# docs_fts_content

c1: EFTA00024430
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024430.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Subject: RE: Travel
Date: Wed, 28 Aug 2019 13:10:36 +0000
Yes, I'd like the same arrangements, if possible, please. Thank you!
Original Message
From:
)
Sent: Wednesday, August 28, 2019 9:03 AM
To:
(USANYS)
Cc:
Subject: Travel
,
and I are traveling to West Palm Beach next week for the Epstein case. Could you please help book our
travel? Here is my information-
can let you know whether she would like the same arrangements.
Thanks so much for your help.
Hotel: Hilton Palm Beach, 600 Okeechobee Blvd, West Palm Beach. Checking in on 9/3 and checking out 9/4.
Conference Room: please book a conference room at the Hilton for both Tuesday and Wednesday. If they have a
room called "the social" available, that would be great.
Flights:
Outbound, leaving at 920 am on 9/3 from EWR to PBI
Inbound, leaving at 6:12 pm on 9/4 from PBI to JFK
Thanks!
Sent from my iPhone
EFTA00024430


c1: EFTA00024397
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024397.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "
. (OIG)"
To:
=
(USANYS)"
Subject: Accepted: Update Conference Call - Epstein
Date: Tue, 13 Aug 2019 00:32:16 +0000
Importance: Normal
Attachments: unnamed
EFTA00024397


c1: EFTA00025167
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025167.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: [EXTERNAL] URGENT: Ghislaine Maxwell 02879-509
Date: Fri, 29 Oct 2021 18:42:43 +0000
Inline-Images: image003.png; image004.png
From: BOBBI c STERNHEIM
Sent: Friday, October 29, 2021 11:51 AM
To:
Cc:
>; ; Christian Everdell
Subject: [EXTERNAL] URGENT: Ghislaine Maxwell 02879-509
Further my earlier email today, as of 10:30 a.m., USPO tracking lists the following 4 items of legal mail
"Available for Pickup" and does not indicate that MDC has retrieved or received them.
Ms. Maxwell has not received legal mail in more than a week.
Please confirm IMMEDIATELY the status of these items on your end.
Failure to response today will result in the filing of an order to show cause requiring your presence in Court.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
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.
EFTA00025167

=== Page 2 ===
Tracking Number: EJ699436400US
Scheduled Delivery by
Status
SATURDAY
Available for Pickup
16
by
October 19. 2021 at 6:51 am
OCTOBER
BROOKLYN NY 11232
2021 1
6:00pm
Get Updates
Available for Pickup
See More
Tracking Number: EJ699436435US
Scheduled Delivery by
Status
THURSDAY
Available for Pickup
14
by
October 15, 2021 at 7:55 am
OCTOBER
BROOKLYN, NY 11232
2021 1
6:00pm 1
Get Updates
Available for Pickup
See More
EFTA00025168

=== Page 3 ===
Tracking Number: EJ699436427US
Scheduled Delivery by
Status
THURSDAY
Available for Pickup
28
by
October 28, 2021 at 10:59 am
OCTOBER
6:00pm
BROOKLYN NY 11232
2021 1
Get Updates
Available for Pickup
Text & Email Updates
Proof of Delivery
Tracking History
Product Information
See Less
Tracking Number: EJ699436413US
Scheduled Delivery by
Status
SATURDAY
Available for Pickup
9
by
October 12. 2021 at 9:07 am
OCTOBER
6:00pm
BROOKLYN NY 11232
2021 1
Get Updates
Available for Pickup
See More
Isabel Maxwell, Paralegal, Leah Saffian, Inc.
LAW OFFICES OF LEAH SAFFIAN; LEAH SAFFIAN BA JD LLM
11420 SANTA MONICA BLVD #25424 LOS ANGELES, CA 90025, USA
NOTICE: The information transmitted by this email is intended only for the person or entity to which it is addressed.
This email may contain proprietary, business-confidential and/or legally privileged material. If you are not the
intended recipient of this message, be aware that any use, review, retransmission, distribution, reproduction or any
action taken in reliance upon this message is strictly prohibited. If you received this in error, please contact the sender
Isabel Maxwell at Tel
and delete the material from all computers.
EFTA00025169


c1: EFTA00024346
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024346.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Automatic reply: Epstein update
Date: Sat, 10 Aug 2019 11:26:45 +0000
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses may be
delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
at
or
EFTA00024346


c1: EFTA00026939
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026939.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
15JA5421P00000117 Page 1 of 19
SOLICITATION/CONTRACT/ORDER FOR COMMERCIAL ITEMS
1. REQUISITION NUMBER
OFFEROR TO COMPLETE BLOCKS 12, 17, 23, 24 & 30
15JA54-21-PR-0199
2. CONTRACT NO.
3. AWARD/EFFECTIVE
4. ORDER NUMBER
5. SOLICITATION NUMBER
6. SOLICITATION ISSUE
DATE
DATE
15JA5421P00000117
03/08/2021
a NAME
b. TELEPHONE NUMBER (No collect calls)
8. OFFER DUE DATE / LOCAL
7. FOR SOLICITATION
TIME
INFORMATION CALL:
9. ISSUED BY
CODE
15JA54
10. THE ACQUISITION IS
X
UNRESTRICTED OR
SET ASIDE:
% FOR
U.S. Attorneys Office Southern District of New York
One St. Andrew's Plaza
SMALL BUSINESS
WOMEN-OWNED SMALL BUSINESS (WOSB)
ELIGIBLE UNDER THE WOMEN-OWNED
New York, NY 10007
HUBZONE SMALL
SMALL BUSINESS PROGRAM
NAICS: 621112
BUSINESS
EDWOSB
SERVICE-DISABLED
SIZE STANDARD: 12,000000.00
VETERAN-OWNED
SMALL BUSINESS
B(A)
11. DELIVERY FOR FOB DESTINATION
12. DISCOUNT TERMS
13b. RATING
UNLESS BLOCK IS MARKED
13a. THIS CONTRACT IS A
SEE
NET 30
RATED ORDER UNDER DPAS
14. METHOD OF SOLICITATION
SCHEDULE
(15 CFR 700)
RFQ
IFB
RFP
15. DELIVER TO
CODE
16. ADMINISTERED BY
CODE
15JA54
SEE SCHEDULE
U.S. Attorneys Office Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
17a. CONTRACTOR/
CODE
020583856
FACILITY
A
18a. PAYMENT WILL BE MADE BY
CODE
UNYS
OFFEROR
CODE
Lisa M. Rocchio, Ph.D. & Associates, Inc.
U.S. Attorneys Office Southern District of New York
86 Chambers Street
New York, NY 10007
TELEPHONE NO. 4017515880
18b. SUBMIT INVOICES TO ADDRESS SHOWN IN BLOCK 18a UNLESS BLOCK BELOW IS
17b. CHECK IF REMITTANCE IS DIFFERENT AND PUT SUCH ADDRESS IN
CHECKED
OFFER
SEE ADDENDUM
19.
20.
21.
22.
23.
24.
ITEM NO.
SCHEDULE OF SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
AMOUNT
R21NYSW1091
Expert Witness Services Psychology
U.S. V. Maxwell
20-CR-00330
2018R01618
Estimated POP: 3/8/2021 12/31/2021
POC: AUSA
See Continuation Sheet(s)
(Ure Reverse and/or Attach Additional Sheets as Necessary)
25. ACCOUNTING AND APPROPRIATION DATA
26. TOTAL AWARD AMOUNT (For Govt. Use Only)
JMD-2021-0311XDIR-JC2-NYS-EXW-EXW-11804-1157-2021
$45,000.00
27a. SOLICITATION INCORPORATES BY REFERENCE FAR 52.212-1, 52.212-4. FAR 52.212-3 AND 52212-5 ARE ATTACHED ADDENDA
ARE
ARE NOT ATTACHED
X
27b. CONTRACT/PURCHASE ORDER INCORPORATES BY REFERENCE FAR 52.212-4. FAR 52.212-5 IS ATTACHED ADDENDA
ARE
X
ARE NOT ATTACHED
28. CONTRACTOR IS REQUIRED TO SIGN THIS DOCUMENT AND RETURN
COPIES TO
29. AWARD OF CONTRACT: REF.
OFFER
ISSUING OFFICE. CONTRACTOR AGREES TO FURNISH AND DELIVER ALL ITEMS SET FORTH
DATED
YOUR OFFER ON SOLICITATION (BLOCK 5)
OR OTHERWISE IDENTIFIED ABOVE AND ON ANY ADDITIONAL SHEETS SUBJECT TO THE
INCLUDING ANY ADDITIONS OR CHANGES WHICH ARE SET FORTH HEREIN,
TERMS AND CONDITIONS SPECIFIED
IS ACCEPTED AS TO ITEMS:
30a. SIGNATURE OF OFFEROR/CONTRACTOR
31a. UNITED STATES OF AMERICA (SIGNATURE OF CONTRACTING OFFICER)
30b. NAME AND TITLE OF SIGNER (TYPE OR PRINT)
30c. DATE SIGNED
31b. NAME OF THE CONTRACTING OFFICER (TYPE OR PRINT)
31c. DATE SIGNED
Nick Siu
03/08/2021
AUTHORIZED FOR LOCAL REPRODUCTION
STANDARD FORM 1449 (REV. 2/2012)
PREVIOUS EDITION IS NOT USABLE
Prescribed by GSA FAR (48 CFR) 53.212
3502-007
Page 1 of 19
EFTA00026939

=== Page 2 ===
15JA5421P00000117 Page 2 of 19
19.
20.
21.
22.
23.
24.
ITEM NO.
SCHEDULE OF SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
AMOUNT
32a. QUANTITY IN COLUMN 21 HAS BEEN
RECEIVED
INSPECTED
ACCEPTED, AND CONFORMS TO THE CONTRACT, EXCEPT AS NOTED:
32b. SIGNATURE OF AUTHORIZED GOVERNMENT
32c. DATE
32d. PRINTED NAME AND TITLE OF AUTHORIZED GOVERNMENT
REPRESENTATIVE
REPRESENTATIVE
32e. MAILING ADDRESS OF AUTHORIZED GOVERNMENT REPRESENTATIVE
32f. TELEPHONE NUMBER OF AUTHORIZED GOVERNMENT
REPRESENTATIVE
32g. E-MAIL OF AUTHORIZED GOVERNMENT REPRESENTATIVE
33. SHIP NUMBER
34. VOUCHER NUMBER
35. AMOUNT VERIFIED
36. PAYMENT
37. CHECK NUMBER
CORRECT FOR
COMPLETE
PARTIAL
FINAL
PARTIAL
FINAL
38. S/R ACCOUNT NUMBER
39. S/R VOUCHER NUMBER
40. PAID BY
41a. I CERTIFY THIS ACCOUNT IS CORRECT AND PROPER FOR PAYMENT
42a. RECEIVED BY (Print)
41b. SIGNATURE AND TITLE OF CERTIFYING OFFICER
41c. DATE
42b. RECEIVED AT (Location)
42c. DATE REC'D (YY/MM/DD)
42d. TOTAL CONTAINERS
STANDARD FORM 1449 (REV. 02/2012) BACK
3502-007
Page 2 of 19
EFTA00026940

=== Page 3 ===
15JA5421P00000117 Page 3 of 19
Table of Contents
Section
Description
Page Number
1
Solicitation/Contract Form
1
2
Commodity or Services Schedule
4
2-3 Specifications/Work Statement
6
EOUSA AI-10-1C Data Security Contract Clause for Contracts Involving the PII of 25 or Fewer
Individuals (July 2016)
8
EOUSA AI-10-1A Notice of Contractor Personnel Security Clearance Requirements (May 2016)
10
3
Contract Clauses
12
52.212-5 Contract Terms and Conditions Required to Implement Statutes or Executive Orders-
Commercial Items (Jan 2021)
4
List of Attachments
19
3502-007
Page 3 of 19
EFTA00026941

=== Page 4 ===
15JA5421P00000117 Page 4 of 19
Section 2 - Commodity or Services Schedule
SCHEDULE OF SUPPLIES/SERVICES
CONTINUATION SHEET
ITEM NO.
SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
MATERIAL
TRAVEL
AMOUNT
COSTS
COSTS
0001
Examine Case
0
$0.0000
$0.00
$0.00
$0.00
Time and Materials
PSC: R424
Line Period of Performance: 03/08/2021 12/31/2021
ITEM NO.
SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
MATERIAL
TRAVEL
AMOUNT
COSTS
COSTS
0002
Prepare Testimony
50
HR
$450.0000
$0.00
$0.00
$22,500.00
Time and Materials
PSC: R424
Line Period of Performance: 03/08/2021 12/31/2021
ITEM NO.
SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
MATERIAL
TRAVEL
AMOUNT
COSTS
COSTS
0003
Court Testimony
50
HR
$450.0000
$0.00
$0.00
$22,500.00
Time and Materials
PSC: R424
Line Period of Performance: 03/08/2021 12/31/2021
ITEM NO.
SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
MATERIAL
TRAVEL
AMOUNT
COSTS
COSTS
0004
Travel Time
0
$0.0000
$0.00
$0.00
$0.00
Time and Materials
PSC: R424
Line Period of Performance: 03/08/2021 12/31/2021
ITEM NO.
SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
MATERIAL
TRAVEL
AMOUNT
COSTS
COSTS
0005
Deposition
0
$0.0000
$0.00
$0.00
$0.00
Time and Materials
PSC: R424
Line Period of Performance: 03/08/2021 12/31/2021
ITEM NO.
SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
MATERIAL
TRAVEL
AMOUNT
COSTS
COSTS
0006
Meals and Incidental Expenses
1
EA
$0.0000
$0.00
$0.00
$0.00
Time and Materials
3502-007
Page 4 of 19
EFTA00026942

=== Page 5 ===
15JA5421P00000117 Page 5 of 19
PSC: R424
Line Period of Performance: 03/08/2021 12/31/2021
ITEM NO.
SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
MATERIAL
TRAVEL
AMOUNT
COSTS
COSTS
0007
Privately Owned Vehicle (NTE coach rate)
0
ML
$0.0000
$0.00
$0.00
$0.00
Time and Materials
PSC: R424
Line Period of Performance: 03/08/2021 12/31/2021
ITEM NO.
SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
MATERIAL
TRAVEL
AMOUNT
COSTS
COSTS
0008
Lodging Reimbursement (Including Lodging Taxes)
1
EA
$0.0000
$0.00
$0.00
$0.00
Time and Materials
PSC: R424
Line Period of Performance: 03/08/2021 12/31/2021
ITEM NO.
SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
MATERIAL
TRAVEL
AMOUNT
COSTS
COSTS
0009
Lodging via GTA (Including Lodging Taxes)
1
EA
$0.0000
$0.00
$0.00
$0.00
Time and Materials
PSC: R424
Line Period of Performance: 03/08/2021 - 12/31/2021
ITEM NO.
SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
MATERIAL
TRAVEL
AMOUNT
COSTS
COSTS
0010
Common Carrier Transportation Via GTA
1
EA
$0.0000
$0.00
$0.00
$0.00
Time and Materials
PSC: R424
Line Period of Performance: 03/08/2021 - 12/31/2021
ITEM NO.
SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
MATERIAL
TRAVEL
AMOUNT
COSTS
COSTS
0011
Common Carrier Transportation Reimbursed
1
EA
$0.0000
$0.00
$0.00
$0.00
Time and Materials
PSC: R424
Line Period of Performance: 03/08/2021 12/31/2021
ITEM NO.
SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
MATERIAL
TRAVEL
AMOUNT
COSTS
COSTS
0012
Other Expenses
1
EA
$0.0000
$0.00
$0.00
$0.00
Time and Materials
PSC: R424
Line Period of Performance: 03/08/2021 - 12/31/2021
TOTAL
$45,000.00
3502-007
Page 5 of 19
EFTA00026943

=== Page 6 ===
15JA5421P00000117 Page 6 of 19
FUNDING DETAILS:
ITEM
FUNDING LINE
OBLIGATED AMOUNT
ACCOUNTING CODES
NO.
N/A
1
$45,000.00
JMD-2021-0311XDIR-JC2-NYS-EXW-EXW-11804-1157-2021
TOTAL: $45,000.00
2-3 Specifications/Work Statement
The United States Attorneys' Office (USAO) conducts litigation in the Southern District of New York on behalf of the United States
of America. Frequently, there is a need for expert witness work prior to a case going to trial and during the trial. When appropriate,
and pursuant to guidelines implemented by the Department of Justice, a USAO may enter into contracts with expert witnesses,
functioning as independent contractors, to conduct record reviews and data analyses in preparation for testimony in person or by
written report and to provide such testimony in court or by trial deposition. In this particular case, the USAO has determined that
an expert witness is necessary to testify in litigation for the government and such services are not available from the agency being
represented or from another agency.
Through this statement of work, the USAO is seeking the services of a contractor to review records, analyze data, interview witnesses,
prepare testimony, testify, and other work pertinent to the case.
Retention
The contractor will be available to commence work for the USAO upon receipt of an executed copy of this contract or a verbal notice
to proceed. The contractor agrees not to work for any other person or party involved in this case on matters relating to this case for
thirty (30) days after he/she is verbally retained, or upon acceptance of this contract, unless notified earlier by the USAO. Should the
thirty (30) days lapse without receipt of an executed contract or notice to proceed, the contractor is free to accept work from any other
party.
Scope of Work
The contractor shall:
Provide all plant, labor, material and equipment except as otherwise provided to perform expert witness services as required by USAO
and in connection with such services agrees to perform such document review, studies and research so as to be able to testify in person
or by written report as an expert witness with respect to the contractor's findings.
Testify as an expert witness during the trial either in person or by written report, unless notified to the contrary by the AUSA, and
must be willing to comply with all requirements of the court as well as local and/or federal rules for such purpose.
Assist the USAO in the obtaining of one or more additional expert witnesses, as needed to support the testimony of the contractor
in person or by written report, who are competent and willing to render a scientifically-supportable opinion and sign an appropriate
affidavit, acceptable to the expert, prepared by the USAO, based upon the findings of the expert and the facts of the Case.
Exercise neutrality and maintain independence. The contractor shall determine the manner in which the services are to be performed
and the specific hours to be worked by the contractor except when the contractor's testimony is required at a specific time and place.
Be of good professional standing and moral character, generally board eligible or board certified in the area of specialty or having
other appropriate qualifications through training or experience; to act as the USAO's expert witness in the Case, the rendering of oral
and written opinions, the signing of affidavits, giving depositions or courtroom testimony under oath and directly consulting with the
USAO.
3502-007
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EFTA00026944

