom
(9)
Additional Handing
858
Date Certain Bill 3rd Party, Signature
(10)
Oversize Extra Service Fee
421
Bill 3rd Party, Cash COD, Domestic
859
Appointment, Bill 3rd Party
422
Bill Recipient, Domestic
(11)
Overweight 150 bs
860
Appointment, Bill 3rd Party, AutoPOD
423
Bill Recipient, AutoPOD Domestic
(12)
Electronic C.O.D., 24 hours
861
Bill 3rd Party, Adult AutoPOD
424
Bill Recipient, COD, Domestic
(13)
Electronic C.O.D. 48 hours
862
Bill 3rd Party, Adult Signature
425
Bill Recipient Guaranteed Funds COD. Dom.
(14)
FedEx Ground Residential
863
Evening. Bill 3rd Party, Adult AutoPOD
426
Bill Recipient, Cash COD. Dom
(15)
FedEx Ground Residential Rural
864
Evening Bill 3rd Party, Adult Signature
427
AutoPOO. Cash COD. Colect, Domestic
(16)
Net Return Transmission Fee
865
Date Certain, Bill 3rd Party, Adult AutoPOD
428
AutoPOD Guaranteed Funds COD, Collect Dom
(20)
FedEx Signature Home Delivery
866
Date Certain Bill 3rd Party, Adult Signature
429
ECOD, Bill 3rd Party, Domestic
(21)
FedEx Date Certain Home Delivery
869
Bill Recipient
430
AutoPOD, COD, Bill 3rd Party, Domestic
(22)
FedEx Appointment Home Delivery
870
Bill Recipient, AutoPOO
431
AutoPOD ECOD, Bill 3rd Party, Domestic
(23)
FedEx Evening Home Delivery
871
Bill Recipient, Signature
432
AutoPOD. Cash COD. Bill 3rd Party, Domestic
(24)
FedEx Home Delivery Residential
872
Evening Bill Recipient
(25)
433
AutoPOO. Guaranteed Funds COD, Bill 3rd Party, Dom.
FedEx Home Delivery Residential Rural
873
Evening Bill Recipient, AutoPOD
434
ECOD, Bill Recipient Domestic
(26)
Cash C.O.D. Charge
874
Evening. Bill Recipient, Signature
435
(27)
AutoPOD COD, Bil Recipient, Domestic
Cash C.O.D. High Density Charge
875
Date Certain Bill Recipient
436
AutoPOD. ECOD, Bill Recipient Domestic
(28)
Cash C.O.D. Extra Difference Charge
876
Date Certain, Bill Recipient AutoPOD
437
AutoPOD. Cash COD. Bill Recipient Domestic
(29)
Proof of Delivery Advantage Charge
877
Date Certain, Bill Recipient Signature
438
AutoPOD Guaranteed Funds COD, Bill Recipient, Dom.
(30)
FedEx Home Delivery Forced Appointment
878
Appointment Bill Recipient
(31)
FedEx Home Delivery Surcharge Out of Service Area
879
Appointment Bill Recipient AutoPOD
(32)
FedEx Home Delivery Surcharge Hazardous Material
FedEx International Ground
880
Bill Recipient Adult AutoPOD
(33)
FedEx Home Delivery Surcharge Over 70 Pounds
881
Bill Recipient, Adult Signature
(34)
FedEx Home Delivery Surcharge COD Package
882
Evening Bill Recipient, Adult AutoPOD
(35)
Fuel Surcharge
022
AutoPOD Prepaid
883
Evening Bill Recipient, Adult Signature
(36)
Oversize > 108" Combined Length and Girth
023
COO, Prepaid
884
Date Certain Bill Recipient Adult AutoPOD
(37)
Oversize > 108" in Length
024
ECOD, Prepaid
885
Date Certain, Bill Recipient Adult Signature
(38)
Oversize > 130" Combined Length and Girth
025
PRP. Prepaid
886
Appointment, Bill Recipient Adult Signature
(39)
Supplemental Oversize Package Charge
026
Prepaid
887
Appointment Bill Recipient Adult AutoPOD
(40)
Canada Goods & Services Tax GST
027
AutoPOD. Collect
(41)
Canada Harmonized and Service Tax HST
028
Collect
(42)
Canada Quebec Sales Tax QST
478
Guaranteed Funds COD. Prepaid
(43)
Reserved
479
Cash COD, Prepaid
(44)
Net Return
480
AutoPOD. COD, Prepaid
(45)
Credit Card Decline Surcharge
481
AutoPOD. Collect
(46)
Consolidated Returns Polybag
482
AutoPOD. ECOD, Prepaid
(47)
Consolidated Returns Package 2x2x4 2x6x8
483
AutoPOO ECOD, Collect
(48)
Consolidated Returns Package 4x4x5 4x8x12
484
AutoPOD PRP, Prepaid
(49)
Consolidated Returns Package 6x6x10 6x10x16
485
AutoPOD Guaranteed Funds COD, Prepaid
(50)
Consolidated Returns Package Bx10x12 10x12x16
486
AutoPOD. Cash COD. Prepaid
(51)
Consolidated Returns Package Fill Charge
487
Bill 3rd Party
(52)
Consolidated Returns Oversize Package Charge
488
Bill 3rd Party, AutoPOD
(53)
Returns Manager
489
Bill 3rd Party, COD
(54)
Security Surcharge
490
Bill 3rd Party, Guaranteed Funds COD
491
Bill 3rd Party, Cash COD
492
Bill Recipient
493
Bill Recipient, AutoPOD
494
Bill Recipient, COD
495
Bill Recipient Guaranteed Funds COD
496
Bill Recipient, Cash COD
EFTA00030860


c1: EFTA00030420
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030420.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: New drive for Maxwell
Date: Fri, 04 Dec 2020 21:35:06 +0000
Will get that to you i a few minutes.
)"
12/4/2020 3:21
PM
In particular, there appears to be a track change that is included in
the second page, which we are hoping you could fix before we submit this
to Judge Nathan.
We also were hoping to chat about some other issues, but even if that's
not possible, we're hoping we can provide the court with a clean copy
without the track change.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
Original Message
From:
)
Sent: Friday, December 4, 2020 2:20 PM
To:
Cc:
)
Subject: RE: New drive for Maxwell
Thank you very much. Would you have time for a quick call to discuss,
please?
Best,
EFTA00030420

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
New York, NY 10007
Original Message
From:
Sent: Friday, December 4, 2020 2:04 PM
To:
Cc:
Subject: RE: New drive for Maxwell
Attached please find the letter to Hon. Nathan.
Best,
Staff Attorney
Department of Justice
Federal Bureau of Prisons
Metropolitan Detention Center Brooklyn
Brooklyn, New York 11232
P:
E:
SENSITIVE/PRIVILEGED COMMUNICATION
The information contained in this electronic message and any and all
accompanying documents constitutes sensitive information. This
information is the property of the U.S. Department of Justice. If you
are not the intended recipient of this information, any disclosures,
copying, distribution, or the taking of any action in reliance on this
information is strictly prohibited. If you received this message in
error, please notify us immediately to make arrangements for its return
to us.
)"
12/4/2020 9:39
AM
EFTA00030421

=== Page 3 ===
Thank you very much.
Original Message
From:
Sent: Friday, December 4, 2020 7:41 AM
To: J
Cc:
Subject: Re: New drive for Maxwell
Not a problem.
Best,
)"
12/3/2020 5:24
PM
Hi all,
Today our office is sending via FedEx a replacement drive for Ghislaine
Maxwell, which should arrive at the MDC tomorrow. This drive will
replace the drive that Maxwell recently dropped and broke, and the
accompanying cover letters are attached. Would you please make sure
Maxwell is given access to this drive?
Would you please mail the broken drive back to our office? It can be
mailed to the below address:
Paralegal Specialist
U.S. Attorney's Office, SDNY
New York, NY 10007
Thanks very much, as always, for your help.
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
<mailto:
EFTA00030422


c1: EFTA00030090
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030090.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS) [Contractor]"
To: "Christian R Everdell - Cohen & Gresser LLP
(
)"
>, "Mark S. Cohen"
>, Bobbi
Sternheim
>, 'BOBBI C STERNHEIM'
Laura Menninger
, Jeff Pagliuca
Cc:
)"
(USANYS)"
i
)"
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Date: Fri, 12 Mar 2021 17:29:44 +0000
Attachments: 2021.03.12_Maxwell_Discovery_Letter_v2.pdf
Counsel,
The index in the previous cover letter inadvertently begins at the wrong bates number for this production. Please find
attached a revised version.
Best Regards,
Paralegal Specialist
United States Attorney's Office SDNY
From:
)
Sent: Friday, March 12, 2021 12:14 PM
To: Christian R Everdell - Cohen & Gresser LLP
(
)
>; Mark S.
Cohen
>; ; Bobbi Sternheim
>; 'BOBBI C STERNHEIM'
>; Laura Menninger
>; Jeff Pagliuca
Cc:
is
(USANYS)
is
(USANYS) [Contractor]
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Counsel,
Pursuant to the Court's Order dated November 18, 2020, today we are producing materials regarding victims who are not
referenced in Indictment number S1 20 Cr. 330 (AJN). Attached please find the accompanying cover letter. The
production is small enough to produce via an FTP site. Would you please send us a link to use for this production?
We will send a CD containing a copy of this production to the MDC for your client to review as well.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00030090

=== Page 2 ===
EFTA00030091


c1: EFTA00030356
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c3: VOL00008
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c7: images
c0:
=== Page 1 ===
From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:47:17 +0000
Inline-Images: image001.png
Congrats!
From:
Sent: Thursday, July 02, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI ORAL DOMINA OF JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
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.
EFTA00030356

=== Page 2 ===
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 [1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
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.
EFTA00030357

=== Page 3 ===
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00030358


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c0:
=== Page 1 ===
July 15, 2021
Prep
AUSAs
&
SA
Prepared for trial testimony.
can authenticate map of area surrounding 358 El Brillo Way
can authenticate video of October 20, 2005 search of 358 El Brillo Way
can authenticate photographs of 358 El Brillo Way from October 20, 2005
search, except those that show opened drawers or boxes
can authenticate PBPD property receipts from October 20, 2005 search of 358
El Brillo Way
can authenticate green massage table seized from 358 El Brillo Way on
October 20, 2005
All evidence seized from October 20, 2005 search of 358 El Brillo Way was
transferred in a caravan of cars of PBPD personnel to PBPD office and stored in
vault there.
transferred all evidence seized from October 20, 2005 search of 358 El Brillo
Way to FBI agent on or about August 28, 2006.
EFTA00029871


c1: EFTA00031449
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c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031449.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Noel & Thomas DP memos
Date: Wed, 14 Apr 2021 21:12:22 +0000
Attachments: 2021.04.14_Thomas_DP_Memo.docx
Adding the Thomas DP memo as well (this is why we need
help with the organization!).
From:
(USANYS)
Sent: Wednesday, April 14, 2021 5:06 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: Noel & Thomas DP memos
Hi
We are sending you the DP memos for Noel and Thomas.
We are also sending you the various application materials so that you have them all in one place.
Let us know if you have any comments/edits/etc. on the memos that you would like us to address.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00031449