=== Page 7 ===
15JA5421P00000117 Page 7 of 19
The full scope of contractor's work will be determined as the matter proceeds, and will be subject to the needs and requests of the
USAO. Occasionally the complexity of the case requires more review hours than initially estimated. Any time it becomes apparent
to the contractor that he/she will need to exceed the time and cost estimates provided to complete his/her work, he/she will provide the
USAO with a revised estimate and shall proceed only after being granted permission by the USAO.
Specific deliverables known at this time include:
In United States V. Maxwell, the Government has charged the defendant with various crimes related to the sexual abuse of mionrs. The
Government anticipates that this case will proceed ot trial. At trial, Dr. Rocchio will serve as a testifying expert to explain various
topics related sexual abuse and trauma. Specifically, Dr. Rocchio will serve as a testifying expert, based on her professional
experience and research, regarding the psychology of sexual abuse, including by explaining the following concepts: grooming,
delayed reporting of child sexual abuse, attachments that form between abusers and victims of sexual abuse, and the effects of sexual
abuse on memory.
In advance of her trial testimony, Dr. Rocchio will meet with the Government for preparation sessions; assist the Government in
responding to motions related to her expert testimony, as needed; and review any materials provided by the Government, or other
relevant materials relevant to the above subject matters as necessary in advance of her testimony.
Dr. Rocchio shall be compensated at a rate of $450 per hour to perform the work described above, including travel time.
This list of deliverables may not be all inclusive; additional deliverables may be identified by the USAO throughout the duration of
this contract.
FAR 31.205-46 Travel Costs. When travel is authorized by the Government, transportation, lodging, meals and incidental expenses
will be reimbursed in accordance with conditions set out in the Federal Travel Regulation (Title 41 Code of Federal Regulations).
Rates listed elsewhere in this contract for mileage and per diem are subject to change and will be reimbursed in accordance with the
rates established by the Federal Travel Regulation. Federal Travel Regulations may be found at this address: http://www.gsa.gov/.
Option to Extend Term of the Contract
The Government may unilaterally extend the term of this contract by written notice to the contractor provided the Government does so
before the contract expires. If any such extension causes an increase in the cost of performance on the contractor then the contractor
may, within 30 days, request an equitable adjustment in the contract price. The Government shall make an equitable adjustment in the
contract price and modify the contract to reflect the adjustment for all fair and reasonable requests. The total duration of this contract,
including unilateral extensions, may extend no longer than 90 days beyond disposition of the Case.
Relationship of the Parties
Notwithstanding any provision hereof, for all purposes of this contract the contractor shall be and act as an independent contractor
and not an employee of the USAO, thereby incurring all expenses associated with the work, including any overhead and other direct
costs. The USAO will not provide fringe benefits, including health insurance benefits, paid vacations, or any other employee benefit,
for the contractor. The contractor shall make no representation as an agent, employee, partner, or joint venturer of USAO. The
contractor shall have no authority to bind nor attempt to bind USAO or incur other obligations on behalf of USAO. The contractor is
an independent contractor and is solely responsible for all taxes, withholdings, and other statutory or contractual obligations of any
sort, including, but not limited to, Workers' Compensation Insurance; and the contractor agrees to defend, indemnify and hold USAO
harmless from any and all claims, damages, liability, attorneys' fees and expenses on account of an alleged failure by the contractor to
satisfy any such obligations or any other obligation (under this contract or otherwise). If the contractor is a corporation, it will ensure
that its employees and agents are bound in writing to the contractor's obligations under this Contract.
Confidentiality
The contractor recognizes that the USAO has and will have law enforcement interests, as well as non-privileged information obtained
from federal agencies and employees, and other proprietary information (collectively "information") which are valuable, special and
unique assets of the USAO. The contractor agrees that other than provided by law, he/she will at no time or under any circumstances,
directly, or indirectly, divulge, disclose, or communicate information to a third party, or use it for its own benefit without the prior
written permission from the USAO. The contractor may disclose information to its employees and subcontractors, who may be
working on the case, in order to facilitate the testimony to be provided by the expert in person or by written report, unless notified
to the contrary by the USAO. The contractor and its employees and subcontractors will protect the information and treat it as strictly
confidential.
3502-007
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EFTA00026945