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031498.pdf
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c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Mon, 06 Jul 2020 21:08:45 +0000
This is now belated, but - thank you!! And hope you and the fam are hanging in there these days!
From:
Sent: Thursday, July 02, 2020 15:01
To:
Subject: Fwd: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congratulations!
Begin forwarded message:
From:
Date: July 2, 2020 at 1:22:27 PM EDT
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
[cid:image001.png@01D53E43.CA2BB290]
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH
JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS<https://edit.justice.gov/usao-sdny/pr/ghislaine-
maxwell-charged-manhattan-federal-court-conspiring-jeffrey-epstein-sexually.
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F. Sweeney
Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of Investigation
("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"), announced that
GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel to engage in
criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity, conspiracy to
commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment unsealed
today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator Jeffrey
Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
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.
EFTA00031498

=== Page 2 ===
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[1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated in
Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies
or taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's
behavior. Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to
accept offers of financial assistance from Epstein, including offers to pay for travel or educational expenses.
MAXWELL also normalized and facilitated sexual abuse by discussing sexual topics with victims,
encouraging them to massage Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and susceptible
to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between minor victims
and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL was present
for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages during which a
minor victim was fully or partially nude, as well as group sexualized massages of Epstein involving a minor
victim where MAXWELL was present.
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
EFTA00031499

=== Page 3 ===
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<https://www.facebook.com/usaosdny/> Follow us on
Twitter<https://twitter.com/SDNYnews> SDNY website <http://www.justice.gov/usao-sdny>
uTube<https://www.youtube.com/user/USAOSDNY>
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the
Indictment set forth herein, constitute only allegations, and every fact described therein should be treated as an
allegation. The defendant is presumed innocent unless and until proven guilty.
<image001.png>
<U.S. V. Ghislaine Maxwell Indictment.pdf>
<Ghislaine Maxwell Indictment PR.pdf>
EFTA00031500


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=== Page 1 ===
From:
)"
To:
)"
Subject: Revised memo
Date: Wed, 14 Aug 2019 22:37:13 +0000
Attachments: 2019.08.14_JE_status_memo_for_Geoff_FINAL.docx
Hey,
As discussed, attached is the revised memo incorporating
comments with just the one final note to answer about
on the last page.
Thanks!
EFTA00029714


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=== Page 1 ===
Instructions: Complete the form (page 2) and break down your travel hours in this format. Once this form is completed return to Nick Siu
in the Human Resources Office. The hours deemed creditable will be forwarded to your supervisor for approval then your
timekeeper for processing. Not all time is creditable so it is important that you provide as much detail as you possibly can.
ie. Travel Log
EXAMPLE
TRAVEL LOG DESCRIPTION OF TIME PERIOD
TIME CLAIMED
FOR HR USE ONLY
Part I - Travel to TDY Station
From
To
Waiting at airport
9:30am
1:30pm
LGA to Washington
1:30pm
3:00pm
Connecting flight - Washington to Columbia, SC (flight delay 2 hours)
3:00pm
6:30pm
Airport to hotel
6:30pm
7:00pm
Additional Information Regarding Compensatory Time for Travel
FLSA Status- AUSAs are exempt; Support staff GS-8 and below are generally non-exempt.
Compensatory time for travel (CT/T) from office to airport during hours that are not part of your Tour-of-Duty is creditable.
Compensatory time for travel (CT/T) is a different entitlement that other OT/CT benefits and has different rules.
Compensable time can only be credited in full 15 minute increments. Rounding is not appropriate.
Time driving to airport from home is not creditable if airport is within boundaries of Official Duty Station (defined as a 50 mile radius of workplace).
Time driving to home from airport, after return flight from TDY, is not creditable.
Creditable time at airport awaiting a departing flight cannot exceed two (2) hours.
Personal time for bona fide meal periods, sleep, rest, etc., during the waiting periods are excluded.
Time that falls within or during en employee's regular duty hours is not creditable.
When travel is driving personal or government vehicle from home to a TDY location outside the Official Duty Station, creditable time starts at time
left home, but agency must reduce time by the employee's normal commute time from his/her home to office.
When employee must go to workplace before starting travel to TDY location, creditable time starts when employee leaves the office.
Regular commuting time for trips to and from the initial and final departure terminal and home are excluded.
EFTA00030427

=== Page 2 ===
REQUEST FOR COMPENSATORY TIME (CT/T) FOR TRAVEL REQUEST AND CERTIFICATION
Name:
SSN:
*FLSA(): Exempt
NonExempt
Date of Request: 11/06/19
Tour of Duty:(ie. 9:00 am - 5:30 pm) 9:30 a.m. - 5:30 p.m.
Normal Commute Time to Work: 15 minutes
Timekeeper:
Destination: Santa Monica, CA
Date of departure: Wednesday, Nov. 13, 2019
Date of return from travel: Friday, Nov. 15, 2019
Pay Period: 23
s
After travel has been completed, complete the applicable items below and certify information provided. Time claimed must be in 15 minute increments.
TRAVEL LOG DESCRIPTION OF TIME PERIOD
TIME CLAIMED
FOR HR USE ONLY
Part I - Travel to TDY Station
From
To
Travel to JFK (11/13)
2:00 p.m.
2:55 p.m.
Wait for flight at JFK (11/13)
2:55 p.m.
3:30 p.m.
JFK to LAX flight (11/13)
3:30 p.m.
10:10 p.m.
LAX to hotel (11/13)
10:10 p.m.
10:40 p.m.
** NOTE: these times are all local time for consistency
PART II - Travel from TDY Station
** NOTE: these times are all local time for consistency
Digitally signed by
Employee Certification (Sign):
Date: 2019.11.06 19:12:11-05'00'
Date: 18 November 2019
Supervisory Certification (Sign):
Date:
Total CT/T Hours Approved:
Approved by:
Date:
EFTA00030428