=== Page 8 ===
15JA5421P00000117 Page 8 of 19
In the performance of services under this contract, the contractor, its employees and/or its subcontractors may be required to perform
operations, have access to, or handle data which contain sensitive, proprietary, or privacy information or data such as, but not limited
to, review or an individuals' tax records or medical records (such as patient files or prescription records) or other materials containing
individual tax or medical information (such as medical utilization reports from carriers, workers' compensation claim files, personnel
files, or court records which include medical or tax reports). The contractor agrees that the following additional safeguards apply to
such information:
The contractor shall be responsible for safeguarding the information or data while under the control of or available to the contractor
and to prevent it from being compromised, altered, damaged, lost, or improperly disseminated. The contractor shall use such
information solely for purposes of the particular court case.
Access to any such information or document should be strictly limited to persons with a legitimate and compelling need for that
information, such as support staff needed to assist in the preparation of testimony in person or by written report. The Contractor shall
ensure that any such persons use such information solely or purposes of the particular court case and protect the confidentiality of such
information.
The contractor shall ensure that all records are maintained securely so that access is strictly limited.
At the end of the contractor's engagement in this matter, all copies of such records shall be returned to the USAO.
All questions about these safeguards and the records which they cover shall be directed to the AUSA.
The confidentiality provisions of this contract shall survive any termination of this contract.
Conflict of Interest
The contractor warrants that he/she is under no obligation to any other entity that in any way conflicts with this contract, that he/she
is free to enter into this contract, and is under no obligation to consult for others in matters covered by this contract. The contractor
shall not, during the term of this contract, perform consulting services for others in any related or similar cases within the scope of this
contract but shall have the right to perform consulting services for others outside the scope of this contract.
If, for any reason, the USAO or the contractor determines that the contractor and/or an employee or subcontractor of the contractor
faces a potential, perceived, or real conflict of interest, the USAO shall notify the contractor or the contractor shall notify the USAO
of the potential, perceived, or real conflict of interest and the contractor and/or contract employee or subcontractor shall cease all work
on or reassign the task or proceed at the discretion of the USAO. At the USAO's option, the contractor may provide an acceptable
replacement.
Government Liability
The United States, its agents, agencies, departments, employees, and/or contracting officials shall not be liable for any injury to the
contractor, its subcontractors, agents, personnel, or damage to the contractor property unless the injury or damage is due to negligence
on the USAO's part and may be recoverable under the Federal Tort Claims Act.
Return of Records
Upon termination of this contract, the contractor will deliver all records, notes, data or memorandum that was received from the
USAO, and are in the contractor's possession or under the contractor's control and are the USAO's property or relates to the USAO's
business. The contractor may properly destroy this material upon permission of the USAO.
EOUSA AI-10-1C Data Security Contract Clause for Contracts Involving the PII of 25 or Fewer Individuals (July 2016)
Data Security Contract Clause for Contracts Involving the PII of 25 or Fewer Individuals (July 2016)
The following clause applies to all contracts involving the personally identifiable information (PII) of 25 or fewer individuals. PII
refers to information that can be used to distinguish or trace an individual's identity, such as his or her name, social security number,
biometric records, etc., whether alone or when combined with other personal or identifying information that is linked or linkable to a
specific individual, such as date and place of birth, mother's maiden name, etc. PII is defined at this link:
http://www.gsa.gov/portal/content/104256.
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Contractors using information systems that are subject to the data security requirements under the Health Insurance Portability and
Accountability Act of 1996 (HIPAA) already are subject to the data security standards outlined below, and, therefore, only paragraphs
(g), (h), and (i) apply.
(a)
Contractors must ensure that computer hardware is secure and shall take the steps outlined below:
(1) Keep your firewall turned on: A firewall helps protect your computer from hackers who might try to gain access
to crash it, delete information, or even steal passwords or other sensitive information. Software firewalls are widely
recommended for single computers. The software is prepackaged on some operating systems or can be purchased
for individual computers. For multiple networked computers, hardware routers typically provide firewall protection,
although the contractor must verify this.
(2) Computers must be protected by username/password logins and password-protected screensavers (after 15-
min. idle). Computer accounts cannot be shared with other users. Contractors must report an incident to the EOUSA
Security Operations Center at
within one hour if their account is accessed by another user.
(3) Install and update your antivirus software: Antivirus software is designed to prevent malicious software
programs from embedding in your computer. If it detects malicious code, like a virus or a worm, it works to disarm or
remove it. Viruses can infect computers without users' knowledge. Most types of antivirus software can be set up to
update automatically.
(4) Install and update your antispyware technology: Spyware is just what it sounds like-software that is
surreptitiously installed on your computer to let others peer into your activities on the computer. Some spyware
collects information about you without your consent or produces unwanted pop-up ads on your web browser. Some
operating systems offer free spyware protection, and inexpensive software is readily available for download on the
Internet or at your local computer store. Be wary of ads on the Internet offering downloadable antispyware-in some
cases these products may be fake and may actually contain spyware or other malicious code.
(5) Maintain active and supported operating systems and application software. Computer operating systems (e.g.,
Windows 8.0) and application software (e.g., Microsoft Word) have a lifecycle that begins when a product is released
and ends when it's no longer supported. Install and maintain security updates and fixes updated to stay in tune with
technology requirements and to fix security holes. Be sure to install the updates to ensure your computer has the latest
protection.
(6) Be careful what you download: Carelessly downloading e-mail attachments can circumvent even the most vigilant
anti-virus software. Never open an e-mail attachment from someone you don't know and be wary of forwarded
attachments from people you do know. They may have unwittingly advanced malicious code.
(7) Turn off your computer: With the growth of high-speed Internet connections, many opt to leave their computers
on and ready for action. The downside is that being "always on" renders computers more susceptible. Beyond firewall
protection, which is designed to fend off unwanted attacks, turning the computer off effectively severs an attacker's
connection-be it spyware or a botnet that employs your computer's resources to reach out to other unwitting users.
(b)
You must encrypt files related to this project on your computer whenever you are not working on them using
a standard software encryption product such as Winzip (Version 18.5 or later with the Windows FIPS 140-2 validated
cryptographic modules enabled), Securezip, or any other product that meets Federal Information Processing Standard (FIPS)
140-2. If you do not already have a suitable encryption program on your computer, you can download one of these products
easily.
(c)
If the data under this contract will be accessed by more than one person, rules of behavior must be signed by users.
These rules shall address at a minimum: authorized and official use; prohibition against unauthorized users; and protection of
sensitive data and PII. You can comply by having all users sign these rules: 1. Keep all data and information received from
the government confidential. 2. Do not leave it unattended in a place where an unauthorized person might read, copy, or take
it. 3. Do not transmit it without encryption from one computer to another. 4. If confidentiality is breached, inform [name
principal of the contractor] within one hour of suspected breach so the United States can fulfill its obligations.
(d)
All PII data must be deleted from all contractor-owned devices within 15 days of contract termination or contractor
completion. The Contracting Officer (CO) must receive a written certification, either via email or letter, that the contractor has
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deleted all PII. This bulletin outlines approved method of data destruction; please see Appendix 1, which begins on page 26:
http://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-88r1.pdf.
(e)
All files related to this project, and contractor-owned removable media (such as removable hard drives, flash drives,
CDs, or floppy disks containing DOJ data) shall not be removed from DOJ facilities (either physically or electronically,
such as by email) unless encrypted using a NIST FIPS 140-2 approved product. Please note that this requirement refers to
transferring information between systems and storage devices (such as back and forth between contractor and DOJ attorney),
while paragraph (b) above applies to data while it is on your computer.
NOTE: As an alternative to media encryption, DOJ data may be securely exchanged between contractors and USAO personnel
via the approved U.S. Attorneys' File Exchange (USAfx) web portal.
(f)
Contractors shall keep an accurate inventory of DOJ-owned devices used on DOJ contracts. It is understood that not
all users will receive a DOJ-owned device. If equipment is provided, then the contractor, as well as the USAO providing the
devices, must maintain an inventory of accountable DOJ property.
(g)
If a data breach is suspected, the contractor shall, within one hour of discovery, report the breach to the EOUSA
Security Operations Center (SOC) at
(h)
The contractor must coordinate with EOUSA and the Department on notifying any individual whose PII was, or is
reasonably believed to have been, breached.
(i)
The contractor must require that all subcontractors under this contract (if any) adhere to all applicable security contract
requirements.
(end of clause)
EOUSA AI-10-1A Notice of Contractor Personnel Security Clearance Requirements (May 2016)
Notice of Contractor Personnel Security Clearance Requirements (May 2016)
Where performance under this contract/task or delivery order/call requires contractor personnel to have access to Department of
Justice (DOJ) information, systems or facilities, contractor personnel will be subject to the background clearance requirements of
Homeland Security Presidential Directive (HSPD)-12, OMB Guidance Memorandum M-05-24, FIPS Publication 201 and DOJ policy
implementing HSPD-12 requirements.
Background clearance requirements are determined by the risk level of each position, type of access and length of access required.
Further information on background security clearance requirements applicable to contractor personnel proposed for performance on
this contract/order/call may be obtained from the Contracting Officer.
All contractor personnel must meet the DOJ Residency Requirements. He/She must have lived in the United States three of the last
five years immediately prior to start of performance on this contract/order/call, and/or worked for the United States overseas in a
federal or military capacity, and/or be a dependent of a federal or military employee serving overseas. Specific limited waiver request
requirements - contractor personnel performing duties for a cumulative total of 14 days or less where there is a critical need for their
specialized and unique skills (as solely determined by the Government) may be proposed for a waiver of the Residency Requirement
by the contractor. Contractor personnel who are non-US citizens proposed for such a waiver of the Residency Requirement must be
from a country allied with the United States (Since the countries on the Allied Countries List are subject to change, the contractor may
review the following website for current information:
http://www.opm.gov
For contracts/orders/calls where access to DOJ information systems is involved, non-US citizens are not permitted to have access to or
assist in the development, operation, management or maintenance of any DOJ IT system, unless a waiver is granted by the head of the
Component, with concurrence of the Department Security Officer (DSO) and DOJ Chief Information Officer (CIO). Any such waiver
must be in writing and be obtained prior to allowing any contractor employee who is the subject of the waiver request to begin work
under this contract/order/call.
The above requirements apply to any and all contractor employees requiring access to DOJ information systems or facilities,
including subcontractor personnel, if applicable.
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(end of clause)
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Section 3 - Contract Clauses
A.1 ADDENDUM TO FAR 52.212-4, Specifications/Work Statement
The terms and conditions for the following clauses are hereby incorporated into this solicitation and resulting
contract as an addendum to FAR clause 52.212-4.
Clauses By Reference
52.252-2 CLAUSES INCORPORATED BY REFERENCE (FEB 1998)
This contract incorporates one or more clauses by reference, with the same force and effect as if they were given in full
text. Upon request, the Contracting Officer will make their full text available. Also, the full text of a clause may be accessed
electronically at this/these address(es): www.acquisition.gov
Clause
Title
Fill-ins (if applicable)
52.212-4
Contract Terms and Conditions-Commercial Items (Oct 2018)
52.212-4 Alt I
Contract Terms and Conditions-Commercial Items (Oct 2018) -
Alternate I (Jan 2017)
Clauses By Full Text
[END OF ADDENDUM TO FAR 52.212-4]
52.212-5
Contract Terms and Conditions Required to Implement Statutes or Executive Orders-
Commercial Items (Jan 2021)
(a) The Contractor shall comply with the following Federal Acquisition Regulation (FAR) clauses, which are incorporated in this
contract by reference, to implement provisions of law or Executive orders applicable to acquisitions of commercial items:
(1) 52.203-19, Prohibition on Requiring Certain Internal Confidentiality Agreements or Statements (Jan 2017) (section 743 of
Division E, Title VII, of the Consolidated and Further Continuing Appropriations Act, 2015 (Pub. L. 113-235) and its successor
provisions in subsequent appropriations acts (and as extended in continuing resolutions)).
(2) 52.204-23, Prohibition on Contracting for Hardware, Software, and Services Developed or Provided by Kaspersky Lab and Other
Covered Entities (Jul 2018) (Section 1634 of Pub. L. 115-91).
(3) 52.204-25, Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment. (Aug
2020) (Section 889(a)(1)(A) of Pub. L. 115-232).
(4) 52.209-10, Prohibition on Contracting with Inverted Domestic Corporations (Nov 2015).
(5) 52.233-3, Protest After Award (Aug 1996) (31 U.S.C. 3553).
(6) 52.233-4, Applicable Law for Breach of Contract Claim (Oct 2004)(Public Laws 108-77 and 108-78 (19 U.S.C. 3805 note)).
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(b) The Contractor shall comply with the FAR clauses in this paragraph (b) that the Contracting Officer has indicated as being
incorporated in this contract by reference to implement provisions of law or Executive orders applicable to acquisitions of commercial
items:
[Contracting Officer check as appropriate.]
(1) 52.203-6, Restrictions on Subcontractor Sales to the Government (Jun 2020), with Alternate I (Oct 1995) (41 U.S.C. 4704 and
-
10 U.S.C. 2402).
(2) 52.203-13, Contractor Code of Business Ethics and Conduct (Jun 2020) (41 U.S.C. 3509)).
-
(3) 52.203-15, Whistleblower Protections under the American Recovery and Reinvestment Act of 2009 (Jun 2010) (Section 1553
of Pub. L. 111-5). (Applies to contracts funded by the American Recovery and Reinvestment Act of 2009.)
(4) 52.204-10, Reporting Executive Compensation and First-Tier Subcontract Awards (Jun 2020) (Pub. L. 109-282) (31 U.S.C.
6101 note).
- (5) [Reserved].
-
(6) 52.204-14, Service Contract Reporting Requirements (Oct 2016) (Pub. L. 111-117, section 743 of Div. C).
(7) 52.204-15, Service Contract Reporting Requirements for Indefinite-Delivery Contracts (Oct 2016) (Pub. L. 111-117, section
743 of Div. C).
-
(8) 52.209-6, Protecting the Government's Interest When Subcontracting with Contractors Debarred, Suspended, or Proposed for
Debarment. (Jun 2020) (31 U.S.C. 6101 note).
-
(9) 52.209-9, Updates of Publicly Available Information Regarding Responsibility Matters (Oct 2018) (41 U.S.C. 2313).
(10) [Reserved].
-
(11)(i) 52.219-3, Notice of HUBZone Set-Aside or Sole-Source Award (Mar 2020) (15 U.S.C. 657a).
-
- (ii) Alternate I (Mar 2020) of 52.219-3.
(12)(i) 52.219-4, Notice of Price Evaluation Preference for HUBZone Small Business Concerns (Mar 2020) (if the offeror elects to
-
waive the preference, it shall so indicate in its offer) (15 U.S.C. 657a).
(ii) Alternate I (Mar 2020) of 52.219-4.
-
(13) [Reserved]
-
(14)(i) 52.219-6, Notice of Total Small Business Set-Aside (Nov 2020) (15 U.S.C. 644).
-
(ii) Alternate I (Mar 2020) of 52.219-6.
-
- (15)(i) 52.219-7, Notice of Partial Small Business Set-Aside (Nov 2020) (15 U.S.C. 644).
(ii) Alternate I (Mar 2020) of 52.219-7.
-
(16) 52.219-8, Utilization of Small Business Concerns (Oct 2018) (15 U.S.C. 637(d)(2) and (3)).
-
(17)(i) 52.219-9, Small Business Subcontracting Plan (Jun 2020) (15 U.S.C. 637(d)(4)).
-
(ii) Alternate I (Nov 2016) of 52.219-9.
-
(iii) Alternate II (Nov 2016) of 52.219-9.
-
(iv) Alternate III (Jun 2020) of 52.219-9.
-
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- (v) Alternate IV (Jun 2020) of 52.219-9.
(18)(i) 52.219-13, Notice of Set-Aside of Orders (Mar 2020) (15 U.S.C. 644(r)).
-
(ii) Alternate I (Mar 2020) of 52.219-13.
-
(19) 52.219-14, Limitations on Subcontracting (Mar 2020) (15 U.S.C. 637(a)(14)).
-
(20) 52.219-16, Liquidated Damages--Subcon-tracting Plan (Jan 1999) (15 U.S.C. 637(d)(4)(F)(i).
-
(21) 52.219-27, Notice of Service-Disabled Veteran-Owned Small Business Set-Aside (Mar 2020) (15 U.S.C. 657f).
-
(22)(i) 52.219-28, Post Award Small Business Program Rerepresentation (Nov 2020) (15 U.S.C. 632(a)(2)).
-
(ii) Alternate I (Mar 2020) of 52.219-28.
-
(23) 52.219-29, Notice of Set-Aside for, or Sole Source Award to, Economically Disadvantaged Women-Owned Small Business
Concerns (Mar 2020) (15 U.S.C. 637(m)).
(24) 52.219-30, Notice of Set-Aside for, or Sole Source Award to, Women-Owned Small Business Concerns Eligible Under the
Women-Owned Small Business Program (Mar 2020) (15 U.S.C. 637(m)).
(25) 52.219-32, Orders Issued Directly Under Small Business Reserves (Mar 2020) (15 U.S.C. 644(r)).
-
(26) 52.219-33, Nonmanufacturer Rule (Mar 2020) (15 U.S.C. 637(a)(17)).
-
(27) 52.222-3, Convict Labor (June 2003) (E.O. 11755).
-
-
(28) 52.222-19, Child Labor--Cooperation with Authorities and Remedies (Jan 2020) (E.O. 13126).
-
(29) 52.222-21, Prohibition of Segregated Facilities (Apr 2015).
(30)(i) 52.222-26, Equal Opportunity (Sept 2016) (E.O. 11246).
-
(ii) Alternate I (Feb 1999) of 52.222-26.
- (31)(i) 52.222-35, Equal Opportunity for Veterans (Jun 2020) (38 U.S.C. 4212).
(ii) Alternate I (July 2014) of 52.222-35.
-
-
(32)(i) 52.222-36, Equal Opportunity for Workers with Disabilities (Jun 2020) (29 U.S.C. 793).
(ii) Alternate I (July 2014) of 52.222-36.
-
(33) 52.222-37, Employment Reports on Veterans (Jun 2020) (38 U.S.C. 4212).
-
(34) 52.222-40, Notification of Employee Rights Under the National Labor Relations Act (Dec 2010) (E.O. 13496).
-
- (35)(i) 52.222-50, Combating Trafficking in Persons (Oct 2020) (22 U.S.C. chapter 78 and E.O. 13627).
(ii) Alternate I (Mar 2015) of 52.222-50 (22 U.S.C. chapter 78 and E.O. 13627).
-
(36) 52.222-54, Employment Eligibility Verification (Oct 2015). (Executive Order 12989). (Not applicable to the acquisition of
commercially available off-the-shelf items or certain other types of commercial items as prescribed in 22.1803.)
(37)(i) 52.223-9, Estimate of Percentage of Recovered Material Content for EPA-Designated Items (May 2008) (42 U.S.C. 6962(c)
-
(3)(A)(ii)). (Not applicable to the acquisition of commercially available off-the-shelf items.)
(ii) Alternate I (May 2008) of 52.223-9 (42 U.S.C. 6962(i)(2)(C)). (Not applicable to the acquisition of commercially available off-
I
the-shelf items.)
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(38) 52.223-11, Ozone-Depleting Substances and High Global Warming Potential Hydrofluorocarbons (Jun 2016) (E.O. 13693).
-
-
(39) 52.223-12, Maintenance, Service, Repair, or Disposal of Refrigeration Equipment and Air Conditioners (Jun 2016) (E.O.
13693).
(40)(i) 52.223-13, Acquisition of EPEAT@-Registered Imaging Equipment (Jun 2014) (E.O.s 13423 and 13514).
-
(ii) Alternate I (Oct 2015) of 52.223-13.
-
(41)(i) 52.223-14, Acquisition of EPEAT@-Registered Televisions (Jun 2014) (E.O.s 13423 and 13514).
(ii) Alternate I (Jun 2014) of 52.223-14.
-
-
(42) 52.223-15, Energy Efficiency in Energy-Consuming Products (May 2020) (42 U.S.C. 8259b).
-
(43)(i) 52.223-16, Acquisition of EPEAT@-Registered Personal Computer Products (Oct 2015) (E.O.s 13423 and 13514).
(ii) Alternate I (Jun 2014) of 52.223-16.
(44) 52.223-18, Encouraging Contractor Policies to Ban Text Messaging While Driving (Jun 2020) (E.O. 13513).
(45) 52.223-20, Aerosols (Jun 2016) (E.O. 13693).
-
(46) 52.223-21, Foams (Jun 2016) (E.O. 13693).
-
(47)(i) 52.224-3, Privacy Training (Jan 2017) (5 U.S.C. 552a).
-
(ii) Alternate I (Jan 2017) of 52.224-3.
-
-
(48) 52.225-1, Buy American--Supplies (Jan 2021) (41 U.S.C. chapter 83).
(49)(i) 52.225-3, Buy American--Free Trade Agreements--Israeli Trade Act (Jan 2021) (41 U.S.C. chapter 83, 19 U.S.C. 3301
note, 19 U.S.C. 2112 note, 19 U.S.C. 3805 note, 19 U.S.C. 4001 note, Pub. L. 103-182, 108-77, 108-78, 108-286, 108-302, 109-53,
109-169, 109-283, 110-138, 112-41, 112-42, and 112-43.
(ii) Alternate I (Jan 2021) of 52.225-3.
(iii) Alternate II (Jan 2021) of 52.225-3.
(iv) Alternate III (Jan 2021) of 52.225-3.
-
(50) 52.225-5, Trade Agreements (Oct 2019) (19 U.S.C. 2501, et seq., 19 U.S.C. 3301 note).
(51) 52.225-13, Restrictions on Certain Foreign Purchases (June 2008) (E.O.'s, proclamations, and statutes administered by the
Office of Foreign Assets Control of the Department of the Treasury).
(52) 52.225-26, Contractors Performing Private Security Functions Outside the United States (Oct 2016) (Section 862, as amended,
of the National Defense Authorization Act for Fiscal Year 2008; 10 U.S.C. 2302 Note).
(53) 52.226-4, Notice of Disaster or Emergency Area Set-Aside (Nov 2007) (42 U.S.C. 5150).
(54) 52.226-5, Restrictions on Subcontracting Outside Disaster or Emergency Area (Nov 2007) (42 U.S.C. 5150).
-
(55) 52.229-12, Tax on Certain Foreign Procurements (Jun 2020).
-
(56) 52.232-29, Terms for Financing of Purchases of Commercial Items (Feb 2002) (41 U.S.C. 4505, 10 U.S.C. 2307(f)).
-
(57) 52.232-30, Installment Payments for Commercial Items (Jan 2017) (41 U.S.C. 4505, 10 U.S.C. 2307(f)).
-
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- (58) 52.232-33, Payment by Electronic Funds Transfer--System for Award Management (Oct 2018) (31 U.S.C. 3332).
-
(59) 52.232-34, Payment by Electronic Funds Transfer-Other than System for Award Management (Jul 2013) (31 U.S.C. 3332).
-
(60) 52.232-36, Payment by Third Party (May 2014) (31 U.S.C. 3332).
-
(61) 52.239-1, Privacy or Security Safeguards (Aug 1996) (5 U.S.C. 552a).
(62) 52.242-5, Payments to Small Business Subcontractors (Jan 2017)(15 U.S.C. 637(d)(13)).
-
-
(63)(i) 52.247-64, Preference for Privately Owned U.S.-Flag Commercial Vessels (Feb 2006) (46 U.S.C. Appx. 1241(b) and 10
U.S.C. 2631).
- (ii) Alternate I (Apr 2003) of 52.247-64.
- (iii) Alternate II (Feb 2006) of 52.247-64.
(c) The Contractor shall comply with the FAR clauses in this paragraph (c), applicable to commercial services, that the Contracting
Officer has indicated as being incorporated in this contract by reference to implement provisions of law or Executive orders applicable
to acquisitions of commercial items:
[Contracting Officer check as appropriate.]
-
(1) 52.222-41, Service Contract Labor Standards (Aug 2018) (41 U.S.C. chapter 67).
(2) 52.222-42, Statement of Equivalent Rates for Federal Hires (May 2014) (29 U.S.C. 206 and 41 U.S.C. chapter 67).
-
-
(3) 52.222-43, Fair Labor Standards Act and Service Contract Labor Standards-Price Adjustment (Multiple Year and Option
Contracts) (Aug 2018) (29 U.S.C. 206 and 41 U.S.C. chapter 67).
(4) 52.222-44, Fair Labor Standards Act and Service Contract Labor Standards--Price Adjustment (May 2014) (29 U.S.C. 206 and
41 U.S.C. chapter 67).
(5) 52.222-51, Exemption from Application of the Service Contract Labor Standards to Contracts for Maintenance, Calibration, or
Repair of Certain Equipment--Requirements (May 2014) (41 U.S.C. chapter 67).
-
(6) 52.222-53, Exemption from Application of the Service Contract Labor Standards to Contracts for Certain Services--
Requirements (May 2014) (41 U.S.C. chapter 67).
- (7) 52.222-55, Minimum Wages Under Executive Order 13658 (Nov 2020).
- (8) 52.222-62, Paid Sick Leave Under Executive Order 13706 (Jan 2017) (E.O. 13706).
-
(9) 52.226-6, Promoting Excess Food Donation to Nonprofit Organizations (Jun 2020) (42 U.S.C. 1792).
(d) Comptroller General Examination of Record. The Contractor shall comply with the provisions of this paragraph (d) if this contract
was awarded using other than sealed bid, is in excess of the simplified acquisition threshold, as defined in FAR 2.101, on the date of
award of this contract and does not contain the clause at 52.215-2, Audit and Records--Negotiation.
(1) The Comptroller General of the United States, or an authorized representative of the Comptroller General, shall have access to and
right to examine any of the Contractor's directly pertinent records involving transactions related to this contract.
(2) The Contractor shall make available at its offices at all reasonable times the records, materials, and other evidence for examination,
audit, or reproduction, until 3 years after final payment under this contract or for any shorter period specified in FAR subpart 4.7,
Contractor Records Retention, of the other clauses of this contract. If this contract is completely or partially terminated, the records
relating to the work terminated shall be made available for 3 years after any resulting final termination settlement. Records relating
to appeals under the disputes clause or to litigation or the settlement of claims arising under or relating to this contract shall be made
available until such appeals, litigation, or claims are finally resolved.
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(3) As used in this clause, records include books, documents, accounting procedures and practices, and other data, regardless of type
and regardless of form. This does not require the Contractor to create or maintain any record that the Contractor does not maintain in
the ordinary course of business or pursuant to a provision of law.
(e)(1) Notwithstanding the requirements of the clauses in paragraphs (a), (b), (c), and (d) of this clause, the Contractor is not required
to flow down any FAR clause, other than those in this paragraph (e)(1) in a subcontract for commercial items. Unless otherwise
indicated below, the extent of the flow down shall be as required by the clause--
(i) 52.203-13, Contractor Code of Business Ethics and Conduct (Jun 2020) (41 U.S.C. 3509).
(ii) 52.203-19, Prohibition on Requiring Certain Internal Confidentiality Agreements or Statements (Jan 2017) (section 743 of
Division E, Title VII, of the Consolidated and Further Continuing Appropriations Act, 2015 (Pub. L. 113-235) and its successor
provisions in subsequent appropriations acts (and as extended in continuing resolutions)).
(iii) 52.204-23, Prohibition on Contracting for Hardware, Software, and Services Developed or Provided by Kaspersky Lab and Other
Covered Entities (Jul 2018) (Section 1634 of Pub. L. 115-91).
(iv) 52.204-25, Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment. (Aug
2020) (Section 889(a)(1)(A) of Pub. L. 115-232).
(v) 52.219-8, Utilization of Small Business Concerns (Oct 2018) (15 U.S.C. 637(d)(2) and (3)), in all subcontracts that offer further
subcontracting opportunities. If the subcontract (except subcontracts to small business concerns) exceeds the applicable threshold
specified in FAR 19.702(a) on the date of subcontract award, the subcontractor must include 52.219-8 in lower tier subcontracts that
offer subcontracting opportunities.
(vi) 52.222-21, Prohibition of Segregated Facilities (Apr 2015)
(vii) 52.222-26, Equal Opportunity (Sept 2016) (E.O. 11246).
(viii) 52.222-35, Equal Opportunity for Veterans (Jun 2020) (38 U.S.C. 4212).
(ix) 52.222-36, Equal Opportunity for Workers with Disabilities (Jun 2020) (29 U.S.C. 793).
(x) 52.222-37, Employment Reports on Veterans (Jun 2020) (38 U.S.C. 4212)
(xi) 52.222-40, Notification of Employee Rights Under the National Labor Relations Act (Dec 2010) (E.O. 13496). Flow down
required in accordance with paragraph (f) of FAR clause 52.222-40.
(xii) 52.222-41, Service Contract Labor Standards (Aug 2018) (41 U.S.C. chapter 67).
(xiii) (A) 52.222-50, Combating Trafficking in Persons (Oct 2020) (22 U.S.C. chapter 78 and E.O 13627).
(B) Alternate I (Mar 2015) of 52.222-50 (22 U.S.C. chapter 78 and E.O 13627).
(xiv) 52.222-51, Exemption from Application of the Service Contract Labor Standards to Contracts for Maintenance, Calibration, or
Repair of Certain Equipment-Requirements (May 2014) (41 U.S.C. chapter 67).
(xv) 52.222-53, Exemption from Application of the Service Contract Labor Standards to Contracts for Certain Services-Requirements
(May 2014) (41 U.S.C. chapter 67).
(xvi) 52.222-54, Employment Eligibility Verification (Oct 2015) (E.O. 12989).
(xvii) 52.222-55, Minimum Wages Under Executive Order 13658 (Nov 2020).
(xviii) 52.222-62, Paid Sick Leave Under Executive Order 13706 (Jan 2017) (E.O. 13706).
(xix)(A) 52.224-3, Privacy Training (Jan 2017) (5 U.S.C. 552a).
(B) Alternate I (Jan 2017) of 52.224-3.
3502-007
Page 17 of 19
EFTA00026955

=== Page 18 ===
15JA5421P00000117 Page 18 of 19
(xx) 52.225-26, Contractors Performing Private Security Functions Outside the United States (Oct 2016) (Section 862, as amended, of
the National Defense Authorization Act for Fiscal Year 2008; 10 U.S.C. 2302 Note).
(xxi) 52.226-6, Promoting Excess Food Donation to Nonprofit Organizations (Jun 2020) (42 U.S.C. 1792). Flow down required in
accordance with paragraph (e) of FAR clause 52.226-6.
(xxii) 52.247-64, Preference for Privately Owned U.S.-Flag Commercial Vessels (Feb 2006) (46 U.S.C. Appx. 1241(b) and 10 U.S.C.
2631). Flow down required in accordance with paragraph (d) of FAR clause 52.247-64.
(2) While not required, the Contractor may include in its subcontracts for commercial items a minimal number of additional clauses
necessary to satisfy its contractual obligations.
(End of clause)
3502-007
Page 18 of 19
EFTA00026956