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 255 Filed 04/29/21 Page 1 of 2
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 4/29/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
On April 26, 2021, defense counsel advised the Court of an incident that took place on
April 24, 2021 in which Defendant Ghislaine Maxwell's legal materials were seized by staff at
the Metropolitan Detention Center. Dkt. No. 248. In the letter, defense counsel requested that
the Court order MDC staff to provide them with more information regarding the incident. The
Court ordered legal counsel for the MDC to show cause why the requested order should not
issue. Dkt. No. 249. The MDC filed its response with the Court. Dkt No. 254. In reply,
Maxwell made additional requests. Dkt. No. 253. Defense counsel's requests are GRANTED in
part and DENIED in part.
IT IS ORDERED that by April 30, 2021, legal counsel to the MDC must provide the
following information:
1. If known, an inventory of the items seized from Ms. Maxwell in the incident that
occurred on April 24, 2021 shall be provided by email to defense counsel only; and
2. A representation to this Court, to be filed on ECF, indicating:
a. Whether any of the materials seized from Ms. Maxwell were duplicated in any
fashion and what investigation was undertaken in order to determine this
information;
EFTA00031606

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 255 Filed 04/29/21 Page 2 of 2
b. Whether Ms. Maxwell is permitted to bring confidential legal materials to in-
person meetings with defense counsel without those materials being seized;
c. What steps have been or will be taken to ensure the confidentiality of Ms.
Maxwell's lawyer-client communications.
Defense counsel's requests are denied in all other respects.
so ORDERED.
Dated: April 29, 2021
Alim D.Netto
New York, New York
ALISON J. NATHAN
United States District Judge
EFTA00031607


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From:
Subject: FW: Efrain Reyes
Date: Mon, 21 Dec 2020 14:55:07 +0000
Embedded: FW:_Efrain_Reyes.msg
Sender:
Subject: FW: Efrain Reyes
Message-Id:
<BN3P110MB03220D3139567D7BB0CE469FFAC00@BN3P110MB0322.NAMP110.PROD.OUTLOOK.CO
M>
To:
EFTA00030097


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=== Page 1 ===
From:
"
)"
To: "Strauss, Audrey (USANYS)"
Subject: RE: Cheat Sheet
Date: Tue, 30 Jun 2020 20:45:25 +0000
That's correct.
From: Strauss, Audrey (USANYS)
Sent: Tuesday, June 30, 2020 4:44 PM
To:
Subject: RE: Cheat Sheet
No mandatory mins?
From:
Sent: Tuesday, June 30, 2020 4:00 PM
To: Strauss, Audrey (USANYS)
Subject: RE: Cheat Sheet
Please see attached.
From:
Sent: Tuesday, June 30, 2020 3:00 PM
To: Strauss, Audrey (USANYS)
Subject: RE: Cheat Sheet
On it.
From: Strauss, Audrey (USANYS)
Sent: Tuesday, June 30, 2020 2:59 PM
To:
Subject: RE: Cheat Sheet
Please add exposure on each count. thnx
From:
)
Sent: Monday, June 29, 2020 4:49 PM
To: Strauss, Audrey (USANYS)
Subject: Cheat Sheet
Here's a first attempt at a cheat sheet for Wednesday. It currently includes the statute and time period charged in each
Count; the particular lies underlying each perjury spec; a note on the applicable statute of limitations; and a similar note
on the sex trafficking statute with which Epstein was charged (and Maxwell is not).
I can of course reformat, revise, or add anything else that might be helpful.
EFTA00031511


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=== Page 1 ===
From:
Subject: USAO SDNY Prisoner for Court Production Request
Date: Thu, 18 Jul 2019 20:42:50 +0000
PRISONER PRODUCTION FOR COURT REQUEST
Use this e-mail only to order defendants for Court.
COURT
DATE 7/31/19
TIME 11 am
JUDGE
Berman
17B
ROOM
PRODUCTION TYPE (enter X in box to the right of
CASE# 19 Cr. 490 (RMB)
description)
Arraignment
Bond hearing
Bond signing
Change of plea
Detention hearing
Fatico hearing
Motion hearing
Other, describe below
Preliminary
Revocation &
Revocation hearing
Sentencing
hearing
sentencing
Suppression
Status hearing
X
Trial
Material witness
hearing
On writ status
Defendant
USMS #
USMS use only/report result to CrimSec
(indicate Y only)
Sentence
Time served Detainer
1
Jeffrey Epstein
76318-054
2
3
4
5
6
7
8
9
10
REMARKS (security precautions, separations, violent crime charge, not standard release issues):
AUSA NAME
AUSA PHONE
EFTA00030614

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00030615


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=== Page 1 ===
SECURITY
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
April 14, 2021
BY USAfx
Montell Figgins, Esq.
Law Offices of Montell Figgins
17 Academy Street, Suite 305
Newark, NJ 07102
Re: United States V. Michael Thomas, No. 19 Cr. 830
Dear Counsel:
This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of
Criminal Procedure. This letter and the materials identified herein are subject to the protective
order entered in this case on December 16, 2019, and have been designated as "Protected
Materials" as defined in the order where noted below. Accordingly, the materials and information
identified herein shall not be disclosed to any third party or referenced publicly except as set forth
in the protective order.
Description
Bates Numbers
Classification Pursuant
to Protective Order
Arrest documentation and signed
SDNY_00017773 -
Confidential
warrants
SDNY_00017775
Documents from the MCC including
SDNY_00017776 -
Confidential
quarters, maps, and rosters
SDNY_00017782
SDNY_00017783 -
Confidential
FBI import forms
SDNY_00017822
SDNY_00017823 -
Confidential
FBI Laboratory examination requests
SDNY_00017825
SDNY_00017826 -
Confidential
FBI process reports
SDNY_00017991
SDNY_00017992 -
Confidential
Witness statements
SDNY_00018024
Anonymized index
SDNY_00018025
Attorney's Eyes Only
Additionally, the Government is producing the following materials only to your client:
06.20.2018
EFTA00031435