=== Page 19 ===
15JA5421P00000117 Page 19 of 19
Section 4 - List of Attachments
3502-007
Page 19 of 19
EFTA00026957


c1: EFTA00024437
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024437.pdf
c6: pdf
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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: RE: Ghislaine Maxwell (USMS No. 02879-509)
Date: Wed, 08 Jul 2020 14:59:05 +0000
Thank you,
We will convey this information to defense counsel and ask that they follow the protocol for any calls
other than the standing 10am calls.
From:
Sent: Tuesday, July 7, 2020 7:51 PM
To:
is
Cc:
Subject: RE: Ghislaine Maxwell (USMS No. 02879-509)
You're welcome. We will do our best to provide a call at 10:00 AM every day this week to Mr. Everdell at the number he has
previously provided. We will also provide a call on Monday 7/13/20.
The EDNY and SDNY created a joint protocol whereby counsel may request legal calls to be placed in the afternoon at the
MDC. Requests should be sent to
Truly urgent requests can be sent to me, but unless there is a last minute, imminent court deadline, counsel really should
send the requests to the federal defenders, as outlined in the protocol. We want to ensure inmates get equitable access. If
they anticipate needing several calls in a week, they should make requests in advance and note whether and when calls
would be preferred. Generally, calls are for 30 minutes in duration. If a longer call is desired, that should be explained as well.
If you need anything else, please let me know.
Thank you,
>>>
)" <
> 7/7/2020 5:00 PM >>>
Thank you so much,
A 10am standing legal call every day before the arraignment on Tuesday 7/14 would be perfect if that's something you
would be able to accommodate. Defense counsel will be available at that time, and they are very grateful for the time.
We have also conveyed to defense counsel that they will need to follow the same protocols as other inmates' counsel
following the arraignment. Thank you for letting us know about the lack of requests from defense counsel thus far. There
appears to be some confusion on their end about how to submit requests to schedule legal calls. Would you be able to
please share with us the procedure that they should follow, so that we can make sure they understand what steps to take
going forward?
Thank you again for all of your help-we really appreciate it.
Best,
EFTA00024437

=== Page 2 ===
From:
Sent: Tuesday, July 7, 2020 4:23 PM
To:
Cc:
is
Subject: RE: Ghislaine Maxwell (USMS No. 02879-509)
You're welcome.
Would 10 am work as a standing legal call through the end of this week (and Monday, if you think that's a good idea), in
advance of the arraignment on Tuesday? However, after this, defense counsel should be required to follow the same
protocols as all other inmates' counsel with respect to requesting legal calls.
I also just want to make clear that defense counsel sent no requests yesterday that I am aware of, and we were able to
facilitate a call yesterday evening following a request from your office, and today, I received one request, about mid-day,
that we were again able to accommodate. So, I do not think it is fair at all to categorize this as defense counsel having
difficulty scheduling legal calls.
Thank you,
>>>
)"
>
7/7/2020 2:37 PM >>>
Thanks,
This is about the legal call today. In addition, because defense counsel his having difficulty scheduling legal
calls, it would be helpful if MDC could schedule standing calls for the rest of this week to address this issue. Thanks very
much.
From:
Sent: Tuesday, July 7, 2020 2:36 PM
To:
Cc:
is
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509)
Hi
I just saw this now. Is this about the legal call issue or something separate? If it's about the legal call, I am working on it.
Thanks,
>>>
)"
> 7/7/2020 1:27 PM >>>
Hi
Thanks for your help with this. Are you available now for a call? We are having a time sensitive issue with this.
Thanks,
Sent from my iPhone
On Jul 6, 2020, at 7:59 PM,
<
>
wrote:
Hi
For future reference, there is a protocol in place for defense counsel to reques legal calls. If counsel is unaware of it, I can
provide the details.
EFTA00024438

=== Page 3 ===
However, I understand that she just came into custody today and there is a more urgent deadline. If you can please
provide the name and phone number of counsel, I will do my best.
Thanks,
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
)"
>
Date: 7/6/20 7:48 PM (GMT-05:00)
To:
<
>
Cc:
>,
>
Subject: Ghislaine Maxwell (USMS No. 02879-509)
>>>
)" 07/06/2020 19:48 >>>
Hi
Hope you're doing well. This evening, Judge Nathan directed the parties in the US V. Ghislaine Maxwell case to file a
letter by 9pm today. Defense counsel need to speak with Ms. Maxwell this evening about the letter, but they have not
been able to reach her. Would it be possible to allow Ms. Maxwell to make a legal call to her lawyers this evening,
please?
Thank you very much for your help.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00024439


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c7: images
c0:
=== Page 1 ===
From:
"
To:
Subject: 2021.10.11 Maxwell Cover Letter v3.docx
Date: Sun, 10 Oct 2021 17:38:03 +0000
Attachments: 2021.10.11_Maxwell_Cover_Letter_v3.docx
EFTA00025277


c1: EFTA00026703
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=== Page 1 ===
From:
To:
Subject: Law360; Dershowitz Can Pursue Bid To DQ Boies Schiller In Sex Case
Date: Wed, 19 Jun 2019 20:29:48 +0000
Importance: Normal
Dershowitz Can Pursue Bid To DQ Boies Schiller In
Sex Case
By Andrew Strickler
Share us on: By Andrew Strickler
Law360 (June 18, 2019, 6:13 PM EDT) -- The New York federal judge who initially refused to hear Alan Dershowitz's
request to disqualify Boies Schiller Flexner LLP from representing a woman accusing the prominent attorney and retired
Harvard Law School professor of sexually molesting her said on Monday that she would consider it.
In a brief order, U.S. District Judge Loretta A. Preska allowed Dershowitz's motion to be reinstated and said he could file a
28-page memo on his request.
The order comes a week after Judge Preska said she was removing the motion because Dershowitz didn't request a
premotion conference before the filing in violation of a court rule.
Dershowitz's accuser,
has alleged that convicted billionaire sex offender Jeffrey Epstein "lent her out for
sex" to Dershowitz and that Dershowitz played a role as Epstein's attorney and friend in a human trafficking scheme
during the late 1990s and early 2000s involving dozens of underage girls.
In a July 7 motion, Dershowitz argued that Boies Schiller shouldn't be allowed to continue to represent
because
the firm has "severe" conflicts in the case.
Those stem from an offer made in 2015 by Boies Schiller partner Carlos Sires to represent Dershowitz after
alleged
in a separate Crime Victims Rights Act suit focused on Epstein's deal with prosecutors that she had sex with Dershowitz
and others.
Dershowitz said in his motion he didn't learn Boies Schiller was representing his accuser in the current case until after he
shared with Sires a "highly confidential" memo spelling out his legal strategy in the case. The next day, Sires informed
Dershowitz that a client conflict was going to prevent him from representing Dershowitz.
Last week, Boies Schiller submitted a letter to the court stating that Dershowitz hadn't complied with the premotion
conference rule; Judge Preska agreed and ordered his filing "marked off the calendar."
"Professor Dershowitz is gratified that the court will consider the motion on its merits," said Dershowitz counsel Arthur L.
Aidala and Imran H. Ansari in a statement Tuesday.
Giuffre counsel Joshua Schiller of Boies Schiller submitted a letter to Judge Preska on Monday urging her to deny the
disqualification request without further briefing.
Dershowitz filed the "tactical" motion months into the suit despite having known for some five years that the firm
EFTA00026703

=== Page 2 ===
represents
Schiller said. Moreover, Dershowitz's brief contact with Sires never resulted in the formation of an
attorney-client relationship.
"Even though he knew that BSF's conflict check had not been completed, Dershowitz copied Mr. Sires into a group e-mail
attaching a memorandum, which Dershowitz now claims was confidential," Schiller wrote, adding that the memo was
addressed to Dershowitz's "friends" and contained no confidential information.
"This is an attempt to manufacture a conflict and delay the case and prevent our client from working with the counsel
she's worked with for five years," Schiller told Law360.
Dershowitz's ties to the Epstein scandal were back in the news after a February ruling by U.S. District Judge Kenneth A.
Marra, who found current Labor Secretary Alex Acosta had been among several prosecutors who mishandled a decade-
old sex crime case against Epstein when they signed a nonprosecution agreement with Epstein without notifying his
victims.
is represented by Joshua Schiller and Sigrid McCawley of Boies Schiller Flexner LLP.
Dershowitz is represented by Imran H. Ansari and Arthur L. Aidala of Aidala Bertuna & Kamins PC.
The case is Giuffre V. Dershowitz, case number 1:19-cv-03377, in the U.S. District Court for the Southern District of New
York.
EFTA00026704


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From:
(USANYS) [Contractor]"
To:
)"
Cc:
)"
)"
Subject: RE: Marshals Intake Form
Date: Wed, 22 Jul 2020 21:27:55 +0000
Will do.
From:
Sent: Wednesday, July 22, 2020 5:01 PM
To:
(USANYS) [Contractor]
Cc:
is
Subject: FW: Marshals Intake Form
could you please add this to the share and to the initial discovery production for Maxwell? Thanks.
From:
(USANYS)
Sent: Wednesday, July 22, 2020 17:00
To:
>; USANYS-INVESTIGATORS
Subject: RE: Marshals Intake Form
See attached.
From:
Sent: Wednesday, July 22, 2020 4:46 PM
To: USANYS-INVESTIGATORS
Subject: Marshals Intake Form
Please process the following:
Requestor's Phone Number:
Name / Alias(es): Ghislaine Maxwell
Court Number: 20 Cr. 330 (AJN)
USAO Number: 2018R01618
USMS Number: 02879-509
Arrest Date: 07/02/20
Date of Birth:
Documents: Email
Photo:
Email
Remarks:
EFTA00024720


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=== Page 1 ===
From:
"
To:
Cc:
Subject: RE: United States V. Ghislaine Maxwell, 20 Cri. 330 (AJN)
Date: Thu, 28 Oct 2021 18:25:01 +0000
Thank you.
Supervisory Deputy U.S. Marshal
U.S. Marshals Service
Southern District New York
From:
Sent: Thursday, October 28, 2021 12:25 PM
To:
Cc:
is
>;
is
is
Subject: RE: United States V. Ghislaine Maxwell, 20 Cri. 330 (AJN)
Hi
We've conferred with the defense, and they would prefer to do the evidence inspection at the proffer rooms at 500 Pearl
immediately following the conference on Monday, 11/1.
Thanks,
From:
Sent: Wednesday, October 27, 2021 11:45 AM
To:
Cc:
is
is
is
is
Subject: RE: United States V. Ghislaine Maxwell, 20 Cri. 330 (AJN)
Hello
Please give me a call.
Thanks,
EFTA00025160

=== Page 2 ===
Supervisory Deputy U.S. Marshal
U.S. Marshals Service
Southern District New York
From:
Sent: Wednesday, October 27, 2021 9:37 AM
To:
Cc:
is
is
>;
is
Subject: RE: United States V. Ghislaine Maxwell, 20 Cri. 330 (AJN)
Hi
Thanks very much. To confirm, are do you mean Friday, 10/29, or Friday, 11/5? And is there a particular time that she will
arrive at the court?
Thanks,
From:
Sent: Tuesday, October 26, 2021 8:28 PM
To:
Cc:
is
>;
is
is
Subject: Re: United States V. Ghislaine Maxwell, 20 Cri. 330 (AJN)
Hello
Friday works best for us. I will be in contact tomorrow to coordinate.
Regards,
Supervisory Deputy U.S. Marshal
U.S. Marshals Service
Southern District of New York
On Oct 26, 2021, at 8:07 PM,
wrote:
Hi
EFTA00025161

=== Page 3 ===
Defense counsel has requested that we schedule an evidence inspection this week with the defendant present. We'd very
much appreciate it if the marshals could produce the defendant to a proffer room this week at 500 Pearl Street. Our
understanding from Eric Blachman, copied here, is that the marshals have been producing defendants for meetings of this
type. A CSO and a case agent will be present for the meeting.
Could you please let us know what dates this week would work for the meeting? We are scheduling this with defense
attorneys who are flying in from out of state, so would appreciate if you could let us know what dates work this week.
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00025162


c1: EFTA00025501
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=== Page 1 ===
From:
)"
To: Sigrid McCawley
Cc:
)"
Subject: RE:
follow-up request
Date: Fri, 08 May 2020 17:58:47 +0000
Sigrid,
Thanks for getting back to us so quickly. Goes without saying that we of course would be happy for you to be on the call
as well-I should have mentioned that in my initial email. On timing, let us just check with the agents on the case to see if
that works for them, and we hope to be able to confirm with you in the next couple hours.
thanks,
From: Sigrid McCawley
Sent: Friday, May 08, 2020 13:27
To:
Cc:
Subject: RE:
follow-up request
Hello
-
said she has time tomorrow if that would work for you team. She is in Texas so an hour behind us. I
would like to be on the call as well. Would it work to do something tomorrow at 11:00 EST? Let me know. If that does not
work I can try to get other times.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Friday, May 8, 2020 11:02 AM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize
the sender.
I unfortunately was on trial during the previous interview, but I think somewhat less time than how long it went last time.
Ordinarily we try not to go longer than about 90 minutes in any event, so I think if she is able to block out that amount of
EFTA00025501

=== Page 2 ===
time, that would be great - and we'll try to be as efficient as possible and hopefully take less than that. If that sounds
alright?
thanks,
From: Sigrid McCawley
Sent: Thursday, May 07, 2020 18:57
To:
Cc:
Subject: RE:
follow-up request
Hello
I am sure
will be happy to help in any way she can. Let me find out what her patient schedule is like for next week
and find a time that works. How much time do you think she should allot for the interview - just so she can plan?
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Thursday, May 7, 2020 6:41 PM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
Hi Sigrid,
We wanted to follow up in connection with
- our supervisors have asked us to do an additional interview with her,
both to follow up on some specific aspects of her recollection but also do basically go through her experiences again. As
I'm sure you know, we have no doubts whatsoever, at all, about her candor and truthfulness in our previous interview,
which also was broadly consistent with what she has said in other interviews, but we are nevertheless hoping she might
be willing to speak with us sometime in the next week or two? Obviously due to the current situation we would plan to
do it via phone, and we would be happy to chat about logistics with you if that would be helpful, or to answer any
questions at all. And if
is willing to speak with us again, we're happy to work around her schedule, including talking
during an evening or weekend if that's easier for her than during the day-whatever you and she would prefer.
Please let us know if any questions, or if it would be useful to chat, and thanks very much.
EFTA00025502

=== Page 3 ===
From:
Sent: Thursday, January 16, 2020 14:35
To: Sigrid McCawley
Cc:
is
)
Subject: RE:
follow-up request
Got it, thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 2:29 PM
To:
Cc:
is
)
Subject: RE:
follow-up request
I checked back with
and she said that the last entry in her journal is in late February and she
went to New Mexico in April.
Thanks
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
Sent by Boxer
On January 16, 2020 at 1:05:54 PM EST,
)
wrote:
Thank you very much, Sigrid.
EFTA00025503

=== Page 4 ===
Just to confirm, does
have any journal entries regarding the time when she traveled to New Mexico? I
believe she told us during our interview that she does not have any entries from that time, but I just wanted to
make sure.
Thanks again,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 12:31 PM
To:
)
Cc:
)
;
)
Subject: RE:
follow-up request
Hello - attached are the pages
sent me to provide to you. Here is a bit of an explanation and I also
asked her to take a copy of the front and back of the journal book which she did. Hope this helps. Please let
me know if you need anything else:
"The shortest page and the one that is the hardest to read is the first entry from 12/95. It is written in colored
pencil and is fading. There are then two pages from 01/07/1996 where I talk about the highlights of my NY
trip and going to Epstein's house and then the next entry from 01/25/1996 is where I talk about going to the
movies with him."
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
) [mailto:
Sent: Friday, January 10, 2020 4:01 PM
To: Sigrid McCawley
Cc:
)
)
EFTA00025504

=== Page 5 ===
Subject: RE:
follow-up request
Thanks very much, Sigrid. Yes, we received the photographs from
,
which we very much appreciate.
Anything else she is willing to share, including her journal entries, would be very helpful.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Friday, January 10, 2020 3:59 PM
To:
Cc:
)
i
)
Subject: RE:
follow-up request
Hello
,
Let me follow up with
about her journal. I know she shared some pictures with you from around the
time period when she was with Epstein/Maxwell. I will ask her about the journal ASAP and will get back to
you and will check with her to see if she has anything else that might be helpful to the investigation.
All my best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 3:30 PM
To: Sigrid McCawley
Cc:
)
i
)
Subject:
follow-up request
EFTA00025505

=== Page 6 ===
Hi Sigrid,
Hope you had a wonderful holiday season and very happy New Year. We wanted to follow up on a request we
made after interviewing
a few months ago. During her interview,
referred to several
entries in her journal that had helped refresh her recollection of the events involving Epstein and Maxwell. As
we mentioned at the end of the interview, it would be very helpful to our investigation if we could review
those journal entries, as well as any other records or documents
may have that relate to her experiences
with Epstein and Maxwell.
Would
be willing to share with us any relevant journal entries (or any other relevant documents she may
have) to assist in our investigation?
Happy to have a call to discuss if that would be helpful.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information
that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of
this 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
EFTA00025506


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
)"
Cc:
)"
(USANYS)"
Subject: RE: Discovery questions
Date: Thu, 20 Aug 2020 22:27:22 +0000
Thanks so much,
From:
(NY) (FBI)
Sent: Thursday, August 20, 2020 6:17 PM
To:
is
Cc:
(USANYS)
Subject: RE: Discovery questions
Hey all,
Just wanted to send a quick email to detail what is being given today. There is a box of media, including VHS, cassette,
and microcassettes, and newspaper articles that were provided by Reiter.
On the thumbdrive is a spreadsheet outlining what is included; items highlighted in blue are included. You will notice a
comment "see disk tracking spreadsheet" in items not highlighted; this spreadsheet will be included in the disk copies we
send over that will detail how many images total and how many removed.
There are loose disks which include 1B evidence scans, 1D1-1D5 evidence items, LSJ 3D imaging, and the FBI file.
Separately, we will keep you updated as we continue to work on the redactions and will let you know as soon as we finish
with the disks.
Let us know you have any questions.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
C:
From:
Sent: Wednesday, August 19, 2020 8:43 PM
To:
Cc:
(NY) (FBI)
is
i
is
(USANYS)
Subject: [EXTERNAL EMAIL] - Re: Discovery questions
I'll be in the office tomorrow.
EFTA00023673

=== Page 2 ===
Sent from my iPhone
On Aug 19, 2020, at 8:18 PM,
)
wrote:
Great, thanks very much. I'm not in the office right now, but hopefully someone from the team can grab these. If not, I
can find a paralegal to take them.
From:
(NY) (FBI)
Sent: Wednesday, August 19, 2020 7:24 PM
To:
)
is
is
Cc:
)
is
(USANYS)
Subject: RE: Discovery questions
Sure no problem. I can bring those over tomorrow as well.
From:
Sent: Wednesday, August 19, 2020 7:22 PM
To:
(NY) (FBI)
i
is
)
Cc:
>;
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Discovery questions
Perfect, thanks! Yes, I think we should take the vhs tapes and microcassettes to get them converted, if that's ok.
From:
(NY) (FBI)
Sent: Wednesday, August 19, 2020 7:20 PM
To:
)
is
is
Cc:
is
(USANYS)
Subject: RE: Discovery questions
That sounds great. Thank you. We are definitely open to them scheduling a time if need be.
I will check in with CART again and get back to you.
As far as the paper evidence and case file, we can drop that off to your office sometime tomorrow evening. Just working
on putting it all on a disk/thumbdrive for you. Also, FYI, included in the boxes from Reiter are vhs tapes and
microcassettes. Would you like us to turn these over to you as well? Let me know your thoughts on this.
Thanks!
From:
Sent: Wednesday, August 19, 2020 7:01 PM
To:
(NY) (FBI)
is
i
)
Cc:
>;
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Discovery questions
Thank you so much for these-very helpful (and sorry I didn't realize the message pad scans also had the same pages
without post-its!)
EFTA00023674

=== Page 3 ===
On these:
Yes, please send over the copy of the gj transcript disc when you can.
Found the original scans from the FL file-thank you!
Yes, please get us the paper evidence from NY, VI, and Reiter as soon as you can.
We'll take the FBI file whenever you can get it to our office.
My understanding from past FBI cases is that CART completes some sort of paperwork documenting the dates on
which they conduct data extractions. We need that for all of the extractions in this case, please (It may not be
302s).
On the evidence from disks, understood. In order to give you more time, we are going to tell the defense
attorneys that the materials are available for them to review in-person if they want to schedule a time to come
down to the FBI office, but that in the meantime we are still working on getting copies of non-nude images to
produce to them.
From:
(NY) (FBI)
Sent: Wednesday, August 19, 2020 2:21 PM
To:
)
is
is
Cc:
is
(USANYS)
Subject: RE: Discovery questions
Hey all, below is a summary of the discovery items you've requested.
Message Pad Scans: The message pads were scanned with the post it notes on them and the very next page is the page
without the post it note, so the pages are back to back.
Papers from Miami case file (grand jury testimony): This is a disk - I can copy it and send it over to you.
Evidence scans: Are you referring to the scans from the FL file? We sent those over with the original message pad scans
last year. If you need that again, let us know and we can get another copy over to you. As far as paper evidence from
the NY and VI searches, and the paper provided by Reiter, we can get that over to you by the end of the week.
FBI file: We have that ready for you.
CART: There are no 302s regarding the extraction of devices.
Evidence from disks: This is a large volume and we've been working on this and removing nude/semi nude images. This
is the only thing that would be difficult to complete by Friday. If we could have a little more time to pull this together,
that would be very helpful.
If it's helpful to talk through some of this via phone, we are happy to do that as well.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
C:
EFTA00023675

=== Page 4 ===
From:
Sent: Tuesday, August 18, 2020 6:41 PM
To:
is
Cc:
(NY) (FBI)
is
is
;
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Discovery questions
Thanks so much,
Really appreciate all the work you and
are putting in on this. Let's touch base tomorrow
to figure out the timeline for the discovery issues.
From:
Sent: Tuesday, August 18, 2020 6:40 PM
To:
)
is
Cc:
(NY) (FBI)
is
>;
(USANYS)
Subject: Re: Discovery questions
Hey guys,
Apologies but today I was out In the field on surveillance and
was also out of the office so we've not
been able to connect on these discovery questions. We will be back in the office tomorrow and will dive into
this as best we can. We have several calls tomorrow, one of which is with Tony Figuero but well do our best to
get on this list. That being said I don't want to make you any promises that everything will be compiled by
tomorrow and that we will have an answer to all of your questions but we can jump on a call tomorrow if you
like to square some of this away.
I did receive your "pages from Miami_case_docs" PDF.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
Sent: Tuesday, August 18, 2020 6:03 PM
To:
is
Cc:
(NY) (FBI)
is
EFTA00023676

=== Page 5 ===
is
(USANYS)
Subject: RE: Discovery questions
Hi
and
Sorry to pester, but would you be able to let us know whether it is realistic to expect that you'll be able to get us these
materials tomorrow or Thursday?
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:41 PM
To:
is
Cc:
(NY) (FBI)
is
>;
(USANYS)
Subject: RE: Discovery questions
Hi
and
The drive you provided us has some scans on it (looks like they're scans of the message pads). As I recall, there was a
larger scanning project, during which the FBI scanned all of the paper that was vouchered in evidence. Are you able to
provide us with all of those scans this week?
With respect to the message pads in particular, I think you mentioned that they were scanned both with post-it notes on
them and also without the post-it notes. The version on this drive just looks like it has the post-it note scans.
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:45 AM
To:
Cc:
(NY) (FBI)
is
>;
i
(USANYS)
Subject: RE: Discovery questions
Sorry, got a bounceback for
too. I'm just attaching the one page I referenced in my email below. Hopefully that
will go through.
From:
Sent: Tuesday, August 18, 2020 4:40 AM
To:
Cc:
(NY) (FBI)
is
>;
i
(USANYS)
Subject: FW: Discovery questions
I got a bounceback from your account for the below email because the attachment was too big. Hopefully it went
through for
so she can see it. If not, please let me know.
EFTA00023677

=== Page 6 ===
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:33 AM
To:
is
(NY) (FBI)
Cc:
is
V.
(USANYS)
Subject: Discovery questions
Hi
and
Thanks so much for your help with the Maxwell discovery so far. I have some follow-up questions about the most recent
batch you provided, and wanted to check in on the longer term tasks we discussed last month.
Below are some questions regarding the discovery
dropped off a few days ago with requests for additional items:
The last page of the attached appears to be a photograph of a disc. The label on the disc seems to suggest it
contains grand jury transcripts. Have you given us those transcripts?
The message pad scans you provided still have post-it notes on top of several of the message pad pages. I think
mentioned that each pad had been scanned twice, but I'm only seeing one copy of each pad-and those
copies all of post-its on them. That's true of nearly every "Notebook" pdf you provided in the "Message pad
scans" folder. Would you please get us a scans of these without post-its on them?
It looks like we're still missing SW returns for the 20 mag 6719 warrant and for the NH premises warrant.
Would you please get us copies of those returns?
Following up on our conversation last month, I think we're still waiting on the below items from you guys. Would you
please be able to get us these this week?
Full FBI sentinel file
CART paperwork regarding the extraction of data from all devices seized during the investigation
All 302s regarding the extraction of data from any seized devices and the review of images (both digital and
hard copy) seized during the investigation, including from Epstein's properties.
Scans of the files Reiter provided to the FBI and provide us with all of those scanned materials
Scans of all hard copy documents, including photos, in the possession of the FBI that have not yet been
scanned, including anything seized during any searches. Please produce to SDNY all of those scans, except any
nude or partially nude images. For nude or partially nude images, please provide us with a log detailing how
many such images were scanned, where they were from, and where they are being stored.
Copies of the contents of all the discs that were seized and searched pursuant to search warrants to a platform
for review. Then please produce to SDNY a copy all of those materials, except any nude or partially nude
images. For nude or partially nude images, please provide us with a log detailing how many such images were
located, where they were from, and where they are being stored.
Please let me know if you have any questions or if it would be useful to hop on a call.
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00023678

=== Page 7 ===
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=== Page 1 ===
From:
"
To:
Cc:
Subject: Priorities 2021
Date: Wed, 02 Jun 2021 18:22:35 +0000
Importance: Normal
Attachments: Priorities_6.2021.docx
Attaching a somewhat rudimentary draft; just let me if you think the proposed cases are appropriate, and any I may've
(very likely) forgotten. Thanks.
Spokesman
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I
Mobile:
I
Press Office:
EFTA00023916


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 11164814 approved by
, now awaiting further
approval
Date: Fri, 01 May 2020 15:44:50 +0000
Importance: Normal
Dear
Travel authorization 11164814 has been approved by
, now awaiting further approval.
Trip ID: 11164814
Traveler name:
Purpose: R20NYS13444 - Epstein Investigation - Witness interview
Destination: Santa Monica, CA, United States
Dates: 2019-12-15 - 2019-12-18
Current status: Pending Authorization Approval
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EFTA00025382


c1: EFTA00024265
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024265.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: Some will question: U.S. District Judge Alison Nathan and Prosecutor's Office
Date: Tue, 15 Dec 2020 15:06:24 +0000
Read if you want.
From: Gregor Hirsch <AliasA1A@hotmail.com>
Sent: Tuesday, December 15, 2020 8:56 AM
To: info@starrandstarr.com; Press@rttv.ru; info@rttv.ru; tips@nypost.com; Todaystories@nbcuni.com;
release@bloomberg.net; evening@cbsnews.com; edu@nytimes.com; weekend@cbsnews.com;
Advertising@univision.net; Supplierdiversity@univision.net; gail.schulman@cbs.com; HaveYourSay
<haveyoursay@bbc.co.uk>; janderson@sun-sentinel.com; Jennifer.geisser@nbcuni.com; letters@washpost.com;
msnbctvinfo@nbcuni.com; Nightly@nbcuni.com; newsalert@bloomberg.net; newmedia@euronews.com;
contact.doc@aljazeera.net; contact.mtp@nbcuni.com; cgtn@cgtn.com;
>;
FOIL@dany.nyc.gov
Subject: Some will question: U.S. District Judge Alison Nathan and Prosecutor's Office
Some will question: How does America judge the degree of underage sex trafficking?
If a wealthy man and/or organization pays for airline tickets, hotel accommodations, and food for underage
teens to which results in the underage girls being paraded on stage in nothing more than what is deemed 'not
much more than lingerie'. eventually resulting in some of the underage girls possibly having sex with anyone
18+ and/or -18... possibly straight sex and/or lesbian sex, surely the wealthy individual and/or organization is
guilty of underage sex trafficking to some degree.
While some will argue such cases are not to the extent of underage sex trafficking such as what unfolded in
the case of Jeffrey Epstein -both Lolita Island and U.S. gatherings, the argument of presentation cannot be
debated, a degree of sex trafficking occurred during what is considered 'Miss Teen USA Contests.'
There is a grooming involved within beauty pageants, is there not? The payment by a wealthy individual
and/or organization offering various teenage girls the 'flamboyant freedom of opportunity for sex behind
pageant doors' is surely 'a hidden secret' which has taken place, has it not?
Had the underage girls not been offered the 'flamboyant freedom of opportunity' through the guise of a
beauty pageant then, cases of -perhaps most likely, lesbian sex between underage girls would not have been
given the time nor, the place for such sex vacations to occur. If such sex vacations occur then, surely it is a form
of sex trafficking being set into place.. into reality by the wealthy individual and/or pageant organization.
While chains, threats, freedom, etc... is perhaps not a form of physical sex trafficking to which often times
associated with sex trafficking, if sex -especially underage sex of any manner at beauty pageant gatherings,
occurs then, this sex trafficking has occurred.
Has anyone ever questioned past teen beauty contestants as to how many of them were sexually involved -
either with those 18+ and/or -18... with either those within and/or around the pageants.. with male or female,
during pageant gatherings?
EFTA00024265

=== Page 2 ===
If indeed any form of sexual involvement occurred then, in fact, sex trafficking occurred under the guise of
'flamboyant freedom of opportunity' presented by the beauty pageant owners. A grooming for the world of
high-dollar prostitution is what many can potentially perceive beauty pageants and modeling shows to be.
NOTE: Obviously, wording of beauty pageants can also be replaced with modeling shows.
https://www.youtube.com/watch?v=MVri5KhzFcM
https://www.youtube.com/watch?v=H8czVPrRkWk
Miss Teen beauty pageants have been places of 'underage grooming.'
https://www.nytimes.com/2020/09/17/nyregion/ghislaine-maxwell-grooming.html
In order to help ensure Ghislaine Maxwell's day in court -not only for her and her lawyers to defend herself
through the legal system, too potentially expose corrupt sex traffickers and, perhaps at this point, to expose the
active participants within the deceased Jeffrey Epstein sex trafficking saga. Those active participants might very
well be high-ranking wealthy politicians and government officials and, socialites typically associated with
Hollywood and the wealthy circles throughout America and, the world.
Ghislaine Maxwell's health and well-being should be extremely important to all women -young and old, in
order to help ensure injustice is not a continuous practice as in the past while justice is upheld even against
those who have thus far been shielded due to political power and/or wealth.
Such is the reason bail should be granted to Ghislaine Maxwell in order to help ensure her appearance before
the Court and, before the Nation does not end prior in such an ill-manner of injustice to which befall upon
Jeffrey Epstein to which many question the government's ruling of death based upon questioning any cover-up
by those in positions of power.
Having an individual alive for justice to be rendered -guilty or innocent within a Court of Law, is a far more
demanding form of Law than having an individual confined behind bars -with a great risk of death for silence,
until their day in court perhaps eventually for the political elite if Ghislaine Maxwell is alive and well while
finally accepting, her voice must be spoken in truth and honesty. including a forthrightness even at this point
in time in order to prevent the freedom of those within political power and wealthy socialite houses to continue
abusing their positions of power based upon wealth against young girls and, young women of all ages.
Again, I petition America and, the Courts of Manhattan to grant Ghislaine Maxwell bail for the security of her
voice. hopefully her forthright voice to be heard in court.
Plenty of stories have been revealed around media and former contestants, Donny Trump had employees
attempting to groom underage girls for him during Miss Teen USA pageants. as have Donny Trump and Billy
Clinton connections with Epstein and Maxwell.
From: Gregor Hirsch <AliasA1A@hotmail.com>
Sent: Tuesday, December 15, 2020 2:14 AM
To: info@starrandstarr.com <info@starrandstarr.com>; Press@rttv.ru <Press@rttv.ru>; info@rttv.ru <info@rttv.ru>;
tips@nypost.com <tips@nypost.com>; Todaystories@nbcuni.com <Todaystories@nbcuni.com>; release@bloomberg.net
EFTA00024266

=== Page 3 ===
<release@bloomberg.net>; evening@cbsnews.com <evening@cbsnews.com>; edu@nytimes.com <edu@nytimes.com>;
weekend@cbsnews.com <weekend@cbsnews.com>; Advertising@univision.net <Advertising@univision.net>;
Supplierdiversity@univision.net <Supplierdiversity@univision.net>; gail.schulman@cbs.com <gail.schulman@cbs.com>;
HaveYourSay <haveyoursay@bbc.co.uk>; janderson@sun-sentinel.com <janderson@sun-sentinel.com>;
Jennifer.geisser@nbcuni.com <Jennifer.geisser@nbcuni.com>; letters@washpost.com <letters@washpost.com>;
msnbctvinfo@nbcuni.com <msnbctvinfo@nbcuni.com>; Nightly@nbcuni.com <Nightly@nbcuni.com>;
newsalert@bloomberg.net <newsalert@bloomberg.net>; newmedia@euronews.com <newmedia@euronews.com>;
contact.doc@aljazeera.net <contact.doc@aljazeera.net>; contact.mtp@nbcuni.com <contact.mtp@nbcuni.com>;
cgtn@cgtn.com <cgtn@cgtn.com>; Wendy.Olsen@usdoj.gov <Wendy.Olsen@usdoj.gov>; FOIL@dany.nyc.gov
<FOIL@dany.nyc.gov>
Subject: For the Prosecutor's Office and/or US District Judge Alison Nathan,
For the Prosecutor's Office and/or US District Judge Alison Nathan to deny Bail Request, denial could
potentially place the weight of injustice upon all women -both young and old, if Ghislaine Maxwell becomes
another Jeffrey Epstein jail statistic based upon any possibility of any high-ranking politicians/government
officials around the world and wealthy socialites seeking her silence.
I encourage both the Prosecutor's Office and the Court to grant Ghislaine Maxwell Bail -based upon
stipulations I have noted within previous email [included below], in order for Ghislaine Maxwell to be given the
opportunity to take the stand -not only in defense of the charges filed against Ms. Maxwell, also those whom
were 'protected' by the death of Jeffrey Epstein.
Jails simply do not provide healthy environments for those Innocent Until Proven Guilty in a Court of Law..
especially a Court Case of such magnitude which stands possibly for any and all youth deemed 'underage' by
U.S. Law.
Any possibly Flight Risk can be avoided based upon Bail Agreement.
Requesting Bail be granted for the health & well-being of Ghislaine Maxwell in order for Court to be upheld in
Truth and Justice.
Greg Hirsch
From: Gregor Hirsch
Sent: Tuesday, December 15, 2020 1:50 AM
To: info@starrandstarr.com <info@starrandstarr.com>; Press@rttv.ru <Press@rttv.ru>; info@rttv.ru <info@rttv.ru>;
tips@nypost.com <tips@nypost.com>; Todaystories@nbcuni.com <Todaystories@nbcuni.com>; release@bloomberg.net
<release@bloomberg.net>; evening@cbsnews.com <evening@cbsnews.com>; edu@nytimes.com <edu@nytimes.com>;
weekend@cbsnews.com <weekend@cbsnews.com>; Advertising@univision.net <Advertising@univision.net>;
Supplierdiversity@univision.net <Supplierdiversity@univision.net>; gail.schulman@cbs.com <gail.schulman@cbs.com>;
HaveYourSay <haveyoursay@bbc.co.uk>; janderson@sun-sentinel.com <janderson@sun-sentinel.com>;
Jennifer.geisser@nbcuni.com <Jennifer.geisser@nbcuni.com>; letters@washpost.com <letters@washpost.com>;
msnbctvinfo@nbcuni.com <msnbctvinfo@nbcuni.com>; Nightly@nbcuni.com <Nightly@nbcuni.com>;
newsalert@bloomberg.net <newsalert@bloomberg.net>; newmedia@euronews.com <newmedia@euronews.com>;
contact.doc@aljazeera.net <contact.doc@aljazeera.net>; contact.mtp@nbcuni.com <contact.mtp@nbcuni.com>;
cgtn@cgtn.com <cgtn@cgtn.com>; Wendy.Olsen@usdoj.gov <Wendy.Olsen@usdoj.gov>; FOIL@dany.nyc.gov
<FOIL@dany.nyc.gov>
Subject: FORWARD ASAP... ATTN: US District Judge Alison Nathan
US District Judge Alison Nathan,
I recommend the US District Court in Manhattan accept Ghislaine Maxwell's bail application offering
of $28.5 million... with the following stipulations:
EFTA00024267