=== Page 2 ===
Page 2
Description
Bates Numbers
Classification Pursuant
to Protective Order
US Marshals Service Intake and Personal
SDNY_MT_00000212 -
History
SDNY_MT_00000223
Finally, while we do not agree these materials are required to be produced pursuant to Rule
16, based on your prior request for information, the Government is providing the following
information from the Bureau of Prisons ("BOP"):
Since approximately January 1, 2019, in BOP matters that resulted in sustained
administrative charges of falsification with regard to log entries, the following disciplinary
actions were taken: 2 letters of reprimand; 50 suspensions; 1 demotion; 3 terminations; and
6 resignations/retirements prior to discipline.
The BOP has records of the following inmate deaths over the last ten years at the MCC and
MDC:
Inmate Name
Register Num
DOD
Institution
Death Location
Cause of Death
Tony McClam
79490-054
9/24/2020
MCC
Housing Unit
Cardiac
Kenneth Houck
06743-015
5/19/2020
MDC
Special Housing Unit
Hanging
Eric Manson
01558-112
10/23/2019
MCC
Community Hospital
Drug Overdose
Jeffrey Epstein
76318-054
8/10/2019
MCC
Community Hospital
Hanging
Oscar Reynoso
60240-019
10/23/2015
MDC
Community Hospital
Hanging
Fang Xin He
79018-053
7/19/2012
MDC
Mental Health Unit
Hanging
The foregoing information is subject to the protective order. Please contact us with any questions.
Very truly yours,
AUDREY STRAUSS
United States Attorney for the
Southern District of New York
By:
/s/
Assistant United States Attorneys
06.20.2018
EFTA00031436


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From: "Margolin, James (USANYS) [Contractor]"
To:
,
"Biase, Nicholas (USANYS)"
Subject: Pathologist Michael Baden says Jeffrey Epstein was homicide victim
Date: Wed, 30 Oct 2019 12:22:50 +0000
FYI.
https://nypost.com/2019/10/30/famed-pathologist-michael-baden-says-jefrey-epsteins-death-was-homicide/
James Margolin
Chief Public Information Officer
U.S. Attorney's Office, SDNY
EFTA00031392


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=== Page 1 ===
From:
Subject: Transcript
Date: Wed, 19 Jun 2019 15:35:21 +0000
Importance: Normal
Attachments: 2019.06.19_Transcript.pdf
Hi
Attached is the transcript from yesterday.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
From:
To:
Subject: Object of the conspiracy was to meet Epstein.docx
Date: Mon, 06 Jan 2020 13:48:51 +0000
Attachments: Object_of_the_conspiracy_was_to_meet_Epstein.docx
EFTA00031085


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From:
(NY) (FBI)"
To:
)"
Subject: RE: Press Conference at Epstein's
Date: Tue, 28 Jan 2020 00:20:47 +0000
Same here
ditto.
SSA
FBI New York
On Jan 27, 2020 7:17 PM,
)"
wrote:
I
honestly cannot tell you how grateful and appreciative we are about our relationship with you (and with
and
- it's incredibly comforting and helpful to consistently be on the same page. Thanks as always, and we'll be in
touch per usual.
From:
(NY) (FBI)
Sent: Monday, January 27, 2020 19:14
To:
Subject: RE: Press Conference at Epstein's
I'm sure, not a problem, we've always been on the same page. Up the chain of command may be a different
story
SSA
FBI New York
On Jan 27, 2020 7:10 PM,
)"
wrote:
It was a complete surprise man. We've been dealing with all kinds of after-affects all day.
From:
(NY) (FBI)
Sent: Monday, January 27, 2020 19:08
To:
is
is
Cc:
is
is
(NY) (FBI)
Subject: RE: Press Conference at Epstein's
Ok
thanks for getting back to me. Just caught a lot of people off guard over here, sounds like it did
with you as well. No worries, talk to you soon.
SSA
FBI New York
On Jan 27, 2020 5:47 PM,
)"
wrote:
,
This morning's press conference took us by surprise -- our supervisors did not say anything to us about it in
EFTA00031722

=== Page 2 ===
advance, and in particular had no idea that there would be comments about the active investigation. Our
understanding now is that the event was in connection with Safe Horizon, the victim services organization, and that
Geoff answered at least one specific question about the investigation, relating to Prince Andrew. We just heard
from
that he spoke to
about it (I think earlier today?) so everybody is playing catch up.
Original Message
From:
(NY) (FBI)
Sent: Monday, January 27, 2020 15:28
To:
)
i
)
Cc:
(NY) (FBI)
i
Subject: Press Conference at Epstein's
All,
I have been getting some questions about the press conference that occurred today at Epstein's mansion, do any of
you know that was about? Our media affairs department has been getting questions. In addition, our Victim
Specialists have been fielding calls from irate victims who weren't notified.
https://twitter.com/AaronKatersky/status/1221833096686903299/photo/1
thanks,
SSA
Squad C-20
Crimes Against Children/Human Trafficking FBI New York
office
mobile
EFTA00031723


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From:
)"
To:
)"
)"
Subject: FW: RE: Epstein investigation /
Date: Tue, 09 Jul 2019 15:44:48 +0000
Importance: Normal
And as similarly promised, here is his info:
Michael Bachner (counsel to
From:
Sent: Tuesday, July 09, 2019 11:44
T
Cc:
Subject: RE: Epstein investigation /
Mr. Bachner,
Following up on our conversation earlier this morning, we wanted to provide you with the additional information and
materials we discussed. In the first instance, so that you have full contact info for the team, please feel free to reach out
to any of us at any time; we're all available via email or at the following phone numbers:
Additionally, attached are the non-prosecution agreement, previously publicly filed in civil proceedings in Florida, and a
blank version of our standard proffer agreement, both as discussed.
As we mentioned, please don't hesitate to reach out with any questions, and we look forward to setting a time to speak
again after you're able to confer with
thank you,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To: "Weinstein, Marc A."
)"
Cc: Andrew Tomback
Bcc: "USAHUB-USAJournal111"
Subject: RE: Epstein Estate update
Date: Mon, 09 Nov 2020 15:27:27 +0000
Embedded: RE:_Epstein_Estate_update.msg
Sender:
Subject: RE: Epstein Estate update
Message-Id:
<BN1P110MB0163A80752E4B980448C20C684EA0@BN1P110MB0163.NAMP110.PROD.OUTLOOK.COM
>
To:
EFTA00029984


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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Subject: N.B.
Date: Tue, 30 Mar 2021 21:16:25 +0000
Attachments: Order.pdf
FYI, the lawsuit was resolved and has now been dismissed, but Judge Koeltl handled this differently from the other case
(opinion attached). I plan to ask for a copy of the materials disclosed to Maxwell's team when we speak to
tomorrow, but let me know if either of you disagree or want to discuss.
Assistant United States Attorney
Southern District of New York
EFTA00029955


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=== Page 1 ===
Event: Accepted: Epstein FOIA call
Start Date: 2021-05-07 19:00:00 +0000
End Date: 2021-05-07 19:30:00 +0000
Location: call in
Class: X-PERSONAL
Comment:
Date Created: 2021-05-06 16:25:19 +0000
Date Modified: 2021-05-06 16:25:19 +0000
Priority: 5
DTSTAMP: 2021-05-06 15:53:53 +0000
Attendee:
EFTA00031623


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=== Page 1 ===
From:
"
(USANYS)"
To:
,
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
N
(USANYS)"
N
)"
)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
i
(USANYS) 1"
Subject: Re: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Date: Thu, 31 Dec 2020 20:06:27 +0000
OK, and sorry again about the delay. That email was just hung in my outbox.
On Dec 31, 2020, at 3:00 PM,
(USANYS)
wrote:
Thanks
! We've incorporated your edits. As for you question about the "under investigation
language," the investigation related to the contraband cellphone is a matter of public record. As for
the
we've consulted with the MCC and softened that
,
language to the effect that Rivera was in the SHU for a disciplinary issue, without referencing the
specifics or the fact that
From:
(USANYS)
Sent: Thursday, December 31, 2020 2:09 PM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
>;
(USANYS)
>;
)
>;
>;
(USANYS)
Cc:
(USANYS)
is
(USANYS)
i
(USANYS)
>;
(USANYS)
^
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Apologies - I looked at this as soon as you sent it, but apparently my outlook was frozen and it was hanging in
cyberspace. I thought it looked good, although there were some typos which I fixed. I also had a couple of
questions/comments in one of the declarations (attached).
From:
(USANYS)
Sent: Thursday, December 31, 2020 12:19 PM
To:
(USANYS)
i
(USANYS)
>;
(USANYS)
i
(USANYS)
is
)
is
)
>;
(USANYS)
^
Cc:
(USANYS)
>;
(USANYS)
>;
(USANYS)
is
(USANYS)
EFTA00030063

=== Page 2 ===
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Hi
:
Please see our proposed letter, which I understand you would like to review, as well as
declarations from associate wardens at the MDC and MCC. The GC and PC chiefs have signed off on
these drafts.
With apologies for the time sensitivity, our contacts at MCC/MDC have asked to leave early today
(before 1/1:30), and have asked us to finalize the declarations as soon as possible.
Best,
From:
(USANYS)
Sent: Wednesday, December 30, 2020 4:24 PM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
is
)
is
-
is
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
i
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
,
who is the Associate Warden at the MCC. There's a possibility that there will be a very
short declaration from someone at the MDC to discuss the specific accommodations for Maxwell. I
am working through that with
From:
(USANYS)
Sent: Wednesday, December 30, 2020 2:45 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
i
)
is
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Thanks. Who is signing the declaration for BOP?
From:
(USANYS)
Sent: Wednesday, December 30, 2020 2:40 PM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
is
)
is
)
is
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
i
(USANYS)
is
(USANYS)
EFTA00030064