=== Page 4 ===
<24 Full-time Security Guards on premises*** [i.e. 12 guards rotating shifts every 8 hours] RV Camper
residences on premises.
<Each Security Guard is paid directly by Ghislaine Maxwell Escrow $20,000 monthly salary per
Security Guard
NOTE: Escrow prepaid 6-months in full [i.e. $480,000/month (x) pre-paid every 6-months =
$2,880,000]
NOTE: Escrow pre-paid prior to release on bail.
NOTE: After six months, if additional 6-month Escrow is failed to be pre-paid, bail immediately
revoked.
NOTE: If Court determines 36 Security Guards, Escrow amount increases -as does number of RV
campers on premises by six.
<First 3-months, Hourly Skype Chat w/Court Employee of Judge's decision within 10 minutes prior to
or, following-top-of the-hour
NOTE: Offer a pre-agreed 7-hour sleep exclusion Hourly Skype Chat timeframe
<Ankle Monitor 24/7/365 or, duration of Bail Term until completion of Case
NOTE: This effort helps ensure Ghislaine Maxwell's safety based upon possible Lolita Island ties to
high-ranking Officials anyone connected with Jeffrey Epstein.
NOTE: Also saves tax dollars in comparison to jail confinement costs [i.e. 10% Forfeiture of Bail
Amount upon Court Case Ruling]
NOTE: Based upon old-school "Innocent until Proven Guilty in a Court of Law."
For Bail Acceptance, based upon me -Greg Hirsch, being without work and, being unable to find any
companies interested in my CAEF endeavors, I ask to be employed as one of the Security Guards.
***If property still owned or, similar property, Ghislaine Maxwell pays for twelve RV campers
strategically situated around property within 10' chain link fence around premises location at [as shown
on Google Maps]:
27 E Washington Road
Bradford, New Hampshire
NOTE: RV campers and 10' chain link fence paid in full and, set in place and, fence erected prior to
prisoner/accused released on bail.
https://www.google.com/maps/place/Ghislaine+Maxwell+Hideout/@43.2344341.-72.0028601.3a,75y8
1.66h,83.62t/data=!3m7!1e113m5!1scBCnMKmOUD66fQAJYacoPgl2e0!6s%2F%2Fgeo0.ggpht.com%
2Fcbk%3Fpanoid%3DcBCnMKmOUD66fQAJYacoPg%26output%3Dthumbnail%26cb_client%3Dsear
ch.gws-
prod.gps%26thumb%3D2%26w%3D86%26h%3D86%26yaw%3D7231005%26pitch9%3D0%26thumbf
ov%3D1007i3328!8i1664!4m5l3m4!1s0x89e18b0fa7599abd:0xb9aba56445d47831l8m2l3d43.23467
91!4d-72.0018127
https://www.rt.com/usa/509672-maxwell-bail-prison-conditions/
https://www.justice.gov/usao-sdny/united-states-v-ghislaine-maxwell
EFTA00024268

=== Page 5 ===
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=== Page 1 ===
From:
To: "Tomback, Andrew"
"Weinstein, Marc A."
<m
Cc:
Subject: RE:
follow-up question
Date: Tue, 19 May 2020 18:36:29 +0000
Inline-Images: image001.png
Thanks and understood re: both.
From: Tomback, Andrew
Sent: Tuesday, May 19, 2020 08:28
To:
>; Weinstein, Marc A.
Cc:
Tomback, Andrew
^
Subject: RE:
follow-up question
Marc and/or I will respond to your email below soon - ideally later today.
Regarding my open issue, the Estate won't list any property before June 15.
Stay safe.
Andy
Andrew E. Tomback I Partner
T
E
White & Case LLP I 1221 Avenue of the Americas I New York, NY 10020-1095
WHITE&CASE
From
Sent: Monday, May 18, 2020 4:17 PM
To: Tomback, Andrew
>; Weinstein, Marc A.
Cc:
Subject: RE:
follow-up question
Mark, Andy,
One question I had meant to ask in our call but forgot, on a separate subject - we had briefly discussed in late February
our request for photographs and videos in the possession of the estate, and my recollection is that with respect to videos,
the estate and trustees were not aware of being in possession of any historical surveillance-type videos (and in particular
that any such surveillance video is regularly over-written, and so would not currently exist for any time before, for
example, Epstein's suicide), and that separately the estate and trustees were not aware of being in possession of other
physical video recordings.
My recollection is that with respect to photographs, that there were some photographs in the properties that had not
been the subject of physical search warrants, i.e., the Florida and New Mexico residences. I think we had discussed that
EFTA00026530

=== Page 2 ===
the most efficient step, in the first instance, would be for us to receive digital photos of those physical photographs, to
whatever extent they exist, but that doing so was not immediately possible at the time of our conversation in late
February due to the estate's then-inability to retain or engage anyone to do that.
In the first instance, please let me know if I am getting any of that wrong, and second, understanding that the
circumstances of the pandemic may have affected this in the interim, we've been asked to again check with you about
whether there is anyone currently working at (or reasonably able to go to) those properties who could convey
photographs of any physical photos at those locations? If you could please let us know any sense of possibility / timing on
that last outstanding request.
thanks,
Assistant U.S. Attorney
Southern District of New York
This email communication is confidential and is intended only for the individual(s) or entity named above and
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EFTA00026531


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=== Page 1 ===
From:
To:
Subject: Travel Authorization 11164814 has received final approval
Date: Fri, 01 May 2020 15:48:25 +0000
Importance: Normal
Dear
Travel authorization 11164814 has received final approval.
Trip ID: 11164814
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R20NYS13444 - Epstein Investigation - Witness interview
Destination: Santa Monica, CA, United States
Dates: 2019-12-15 - 2019-12-18
Current status: Authorization Approved
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
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EFTA00025353


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=== Page 1 ===
From:
To:
Cc:
)"
Subject: Re: travel approval request
Date: Fri, 24 May 2019 19:54:51 +0000
Importance: Normal
All approved.
Sent from my iPad
On May 24, 2019, at 2:57 PM,
wrote:
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
EFTA00024172

=== Page 2 ===
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week
for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night
and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00024173


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: Sentencing with Berman
Date: Wed, 06 May 2020 23:51:30 +0000
Right like presumably the defense attorney in that random case wasn't the one who called the Daily News to get them
quotes
Let me know if he does do anything fun tomorrow! And good luck to
!!
From:
(USANYS)
Sent: Wednesday, May 06, 2020 19:50
To:
Subject: Re: Sentencing with Berman
Almost as though he's putting on a show for the press.
has something with him tomorrow morning and we're worried he'll do something crazy.
Sent from my iPhone
On May 6, 2020, at 7:45 PM,
wrote:
https://www.nydailynews.com/new-york/ny-judge-berman-epstein-barr-bop-20200506-a6p4hvl3tncpndjbz2pda2hsde-
story.html
From:
(USANYS)
Sent: Tuesday, May 05, 2020 12:34
To:
Subject: RE: Sentencing with Berman
Omg. Amazing. He just can't help himself.
From:
)
Sent: Tuesday, May 05, 2020 12:33 PM
To:
(USANYS)
Subject: FW: Sentencing with Berman
From:
Sent: Tuesday, May 05, 2020 12:32
To:
is
Subject: Fwd: Sentencing with Berman
EFTA00025499

=== Page 2 ===
Sent from my iPhone
Begin forwarded message:
From:
(USANYS)"
Date: May 5, 2020 at 12:26:14 PM EDT
To:
)"
Subject: Sentencing with Berman
Sua sponte talking right now about how he thinks Barr hasn't done a satisfactory investigation about Epstein's death
and BOP generally in the wake of his death.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York, New York 10007
EFTA00025500


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=== Page 1 ===
Haddon, Morgan and Foreman, P.C.
Jeffrey Pagliuca
HADDON
MORGAN
150 East 10th Avenue
FOREMAN
Denver, Colorado 80203
PH
www.hmflaw.com
August 24, 2020
VIA EMAIL
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: Proposed Redactions to Request to Modify Protective Order (Under Seal)
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
In accordance with this Court's Order of August 18, 2020 (Doc. 44), Ms. Maxwell hereby
respectfully submits under seal her proposed redactions to her Request to Modify Protective
Order ("Request"), filed under seal on August 17, 2020. Ms. Maxwell also has filed her Reply
under seal and contemporaneously submits her proposed redactions to that pleading.¹
Ms. Maxwell has no opposition to keeping under seal, and redacting from her Request and
Reply, the contents, description and discussion of the sealed materials themselves; because the
government has marked them Confidential, the Protective Order requires as much. See Doc. 36,
I 15.
The government's proposed redactions, however, go further and propose to redact significant
procedural background, all of which is publicly available information. The government would
have this Court redact the "specific civil suit from which the government obtained materials
the
V. Maxwell litigation" on the premise that it would "risk jeopardizing the
government's investigation."
Ms. Maxwell has already publicly and repeatedly pointed out in the
case, and to the
Second Circuit, that which was obvious from the outset of this criminal case -- that her sealed
deposition was somehow obtained by the government and included verbatim in the Indictment
and Superseding Indictment. Ms. Maxwell has told those courts as she must, given the rapidly
I
To the extent this Court believes this letter also should be filed publicly, counsel also has indicated her proposed
redactions to this letter.
EFTA00023662

=== Page 2 ===
The Honorable Alison J. Nathan
August 24, 2020
Page 2
unfolding unsealing process and emergency stay, that she is seeking leave from this Court to
modify the protective order and reveal information under seal to those two courts.
Moreover, the government has made repeated, highly public statements, including at the press
conference following Ms. Maxwell's indictment,² in the press conference following Mr.
Epstein's indictment, in a press conference convened at the doorstep of Mr. Epstein's former
New York mansion,4 and in other publicly-released statements that its investigation into
associates of Mr. Epstein is ongoing and active.
Fundamentally, the sealed materials are judicial documents. The pleadings and orders do not
contain any alleged victim names or identifying information. There is no reference in the sealed
materials to any confidential informant, wiretap, or other actual ongoing investigative process
that might be compromised by disclosure of the materials The process to evaluate whether a
judicial document should remain under seal is clear. Once a determination is made that the
materials are judicial documents the Court is required to determine whether any countervailing
interests outweigh the presumptive right to public access.
V. Maxwell, 929 F.3d 41, 49-50
(2d Cir. 2019).
Frankly, Ms. Maxwell does not believe that the government has established a countervailing
interest compelling enough to justify continued sealing of the documents. As a threshold
consideration the only reason that the documents are sealed is because the government
circumvented the process established in Martindell. It is also likely that these same documents
will be the subject of future motion practice in this Court, making the material, for the third time,
judicial documents.
However, Ms. Maxwell has no interest in additional pretrial publicity related to any of these
documents and submits that protecting her right to a fair trial is the countervailing interest that,
at this point, requires her proposed redactions and the continued sealing of the materials with the
exception of her limited request to file the materials under seal with the Second Circuit Court of
Appeals and Judge Preska.
2 "These charges to be announced today, are the latest result of our investigation into Epstein, and the people
around him who facilitated his abuse of minor victims. That investigation remains ongoing."
(https://www.rev.com/blog/transcripts/announcement-transcript-of-charges-against-ghislaine-maxwell-in-new-york-
jeffrey-epstein-associate-arested).
3 "This in no way is over, OK. There's going to be more investigative steps they're going to take place and the FBI
with the U.S. attorney here is going to continue to investigate."
http://transcripts.cnn.com/TRANSCRIPTS/1907/08/ath.01.html).
4 Sarah Nathan and Kate Sheey, "Prince Andrew refuses to cooperate with feds in Jeffrey Epstein probe," NY Post
(Jan. 27, 2020) https://mypost.com/2020/01/27/prince-andrew-refuses-to-cooperate-with-feds-in-jefrey-epstein-
probe/).
5 Alan Feuer, "Prince Andrew and U.S> Prosecutor in Nasty Dispute Over Epstein Case," NY Times (June 8, 2020)
(https://www.nytimes.com/2020/06/08/nyregion/jeffrey-epstein-prince-andrew.html).
EFTA00023663

=== Page 3 ===
The Honorable Alison J. Nathan
August 24, 2020
Page 3
Respectfully Submitted,
Jeffrey S. Pagliuca
CC: Counsel of Record (via Email)
EFTA00023664


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein Image/Video File Review Protocol
Date: Mon, 19 Oct 2020 20:22:58 +0000
Thanks,
We will send the protocol to the other paras who will be helping with this and let them know to expect
a conference call once the copies start getting completed.
From:
Sent: Monday, October 19, 2020 4:08 PM
To:
is
is
is
is
Cc:
is
(
)
^
Subject: Epstein Image/Video File Review Protocol
All,
Attached please find the review protocol for the image and video files from Epstein's devices. The protocol asks that all
reviewers read the warrant and supporting affidavit, which are both attached here as well. I am also attaching a copy of
the Maxwell indictment, which contains a photograph of Epstein and Maxwell.
Once the USAO and FBI review teams are assembled, please let me know when would be a good time for me to have a
call with them to talk through the review and answer any questions.
In the first instance, we would ask that the FBI team review the following devices:
NYC024363
NYC024394
NYC024326
NYC024368
NYC024390
NYC024334
NYC027910
NYC024323
NYC024355
NYC027908
Depending on how quickly the FBI and USAO teams move through the review, we may reassign some devices between the
teams.
Thanks very much,
EFTA00024731

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00024732


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=== Page 1 ===
[Type text]
A. Public Corruption Unit
The Public Corruption Unit, consisting of about 20 AUSAs, including two supervisors, had
a busy year focusing on both traditional corruption offenses and other abuses of power by-both
local and national in scope. The Unit charged numerous law enforcement and correctional officers
in the New York City area with various abuses of power, including an excessive force prosecution
involving a mentally disturbed homeless victim, and multiple federal correctional officers,
including one who has since pled guilty to sexually assaulting numerous female inmates under his
watch. The Unit also brought charges of national significance, including campaign finance and
related charges against Lev Parnas and Igor Fruman, among others; extortion and fraud charges
against attorney Michael Avenatti, and sex trafficking charges against former financier Jeffrey
Epstein.
At the local level, the Unit successfully prosecuted both local and federal officials,
including a former NYPD Detective who used his position to facilitate a scheme to steal tens of
thousands of dollars from dozens of New York victims. U.S. V. Bonanno, 18 Cr. 427 (PGG).
Another police officer, Robert Espinel, became the final defendant to plead guilty in the unit's
multi-case prosecution of officials at the NYPD's gun licensing division for accepting bribes to
approve and expedite gun licenses. U.S. V. Robert Espinel, 17 Cr. 398 (ER). The Unit also brought
charges against a sitting Brooklyn Supreme Court Justice for obstructing a federal investigation
into fraud and corruption at the Municipal Credit Unit ("MCU") whose board she chaired. U.S. V.
Ash, 19 Cr. 780 (LAK). Finally, the Unit brought charges against three federal correctional officers
at the MCC, one for abusing his position to sexually assault numerous female inmates under his
watch over a multi-year period, U.S. V. Akparanta, 19 Cr. 363 (LGS), and two for falsifying records
intended to conceal their failure to conduct routine rounds and checks on the night Jeffrey Epstein,
then an inmate at the MCC, committed suicide. U.S. V. Noel et al., 19 Cr. 830 (AT).
At the national level, the unit brought campaign finance and related charges against four
defendants, including Lev Parnas and Igor Fruman, based on their participation in a scheme to
funnel money to political candidates and committees in the hope of gaining access and influence,
including with respect to their efforts to cause the removal of the then-U.S. Ambassador to
Ukraine. U.S. V. Parnas, 19 Cr. 725 (JPO). The unit also charged Stephen Calk, the CEO and
Chairman of the Federal Savings Bank in Chicago, with bank bribery in connection with financing
he provided to Paul Manafort with the intent of securing a position within the Trump
administration. U.S. V. Calk, 19 Cr. 366 (LGS). The unit also successfully prosecuted the operator
of a fraudulent political action committee ("PAC") for defrauding tens of thousands of victims into
making what they believed to be political or cause-specific contributions under false pretenses,
obtaining over $1.5 million in restitution and forfeiture for victims at sentencing. U.S. V. Tierney,
18 Cr. 804 (JMF). In addition, the unit charged a second individual with
wire fraud in connection with his efforts to steal money from individuals who thought they were
donating to prominent political figures such as Bernie Sanders and Beto O'Rourke. U.S. V.
DuPont, 19 Cr. 791 (ER). Finally, the unit charged and secured a guilty plea from Natalie
Mayflower Sours Edwards, a previous high level official at the Financial Crimes Enforcement
Network of the Treasury Department, with the unauthorized leaking of suspicious activity reports.
U.S. V. Edwards, 19 Cr. 64 (GWR).
EFTA00025171