=== Page 3 ===
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
:
We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to
explain that the discovery and counsel access accommodations that have been provided to Maxwell
and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of
their lawyers, and their individual housing circumstances. On all of these factors, there are several
important differences, including:
-
The Maxwell case has multiple times more discovery than the Rivera case. Hence, the need
for such expanded discovery access is greater in the Maxwell case.
-
At the MDC, Maxwell has a unique housing situation, as she is in protective custody outside
the general population. She therefore has sole access to a room to use a computer and phone
for approximately 13 hours a day. Rivera, by contrast, is housed in the general population.
-
There are approximately 80 other inmates at the MCC in Rivera's unit that use the same VTC
room for court appearances, probation interviews, and attorney meetings. By contrast,
Maxwell shares access to the MDC VTC room with substantially fewer inmates. The MDC can
therefore provide 15 hours of VTC meetings with her attorneys without compromising access
for other MDC inmates. The same is not true for Rivera at the MCC.
Going forward, even though Rivera's counsel have asked (and the Court has ordered) that Rivera
receive three hours of laptop access each day, the MCC is now leaving the laptop with him all day
long, and only takes it back at night to charge it. Therefore, the MCC is now providing the same
amount of electronic discovery access to Rivera that Maxwell receives at the MDC.
As for providing Rivera with up to 15 hours of VTC access, we will explain that doing so will
compromise access for other inmates. If defense counsel expresses a need for additional time, the
MCC will continue to find ways to accommodate those requests as best as they can.
Please let me know if you have any questions or would like to discuss this further.
Best,
From:
(USANYS)
Sent: Monday, December 21, 2020 4:42 PM
To:
(USANYS)
is
(USANYS)
i
(USANYS)
is
(USANYS)
i
is
is
(USANYS)
>
Cc:
(USANYS)
is
(USANYS)
i
(USANYS)
is
(USANYS)
^
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Thanks,
Can you keep me posted on what we think will be the substance of the draft declaration when you
know (that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences
between MCC and MDC, as well as specific differences in their housing situations?
From:
(USANYS)
Sent: Monday, December 21, 2020 4:35 PM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
i
(USANYS)
is
EFTA00030065

=== Page 4 ===
is
)
>;
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
>;
(USANYS)
>;
(USANYS)
is
(USANYS) 1
Subject: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
All:
I wanted to bring to your attention a recent issue that's surfaced in United States v. Rivera et al., a
sex trafficking case pending before Judge Engelmayer. As I'll describe in more detail below, Judge
Engelmayer has asked us to submit a declaration from the BOP explaining why the discovery and
counsel access accommodations provided to Ghislaine Maxwell (detained at the MDC outside the
general population) cannot be extended to Justin Rivera (detained at the MCC in the general
population).
Justin Rivera was charged in February 2019 with sex trafficking conspiracy. He's been detained at
the MCC since April 2019 on consent (he's also serving a state sentence). His trial, which was
originally scheduled for April 2019, is expected to start on February 16, 2020. In July 2020, he had
new counsel appointed, citing an irreconcilable breakdown with his former counsel.
Since this fall, Judge Engelmayer has become increasingly frustrated with the MCC's treatment of
Rivera. In particular, he's cited their failure to provide Rivera with adequate accommodations to
review discovery and meet with his lawyers, who refuse to visit Rivera at the MCC for personal health
concerns. We have two court orders in place to address these issues: (1) a laptop order, which
requires the MCC to provide Rivera access to a laptop for three hours per day; and (2) a
videoconference order, which requires the MCC to make available four hours of videoconferencing
each week, in addition to any telephone or videoconference calls obtained through the Federal
Defenders.
At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time
Rivera has for videoconferences and electronic discovery review is insufficient for trial preparation,
although defense counsel has stated that they may request more time in the future. However, in a
letter last night and during a court conference this morning (transcript attached), defense counsel
cited the accommodations that the MDC has provided to Maxwell, describing them as "strikingly
different and far superior" to those afforded to Rivera. Defense counsel further suggested that Rivera
was being treated differently on account of his race, gender and class. Judge Engelmayer stated that
the disparity in access "jumped off the page" and that the optics were "terrible," and asked us to
explain the rationale for the differing treatment. After conferring with
and
before our conference, we explained our understanding that the disparity comes down to
the fact that Maxwell and Rivera have very different housing situations, with Maxwell's situation
being more amenable to greater access to electronic discovery review and legal visits.
Judge Engelmayer asked us to submit a declaration, from an appropriate person at the BOP,
explaining in more detail why the accommodations provided to Maxwell cannot be extended to
Rivera. Based on the recent bail opposition in the Maxwell case, I believe the differences in
counsel/discovery access are as follows:
Accommodation
Maxwell
Rivera
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=== Page 5 ===
Review of electronic
13 hours per day/7 days per
3 hours per day/7 days per
discovery (NB: each
week (91 hours total)
week (21 hours total)
defendant has laptop access)
Counsel visits (by video)
3 hours per day/5 days per
Four hours per week (plus an
week (15 hours total)
additional two hours
scheduled through the
Federal Defenders) (6 hours
total)
Weekend legal calls
As needed
Not available
The declaration is due by December 31. Because Judge Engelmayer's request implicates at least two
criminal cases, and potentially the ongoing civil litigation with the MCC, we wanted to make sure that
you were all aware of this issue. We are also happy to set up a call to discuss this further. In the
meantime, we are working with
to identify the appropriate declarant and draft an
explanation for the Court.
Best,
Assistant United States Attorney
United States Attorney's Office for the Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Tel:
EFTA00030067


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=== Page 1 ===
From:
)"
To:
Subject: RE: Maxwell drive delivery Monday 1/11
Date: Mon, 11 Jan 2021 21:32:10 +0000
Thank you!
Original Message
From:
Sent: Monday, January 11, 2021 3:48 PM
To:
Subject: Re: Maxwell drive delivery Monday 1/11
No problem and Yes everything went smoothly.
> On Jan 11, 2021, at 15:45,
)
wrote:
>
> Thank you so much for doing this! Did everything go ok?
V
>
Original Message
> From:
> Sent: Monday, January 11, 2021 11:49 AM
> To:
> Cc:
V
(USANYS)
>
[Contractor]
(USANYS)
V
)
>
Subject: Re: Maxwell drive delivery Monday 1/11
V
V
I'm here in front MDC on 29th Avenue but not totally sure where you would like to meet. Give me a
call when you have a chance.
V
>
V
V
V
>>
On Jan 11, 2021, at 10:54,
wrote:
>> Yes, that works for us!
1/11/2021 10:47 AM
»
>> I will be picking up the drives today. Are you available to run out
>>
to me around 11:30?
or
ideally I'd be bringing the drives directly to you
>>
after pick up. Are you available around 12-1230?
EFTA00030870