=== Page 2 ===
State of the Office 2018
Page 2
The Unit's work in 2019 extended beyond the traditional realm of public officials. In early
2019, the Unit brought novel extortion charges against attorney Michael Avenatti for attempting
to extort tens of millions of dollars from the athletic apparel company, Nike. U.S. V. Avenatti, 19
Cr. 373 (PGG). Avenatti was also charged in a separate scheme to defraud his former client
Stephanie Clifford a/k/a "Stormy Daniels," who had been the recipient of hush money payments
in connection with the unit's earlier prosecution of Michael Cohen U.S. V. Avenatti, 19 Cr. 374
(JMF). In July 2019, the unit brought sex trafficking charges against the former financier Jeffrey
Epstein who over a multi-year period abused dozens of minor victims in New York, Florida and
other locations. U.S. V. Epstein, 19 Cr. 490 (RMB). While Epstein committed suicide while
awaiting trial, at a unique hearing held in connection with the entry of an order of nolle prosequi,
dozens of Epstein's victims were afforded an opportunity to address the Court and publicly
confront their abuser. Finally, in 2019, the Unit successfully completed its prosecution of three
cases stemming from corruption in the world of college basketball, including trying to verdict
bribery charges against two defendants for making cash payments to university coaches. U.S. V.
Evans, 17 Cr. 684 (ER), U.S. V. Person, 17 Cr. 683 (LAP).
EFTA00025172


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein search warrant documents
Date: Mon, 06 Jul 2020 15:43:35 +0000
Yeah, that doesn't sound right. CART did this once last winter, but screwed it up, and we couldn't use it in the format they
made for us - the FBI can, so it is possible what she is hearing is that her team has access to some number of these
devices. But we have nothing. And I have personally been on calls with the SSA and the CART folks since early April
about fixing this problem, and they always promise to do so quickly, and tomorrow and tomorrow and tomorrow
From:
(USANYS)
Sent: Monday, July 6, 2020 11:26 AM
To:
(USANYS)
Subject: RE: Epstein search warrant documents
As expected, FBI is pretty resistant to using a vendor. I explained to
that we just can't mess around with this
anymore. She is going to get updated information about status and we will talk again later today (her team told her that
we have been provided with roughly 30 of 52 devices, so obviously our information is not matching up).
From:
(USANYS)
Sent: Monday, July 6, 2020 8:49 AM
To:
(USANYS)
Subject: RE: Epstein search warrant documents
Pretty sure it's everything. The estimate references 57 devices, as noted below, I think we're now up to 62, but we're into
one of them, so really 61. We can get an updated estimate for the 61 if that would be helpful, but given how much
business the PC unit gives
he should be good to us on that
From:
(USANYS)
Sent: Monday, July 6, 2020 8:44 AM
To:
(USANYS)
Subject: RE: Epstein search warrant documents
What is the estimate for? All of these? Just UVI?
From:
(USANYS)
Sent: Friday, July 3, 2020 2:50 PM
To:
(USANYS)
Subject: RE: Epstein search warrant documents
Yes, there are a total of 62 devices which can be divided into three main buckets based on how/where we obtained them,
the second and third of which are by far and away the biggest:
1 Phone and 1 iPad seized from Epstein at the time of his arrest on July 6, 2019. The FBI first delivered copies of
the extractions from these devices last week. We were able to review the iPad, but we have not been able to
open the iPhone data. IS THIS AN FBI TRANSMISSION ISSUE WITH THE IPHONE DATA, OR IS IT THAT IT WAS UN-
OPENABLE?
33 electronic devices seized from the New York residence on July 11, 2019. These include multiple hard drives,
multiple computers, multiple USB drives, and multiple iPads. We currently have extractions from/access to none
of them.
EFTA00026405

=== Page 2 ===
27 electronic devices seized from the Virgin Islands residence on August 12, 2019. These include multiple
computers, multiple iPads, and multiple USB drives. We currently have extractions from/access to none of them.
From:
(USANYS)
Sent: Friday, July 3, 2020 1:51 PM
To:
(USANYS)
Subject: Re: Epstein search warrant documents
Can you have the team summarize status of different buckets of devices for me? I'll push this to resolution,
possibly through vendor.
On Jul 2, 2020, at 7:13 PM,
(USANYS)
wrote:
Let's discuss. I just don't have a lot of confidence that is going to get this done.
Sent from my iPhone
On Jul 2, 2020, at 6:35 PM,
(USANYS)
wrote:
Ok. Audrey is also prepared to call
about pushing this issue if need be.
On Jul 2, 2020, at 6:32 PM,
(USANYS)
wrote:
On this issue of the Epstein devices, the team got an estimate from BRG that seems reasonable in terms of both cost
and time line. At this point, I would be inclined to do this, but let's find some time to chat more about it tomorrow if
you're around or early next week if that's better. Thanks
From:
)
Sent: Thursday, July 2, 2020 5:11 PM
To:
(USANYS)
Cc:
(USANYS)
i
Subject: RE: Epstein search warrant documents
Following up on the below, I think we've given this our absolute best efforts with FBI - they are now well over a
month later than their estimate from April on when we would get the New York materials, they're also past their
estimate of getting us the New York materials from just this Monday, and we don't have anything close to an
estimate on the USVI materials, which constitute the overwhelming majority of the data and are vastly more
voluminous than the New York devices. We have kept pushing the timeline back for this option, hoping that CART
will finalize, but I think at this point we should have a vendor do it.
Attached is an estimate we got from BRG, which would get everything to us in under a month, and in Relativity-
friendly format, in a range of $85-135K. BRG has done this for our office multiple times in the past and are very
effective and efficient, and they get the materials we need. And most importantly, they estimate they can do it all in
less than a month. May we have approval to seek funding for this? The estimate is attached. Thanks very much.
EFTA00026406

=== Page 3 ===
From:
)
Sent: Tuesday, June 30, 2020 16:23
To:
(NY) (FBI)'
is
(USANYS) [Contractor]
Cc:
(USANYS)
in
(NY) (FBI)
is
is
is
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
From:
Sent: Monday, June 29, 2020 13:00
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS)
i
(NY) (FBI)
V.
is
is
(NY)
(FBI)
>;
(USANYS)
Subject: RE: Epstein search warrant documents
Okay thanks - good luck with the cardiologist! And if you can let us know tomorrow that would be great. Thanks
again.
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:59
To:
(USANYS) [Contractor]
is
)
Cc:
(USANYS)
is
(NY) (FBI)
is
>;
i
(NY)
(FBI)
y.
(USANYS)
Subject: RE: Epstein search warrant documents
When I'm in the office tomorrow, I will be better able to estimate. I'm at my cardiologist right now.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:56 PM,
)"
wrote:
Great, thanks. Is there even a rough estimate of when we will get the USVI materials? Or an estimate of when you'll
be able to see how many items to export, so we'll have a better sense of when we'll get those?
EFTA00026407

=== Page 4 ===
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:55
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
>;
(NY) (FBI)
is
is
i
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Yep
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:52 PM,
)"
wrote:
Okay, and I'm sorry to ask again, but to make sure, in this production, you're sending us new versions of what you
previously sent?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:50
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
is
(NY) (FBI)
is
is
is
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
You are getting both NY and USVI. The biggest stumbling block are the newer Mac items that are in APFS
(there are a bunch from the Island,) so it is difficult to estimate how long those will take until I see how
many items I have to export.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:40 PM,
)"
wrote:
Okay thanks, and just to clarify, a few days to finalize the New York materials, and then what about the USVI
materials? I think that is quite a bit more. Just looking for an estimated completion date for everything.
And on my other question - does this mean you're giving us a new, complete copy of everything from both NY and
USVI?
thanks,
EFTA00026408

=== Page 5 ===
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:34
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
i
(NY) (FBI)
is
is
i
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
I am in the process of exporting the materials (documents, spreadsheets, emails, etc) for your review as per
my discussions with
Most of the NY stuff is done, just Mac items left. This might take a few days as
1 item in particular has over 500,000 emails. We will be able to provide discovery once Defense Council
has provided drives for us to copy items over to. This goes quicker as there is no processing involved. I'll let
you know when everything is complete.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 11:03 AM,
)"
wrote:
Following up on this, I understand from
that she was able to provide you with a 12 TB drive last week - could
you please let us know when we will be able to get the materials? I expect a judge will ask us about discovery as
early as this week.
Also, the related critical question that I don't think we have clarity on is whether you're giving us a copy of everything
that was collected (including reproducing the materials that you previously gave us, but which are not searchable), or
have you and
figured out a way to categorize the prior productions so they're useful for us? We would strongly
prefer to just get everything at once in a usable format, but please let us know if you expect to produce materials
differently than that.
thanks,
From:
(NY) (FBI)
Sent: Friday, June 19, 2020 13:14
To:
(USANYS) [Contractor]
in
Cc:
(USANYS)
is
(NY) (FBI)
is
is
is
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
,
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK
when I can expect the drives. Thanks.
NY CART Coordinator
EFTA00026409

=== Page 6 ===
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
)
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(NY) (FBI)
is
)
is
>;
(NY) (FBI)
is
(USANYS)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July
and September searches before moving forward with possible additional charges in the case. I know you had
mentioned you needed to push back your prior estimate of complete production by early June, by a couple weeks, so
wanted to see what the current estimate is? I don't think we've started to get anything yet but please correct me if
I'm wrong.
thanks,
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
)
in
>;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go
from there.
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
EFTA00026410

=== Page 7 ===
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
)
is
)
>;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If
we can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our
staffing levels will be steadily increasing over the next few weeks, but I'm going to have to push back my
estimate by a week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can
easily identify what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
Thanks for this update - we'll take a look and circle back if any questions.
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in
searchable format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to
specific devices - so if we're able to match them up by Bates number now, that might work, but otherwise I think it
makes sense for us to get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think
we've gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial
numbers. Any questions, let me know.
FBI NY CART Coordinator
EFTA00026411

=== Page 8 ===
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
>;
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of
information we need is the serial number, or some other specific identifier, ideally for each device but at least for any
device that there is more than one of the same thing. So for example, we need to be able to somehow differentiate
the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the
USVI spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the
USVI list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to
reproduce all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we
aren't able to match any of the prior productions to specific devices - so if we're able to match them up by Bates
number now, that might work, but otherwise I think it makes sense for us to get everything. But let us know if any
issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
)
is
(USANYS) [Contractor]
Cc:
is
V.
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
EFTA00026412

=== Page 9 ===
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I
could to convey the information. If you are confused by anything, please let me know. In the column for
approximate size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column,
I put what load file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight)
If there is no entry in that column, that data has yet to be transferred. There are 2 Macs and a DVR you
don't have as well as an iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what
I can to beef them up. I will get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a
format such that we can view them using a system we have access to. We're not able to get web-enabled access
through any FBI tool, so we asked for the materials to be transferred in a loadable format so we could put them on
Relativity, which both we and the agents can access. We're required to have the files in a format that we can
produce them to defense counsel. I've done that in many other cases and it hasn't previously been an issue. My
understanding from
is that the best way to do it now is just for us (the U.S. Attorney's Office) to get the original
files, which our vendor will process-by which I just mean converting into file formats that are loadable onto
Relativity. It doesn't really have anything to do with the taint review-we have to have access to the docs in our
systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents
earlier this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9.
Again, I understand from
that the best way forward is to just get copies of the materials in their original
formats, which I understand will be segregated and designated by device. That should work for us! I was just trying
to understand the approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
is
(USANYS) [Contractor]
Cc:
is
is
EFTA00026413

=== Page 10 ===
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking
files that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity)
to do a taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you
insisted you do the taint review in Relativity, I warned you that it was adding months worth of work on top
of what was already done, and that Relativity was incapable of viewing everything. You insisted we do it
this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get
it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it
piece by piece as things are processed, I was unaware that you didn't want to review as things were
processed, that you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a
differentiation of methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a
while back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
)
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just
basically sending us copies of everything? I don't totally understand why we couldn't have done that eight months
ago, but regardless of the passage of time, I want to make sure we understand so we can report to our supervisors.
I
assume that means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the
processing ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
is
)
Cc:
is
)
Subject: RE: Epstein search warrant documents
EFTA00026414

=== Page 11 ===
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it
to a particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
>;
Cc:
is
)
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so
we make sure we get all the info we need. I think you had previously sent us a list of certain information that
unfortunately wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload
it on our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already
been processed. I think what we talked about on the phone a month ago was getting, for example, data from one
device to make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
EFTA00026415

=== Page 12 ===
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data
and where the data was collected. I will work to send some hard drives to
so he can begin to copy the data
and send it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
in
(USANYS)
i
(NY) (FBI)
>;
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to
review the returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
V.
)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave
you. If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for
complete transmission of the search warrant returns is no longer likely? If so could you please let us know what the
current estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
i
)
>;
EFTA00026416

=== Page 13 ===
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
-
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I
will be back in the office on Thursday and will be able to get you the list then as I have to access some of
our systems to do so.
Also,
,
please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're
waiting on that list to be able to do an updated search warrant on all of those devices. Please let us know the
current timeline - and also the current timeline on producing the results from those August and September
searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it
a couple months from our call, which would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
) [mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
is
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
i
is
EFTA00026417

=== Page 14 ===
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us
know, otherwise I'd propose we do:
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
>;
(NY) (FBI)
is
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago,
but are you at all able to assist while working remotely? This has been pending for almost two months and we still
don't have a very basic list of each device or item that was seized and searched, or for which of those we've received
materials. We're happy to have a call if that would be useful, but as a first step the most basic thing we're looking for
is the info in the template spreadsheet we sent earlier (that's also attached).
thanks,
From:
)
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
EFTA00026418

=== Page 15 ===
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24?
The excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we
sent on 2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you
mean by "loose media" without a specific comparison to what was seized, we don't know which items you're
referring to as "Windows machines," and we can't tell whether the entirety of any particular item has been
transferred, or just partial. For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
The data we've received has no way to put any emails and attachments together. So if an email says, "see
the attached flight records," for example, we have no way of linking that up with the records themselves.
Not only is that a big problem for us in review, it's going to be a huge problem for producing the documents
to defense counsel.
-
The load file has no link to the native file, so when we load the data to the database, there's no way to have
the native files show up in the database. Because many of the files are too large to open in the viewer, it
effectively means that there are many files that are completely invisible to us.
-
Related, the control numbers in the load file don't match up to the native files. So we have two sets of
numbers and no way to match up anything-that is, even if we were to try to go hunt down every individual
large file in the native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need
to get a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more
than a million documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary
record-keeping, and we need that info at the very least, as well as anything else you think would be useful. Also
attaching the SW returns for reference. And again, we're happy to meet up anytime and hash all this out in person if
that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some
points of clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3
copies of 3 drives (9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were
all copies). All the loose media from the NY apartment is included. All the Windows machines from the NY apartment
are included. Only 2 Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the
tool they have to be processed with does not easily re-name the load files.
EFTA00026419

=== Page 16 ===
Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From:
) [mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
i
>;
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so
we can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
i
)
is
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
i
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
)
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
EFTA00026420

=== Page 17 ===
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together
to have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next
week? And what I think would be most helpful to facilitate that would be a spreadsheet of each separate device
referenced in the two search warrant returns, with columns for whether we've dumped the contents, whether
they've been reviewed and/or transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the
attached is mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed,
transferred, and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I
think FBI was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get
those to be able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
i
>;
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they
mandated we delete old stuff (about 400 TB worth). Now that they are working on replacing the network,
we can do only local work. I should be able to give you an accounting of what is what. I can say, off the top
of my head, that all windows based items from the NY search have been handed over as well as all loose
media. The CDs from NY only contained pictures, no documents. There are still some Apple items from NY
that need to be produced. As far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac
has been produced. Still working on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e.,
EFTA00026421

=== Page 18 ===
which devices the materials came from, whether it's full or partial results, how many more devices we have coming,
etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are
approximately 40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even
counting at least 60+ CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices,
including multiple servers / server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of
moving pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming
week from Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be
plenty of time to schedule a productive meeting.
thanks all,
From:
)
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
in
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have
the hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also
old materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's
new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of
what we're getting, and what has been completed, without some kind of identification or labeling system, along with
a list of which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a
modified date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we
haven't gotten any info on which folders match up to which devices, etc. And then there's another folder titled
"NYC024362" that has a modified date of 1/27/20, so I think that may be the materials we hadn't previously
received? That folder by itself has more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the
folder or file names whether everything on the drive is new, or whether just additional materials were saved onto it
in addition to what we already have.
are you able to give us some guidance on this? Ultimately what we
really need is a spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying
that same info - which device, and what materials from it - are being given to us with each data transfer. Otherwise
I think organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
EFTA00026422

=== Page 19 ===
Southern District of New York
<mime-attachment>
EFTA00026423


c1: EFTA00025962
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025962.pdf
c6: pdf
c7: images
c0:
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c1: EFTA00024350
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024350.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: Re: WSJ News Alert: Jeffrey Epstein Found Dead in Jail, Officials Say
Date: Sat, 10 Aug 2019 14:16:21 +0000
Thanks
On Aug 10, 2019, at 10:05 AM,
(USANYS)
wrote:
In case you didnt see it -
Sent from my iPhone
Begin forwarded message:
From: "The Wall Street Journal."
Date: August 10, 2019 at 9:40:12 AM EDT
To:
Subject: WSJ News Alert: Jeffrey Epstein Found Dead in Jail, Officials Say
Reply-To:
Trouble viewing this email? View in web browser )
The Wall Street Journal.
NEWS ALERT
Jeffrey Epstein Found Dead in Jail, Officials Say
Financier Jeffrey Epstein has been found dead in jail while awaiting trial on
sex-trafficking charges, law enforcement officials said.
See More Coverage >
Share this email with a friend.
Forwarded this email by a friend?
Forward
Sign Up Here
EFTA00024350