=== Page 2 ===
Feel free to call me at
On Jan 11, 2021, at 09:48,
wrote:
It will be myself or
Best,
)"
1/8/2021 2:20
PM
Good afternoon,
The FBI has very kindly agreed to deliver two new drives from my
office
to the MDC for Ghislaine Maxwell on Monday, January 11th. I've cc'd
Special Agent
,
who will be coordinating the delivery.
Would
you please let us know what time the FBI should plan to make the
delivery and who will be available to receive the drives on Monday?
Thank you all very much for your help.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
<mailto:
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=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:38:36 +0000
Inline-Images: image001.png
Thank you!
From
Sent: Thursday, July 02, 2020 14:38
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Huge congrats.
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
UNITED QUI PRO DOMINA JUSTITIA OF NOFFICE SESTION
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
EFTA00030374

=== Page 2 ===
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
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.
EFTA00030375

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
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[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: update on social visit?
Date: Fri, 30 Aug 2019 17:31:45 +0000
Agree.
From:
(USANYS)
Sent: Friday, August 30, 2019 7:56 AM
To:
Subject: Fwd: update on social visit?
MCC's position below is exactly what we told him. He doesn't just get social visits for the sake of it but only for mitigation
preparation. He's making it difficult for us to do anything by phone anymore because he "misunderstands" too often.
Assistant U.S. Attorney
Begin forwarded message:
From: Bruce Barket
Date: August 29, 2019 at 22:55:09 EDT
To:
(USANYS)"
>,
Swergold (USANYS)"
Subject: Fwd: update on social visit?
This is not the position I expected from my first request for Nick to see his parents. Apparently, I misunderstood our
conversation from a few weeks ago.
We did not ask the court to intervene because of my understanding. We will be filing a request for intervention ahead
of our next appearance.
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country road
Garden City, NY 11530
- 0
- M
Barket Epstein.com
Begin forwarded message:
From: Bruce Barket
Date: August 29, 2019 at 5:30:15 PM EDT
To:
Cc:
>,
Subject: RE: update on social visit?
Thanks for getting back to me. Let me know as soon as you can about a visit for next week.
EFTA00030715

=== Page 2 ===
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
[P] (516) 745 1245 [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
From:
[mailto:
Sent: Thursday, August 29, 2019 5:28 PM
To: Bruce Barket
Cc:
;
Subject: RE: update on social visit?
Hi Bruce,
MCC New York has permitted social visits despite disciplinary sanctions when the visit is specifically for mitigation
purposes. Disciplinary sanctions notwithstanding, all pretrial inmates have the same access to family communications:
monitored social visiting, monitored social phone calls, and monitored social mail. While I understand your client is a
death penalty case, there are many inmates at MCC with very complex cases who have legal decisions they need to
discuss with their families, and the methods available to them are the three methods I just mentioned. If a social
phone call is insufficient, then we will raise the issue again with administrators to see if they will allow a social visit
during your client's regular social visiting hours. However, please be advised that once your client returns to general
population with regular phone access, I do not anticipate administrators will be amenable to social visit requests unless
they are being used as mitigation evidence.
I am out of the office starting tomorrow, but Adam will let you know once he discusses it with Exec staff.
Thanks,
Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, NY 10007
p:
f:
>>> Bruce Barket <
> 8/29/2019 5:15 PM >>>
I am sorry, but that won't be sufficient. We had a conversation with
and
a few weeks back and they
told us that, in light of the particular needs for preparation for a capital case, MCC would permit periodic social visits
as needed. I did not raise this issue with the court because of what we were told. Perhaps I misunderstood.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
EFTA00030716

=== Page 3 ===
666 Old Country Road, Ste. 700
Garden City, NY 11530
[P] (516) 745 1245 [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
From:
[mailto:
Sent: Thursday, August 29, 2019 3:03 PM
To: Bruce Barket
Cc:
;
Subject: RE: update on social visit?
Hi Bruce,
After some discussion, MCC's administrators are prepared to offer your client a social phone call with his parents, which
would be outside the normal phone schedule provided to inmates in Special Housing. If you fell that would be
inadequate, please advise and Adam and I will take the issue back to our administrators.
Thank you,
Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, NY 10007
p:
f:
>>>
8/28/2019 4:23 PM >>>
Hi Bruce,
Our Exec staff are still discussing it. I should hopefully have an answer for you by tomorrow. In the meantime, can you
give me any information about the "critical stage" in the case? I don't want to know anything that would violate
privilege, but something very general (e.g. a plea is on the table, a cooperation agreement is on the table, etc.) might
help our Exec staff evaluate the request.
Thanks,
Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, NY 10007
p:
f:
EFTA00030717

=== Page 4 ===
>>> Bruce Barket <
> 8/28/2019 3:40 PM
Is there any update on a visit with his parents this week?
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
[P] (516) 745 1245 [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
From:
[mailto:
Sent: Wednesday, August 28, 2019 8:31 AM
To: Bruce Barket
Cc:
Subject: Re: meeting with Tartaglione
No problem - I'll pull him down before the count.
Thanks,
Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, NY 10007
p:
f:
>>> Bruce Barket<
> 8/28/2019 8:28 AM >>>
I know it is late notice but I am hoping to see Nick tonight at 5:00. Thank you
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
[P] (516) 745 1245 [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
EFTA00030718

=== Page 5 ===
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
EFTA00030719