=== Page 2 ===
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All Rights Reserved.
EFTA00024351


c1: EFTA00024854
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024854.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 - 1B7
Details
Collected On: 08/28/2006 8:00 AM
Receipt Item #: None
CATS ID #:
None
CATS Abandonment #: None
FBI Seizure #: None
Abandonment #: None
Storage Location
Discovery
Location
Holding Office: NY - NEW YORK
Finalized By:
Area:
Unavailable in data migrated from
Last Inventory: 07/20/2021 12:00 AM
ACS
Seizing
Individual:
Specific:
Unavailable in data migrated from
ACS
Collected By:
Retention
Retention: No
Legal Caveats
None
Chain of Custody
Shipping Log
History
Acquisition Event
Acquisition Event: (U//FOUO) Items migrated on 2006-08-28
Collected From: (U//FOUO) DET
345 SOUTH COUNTY ROAD
PALM BEACH, FL, 33480
Receipt Given:
No
Holding Office:
MM - MIAMI
Evidence Log:
Missing
Missing
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/1
EFTA00024854

=== Page 2 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B7
Barcode : E4229234
Accepted By:
Printed Name:
Signature: S
Reason: Collected
Date/Time: 08/28/2006
11:00am
Accepted By:
Printed Name:.
Signature: yea-
Reason:
STORAGE.
Date/Time: 2-8-08
330 330 PM. PM.
Accepted By:
Printed Name:
Signature: Isa-
Reason: RELEASED TO SA.
Date/Time: 4-10-08
1100 AM.
Accepted By:
Printed Name:
Signature:
Reason: Review
Date/Time: 04/10/2008
11:01am
Accepted By:
Printed Name
Signature: <.,
Reason: Hill Return dall IBs
Date/Time: 01/13/20 93:14Pm
Accepted By:
Printed Name:
Signature: If
Reason:
STORAGE.
Date/Time: 01-13-09 315PM.
Accepted By:
Printed Name:
Signature:
Reason:
Printed Name:
RE R
Date/Time:
Accepted By:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Reason:
6/14/19 Signature:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
EFTA00024855

=== Page 3 ===
EVIDENCE CHAIN OF CUSTODY
Relinquished Custody FedEx#: 47834467 6408
Date and
Accepted Signature: Custody
Date and
Time
Time
Signature
6/17/19
Printed Name/Agency:
6/18/19
FBI
9:35AM
Printed Name/Agency:
Reason:
Reason: A MMMMA 36PM
Signature: Printed Relinquished Name/Agency Transferred M Custody to NY
Date and
Accepted Custody
Date and
6/18/19
Time
Time
Signature:
6/18/19
Reason: CCO
Printed Name/Agency:-
3:45pm
Reason: Evidence Review
3:45p
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature
3/4/21
Signature:
3/4/21
Printed Name/Agency:
FBI
12:27
Printed Name/Agency:
Relinquished Reason: Evidemestenting Custody
Reason:
charges 11
12:27pm
Date and
Accepted Custody
Date and
Printed Signature: Name/Agen %
Time
Time
3/3//21
Signature:
3/31/21
Printed Name/Agency:
Reason:
335
Reason:
Review
3355p
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature: Ayoung
4/8/21
Signature: alout
Printed Name/Agency:
Printed Name/Agency
4/8/21
Reason: storage
2:33
233pm
Relinquished Custody
Date and
Reason: Storage
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Case ID: 31E-MM-108062
1B: 7
Barcode: E4229234
This form is incomplete without reference to the FD-1087.
EFTA00024856


c1: EFTA00024426
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024426.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Fwd: United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Date: Mon, 26 Aug 2019 20:17:15 +0000
Hi,
The below emails apparently did not go through to Judge Berman or his clerk. Would it be possible to check and
see why that might be?
Thanks,
Begin forwarded message:
From:
Date: August 26, 2019 at 3:46:43 PM EDT
To:
Cc:
Subject: FW: United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
From:
Sent: Monday, August 26, 2019 1:58 PM
To:
Cc:
Subject: United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Berman,
We received a request from the Court for the contact information for victim attorneys. Not all victims are represented by
counsel, but the attorneys we are aware of are:
EFTA00024426

=== Page 2 ===
Although the Government has made best efforts to notify victims of tomorrow's proceeding, the Government does not
know which victims plan to attend tomorrow's conference, and it is possible that victims the Government is not aware
of may attend.
We have not copied defense counsel here, in order to respect the privacy of the victims.
Respectfully,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00024427


c1: EFTA00024502
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024502.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Epstein NY property
Start Date: 2020-07-16 17:30:00 +0000
End Date: 2020-07-16 18:00:00 +0000
Organizer: Weinstein, Marc A.
Location: Skype Meeting; Conference ID: 612 758 867;
Class: X-PERSONAL
Date Created: 2020-07-16 14:42:22 +0000
Date Modified: 2020-07-16 14:42:22 +0000
Priority: 5
DTSTAMP: 2020-07-16 14:27:16 +0000
Attendee:
i
i
>; Andrew Tomback
Alarm: Display the following message 15m before start
Reminder
Dial-In Information (for meetings with no presentations or video)
Dial-In Number:
Conference ID:
612758867
One touch dial-in from mobile phone (via cellular service)
Additional Dial-In Numbers
Brazil
Canada
China
France
Germany
+
India
Ireland
Israel
Japan
Korea (Seoul)
Singapore
+
United Kingdom
EFTA00024502

=== Page 2 ===
United States
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?
[!OC([CUSTOMINVITE])!]
EFTA00024503


c1: EFTA00025342
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025342.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Alex Conlon <aconlon@kaplanhecker.com>
To:
)"
Subject: FW: FBI Victim Services Division Briefing for Victims of Jeffrey Epstein
Date: Mon, 07 Oct 2019 21:55:52 +0000
Alex Conlon Kaplan Hecker & Fink LLP
Original Message
From:
(NY) (FBI)
Sent: Friday, October 4, 2019 3:11 PM
To:
(NY) (FBI)
>; ; VictimServices <victimservices@fbi.gov>
Subject: RE: FBI Victim Services Division Briefing for Victims of Jeffrey Epstein
Dear Law Firm - I am reaching back out since today is the requested RSVP date. Thank you so much for your
assistance in getting the invitation to your clients. We do understand that it was a short turn around, so please
continue to reach out to us with all those that would like to attend.
If you are accompanying your client we will also need your RSVP with the following information as the briefing
will be held in a federal building.
Information for Security:
Full Name:
Firm Name:
Email Address:
Phone Number:
Social Security Number:
Personal Address
Address 1:
Address 2:
City:
State:
Zip:
Citizenship:
Country of Birth:
Victims Information:
Please provide the name of the victim(s) you are representing:
Please identify the briefing you plan to attend:
Date: October 15, 2019
Time: 10:00 AM
Location: 2030 SW 145th Avenue, Miramar, FL 33027
EFTA00025342

=== Page 2 ===
OR
Date: October 23, 2019
Time: 10:00 AM
Location: 290 Broadway, New York, NY 10007
Please let me know if you have any questions. Thank you again for your support.
, MS
FBI Victim Specialist
New York Field Office
Original Message
From:
(NY) (FBI)
Sent: Friday, September 27, 2019 5:24 PM
Subject: FBI Victim Services Division Briefing for Victims of Jeffrey Epstein
Dear Law Firm - if you are receiving this email; you have been identified as representing an identified victim of
Jeffrey Epstein. Please be advised that you have received an invitation for that individual from the email address
victimservices@fbi.gov. The FBI Victim Services Division is hosting two briefings for victims on October 15th
at the Miami Field Office and on October 23rd at the New York Field Office. If you have additional clients that
did not receive an invitation please respond back to victimservices@fbi.gov with their individual contact
information.
If you have any questions please feel free to contact me directly.
V/R
, MS
FBI Victim Specialist
New York Field Office
This email and its attachments may contain information that is confidential and/or protected from disclosure by
the attorney-client, work product or other applicable legal privilege. If you are not the intended recipient of the
email, please be aware that any unauthorized review, use, disclosure, dissemination, distribution, or copying of
this communication, or any of its contents, is strictly prohibited. If you have received this communication in
error, please notify the sender immediately and destroy all copies of the message from your computer system.
Thank you.
EFTA00025343


c1: EFTA00025084
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025084.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: travel approval request
Date: Wed, 12 Feb 2020 15:57:52 +0000
Inline-Images: image001.png
Thanks very much,
In my searches, I'm still seeing the 6:44pm American flight, but looks like it's now landing at
12:25 AM. Do you see that?
If not, is it possible the flight is only available non-refundable? If that's the case, then I suppose we should hold off
booking until we have final confirmation on the schedule from our agents.
From:
Sent: Wednesday, February 12, 2020 10:49 AM
To:
Cc:
>;
Subject: RE: travel approval request
Importance: High
I was in the midst of making your travel reservations, but I'm unable to see the return flight from PNS - LGA
departing at 6:44pm on 2/19, arriving at 12:03am on 2/20 that you requested in the attached email below. I assume that
it's no longer available.
The latest flight returning to LGA is leaving at 4:06pm, which I assume is too early. The latest return flight time I found
that's fully refundable is departing PNS at 5:53pm, arriving in JFK at 1:24am on 2/20/20. Let me know if this flight is okay
to book and l'll reserve it ASAP. Thanks.
2/19/2020: PNS - JFK (leaving late afternoon / evening)
American Airlines
Feb 19
ensacola, FL (PNS), 5:53 PM
ami, FL (MIA), 8:35 PM
0 miles
A 3427 (Operated by ENVOY AIR AS AMERICAN EAGLE)
bach Unrestricted
nbraer ERJ-145
eview seat map
Layover (1h 53m)
Miami, FL (MIA)
American Airlines
Feb 19
ami, FL (MIA), 10:28 PM
ew York, NY (JFK), 1:24 AM Different date Thu, Feb 20
192 miles
A 1357
bach Unrestricted
being 737-800
eview seat map
EFTA00025084

=== Page 2 ===
Top of Form
All available fares for Option 25
$188.20
-DG
Govt non-contract fare limited availability
Bottom of Form
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Wednesday, February 12, 2020 10:03 AM
To:
Cc:
is
Subject: FW: travel approval request
Hi
Would you please help us book travel to Pensacola, FL and back for next week? I'd like refundable tickets for the following
flights, please:
Tuesday 2/18 American Airlines flight from LGA to PNS, departing 5:00 PM, arriving 9:03 PM (layover in DCA)
Wednesday 2/19 American Airlines flight from PNS to LGA, departing 6:44 PM, arriving 12:03 AM (layover in CLT)
Please make sure the tickets are refundable just in case we need to move things around. We are still waiting to hear back
from the agents about where exactly we should be staying for the hotel, so we'd like to just book the flights for now, and
l'll let you know when we have a more precise location for the hotel.
Thanks very much,
From:
Sent: Wednesday, February 12, 2020 6:43 AM
To:
)
Cc:
is
)
is
i
Subject: Re: travel approval request
Approved
Sent from my iPad
On Feb 11, 2020, at 7:53 PM,
)
wrote:
Similar to prior requests in connection with the Epstein investigation (2018R01618),
and I would like to please
request permission for the two of us to travel next week for an interview of a witness in Pensacola, Florida on 2/19.
EFTA00025085

=== Page 3 ===
We'd plan to fly down on 2/18 and fly back on 2/19. Also, similar to prior requests, we'd like to request approval to get a
conference room on 2/19.
Thank you,
From:
Sent: Tuesday, January 21, 2020 2:56 PM
To:
Cc:
is
is
i
is
Subject: RE: travel approval request
Approved
From:
Sent: Tuesday, January 21, 2020 2:49 PM
To:
Cc:
y.
in
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), but with an added international
element, we'd like to please request permission for the team to travel next week for an interview near Stockholm,
Sweden, next week on January 29th and/or 30th. We expect to be traveling, respectively, some combination of the 27th
(overnight) to the 31st, depending on when the interview ends up being scheduled, and we'll put final dates on our
formal applications. Also similar to prior trips, we'd like to request approval to get a conference room for one of those
days at a hotel for the interview itself.
Also based on our discussion earlier we'll be mindful of looking for domestic (or domestic-flagged) carrier flights, as well
as the costs of any alternatives, in looking at possible specific bookings. Thanks as always for your help and input on
that.
thank you,
From:
Sent: Wednesday, December 11, 2019 09:58
To:
Cc:
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16
and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior trips,
we'd like to request approval to get a conference room for one of those days.
EFTA00025086

=== Page 4 ===
thank you,
From:
)
Sent: Tuesday, November 05, 2019 16:53
To:
Cc:
>;
V.
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be traveling,
respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip).
thanks,
From:
Sent: Tuesday, October 22, 2019 13:55
To:
Cc:
is
>;
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel on that Monday for the interview, please.
thanks very much,
From:
Sent: Wednesday, June 12, 2019 14:51
To:
Cc:
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference
room at the hotel on Thursday for the interview, please.
EFTA00025087

=== Page 5 ===
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
)
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week
for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night
and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
EFTA00025088

=== Page 6 ===
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00025089


c1: EFTA00027076
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00027076.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: Christian Everdell
Cc:
"
)"
)"
>,
"Mark S. Cohen"
N
"Laura
Menninger"
>, Jeff Pagliuca
>, , "Bobbi
Sternheim
(
)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: US V. Maxwell - discovery production
Date: Tue, 20 Oct 2020 13:49:29 +0000
Embedded:RE:_US_v_Maxwell_-_discovery_production.msg
Sender:
Subject: RE: US V. Maxwell - discovery production
Message-Id:
<SN5P110MB0542FBD2FFEAE3651F4565BD921F0@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM,
>
Cc:
Cc:
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Pretrial Jeffrey Epstein
Date: Mon, 08 Jul 2019 12:04:42 +0000
Importance: Normal
Attachments: 9_Cr._490_Epstein_Sealed_Indictment.pdf
H
The indictment is attached. We hope to have it unsealed within the next hour or so. The defendant's date of birth is
1/20/53. The Government will be seeking detention in this case, and if you have any questions please feel free to give me
a call. My cell is
Thanks,
From:
Sent: Monday. July 8. 2019 7:51 AM
To:
Cc:
Subject: Pretrial Jeffrey Epstein
Good morning all,
I was notified that Mr. Epstein will be arriving today.
Can you please provide me with his pedigree information, a copy of the charging instrument and the estimated time of
arrival he will be at Pretrial Services
Thank You
Sent from my iPhone
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From:
To:
Cc:
Subject: Re: [EXTERNAL] information
Date: Tue, 26 Oct 2021 01:13:30 +0000
Thanks,
I'll figure out where it should go and let you know.
Sent from my iPhone
On Oct 25, 2021, at 8:36 PM,
wrote:
FYI- we discussed this over the summer but I guess he never submitted the request. I know you're no longer on
the case but let me know who I should forward this to in the event I receive a copy of his request. Copying
for his awareness.
Begin forwarded message:
From:
Date: October 25, 2021 at 8:33:40 PM EDT
To:
Cc:
Subject: Re: [EXTERNAL] information
Hi Mr.
As I discussed with Ms.
over the summer, you would need to submit a FOIA request to the BOP and
note that you are specifically requesting what they released to the NYT. You can send me copy of that request
once it has been submitted to the BOP and as a courtesy I will ensure that the correct recipient in the Civil
Division of our Office has received it. We do not handle FOIA requests in our division.
Best,
On Oct 25, 2021, at 12:40 PM,
wrote:
Hi,
Hope this finds you well.
EFTA00025055

=== Page 2 ===
I would like to get a copy of ALL of the records that were released to the New York Times on their FOI request
regarding my brother's case (Jeffrey Epstein).
Please advise the quickest way to accomplish this.
Thanks,
Scanned by McAfee and confirmed virus-free.
EFTA00025056


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=== Page 1 ===
From:
)"
To:
Cc: KHP Warrants NYSD <KHP Warrants@nysd.uscourts.gov>,
)"
Subject: RE: Warrant
Date: Mon, 29 Jun 2020 18:35:40 +0000
Attachments: Maxwell_arrest_warrant_signed.pdf
Dear Judge Parker,
Attached is the corrected arrest warrant, which Judge Smith's Chambers just sent to us. I can be reached at
if there are any questions regarding the search warrant.
Thank you, and apologies for the error,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-2225
From:
)
Sent: Monday, June 29, 2020 1:23 PM
To: Katharine Parker
Cc: KHP_Warrants NYSD <KHP_Warrants@nysd.uscourts.gov>;
Subject: RE: Warrant
Dear Judge Parker,
Attached please find signed copies of the indictment and arrest warrant referenced in the warrant application. AUSA
will be available to call the Court at 2pm with the agent on the line to swear out the warrant.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00026521

=== Page 2 ===
From:
Sent: Monday, June 29, 2020 9:33 AM
To: 'Katharine Parker'
Cc: KHP_Warrants NYSD <KHP_Warrants@nysd.uscourts.gov>
Subject: RE: Warrant
Dear Judge Parker,
Thank you very much. I will send a pdf of the signed documents as soon as I have them, and I will call the number
provided below with the agent on the line around noon.
Respectfully,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Katharine Parker
Sent: Monday, June 29, 2020 8:29 AM
To:
Cc: KHP_Warrants NYSD <KHP_Warrants@nysd.uscourts.gov>
Subject: Warrant
Dear Ms.
I have reviewed the warrant. After the Indictment and arrest warrant are signed (around 11:30), please send me a
pdf of the signed documents. I can then swear out the warrant around noon. Please call me with the agent on the
line at
Best,
Judge Parker
USMJ
Get Outlook for iOS
EFTA00026522


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=== Page 1 ===
From:
To:
Subject: [EXTERNAL] Fwd: Request for Comment
Date: Thu, 21 Oct 2021 15:37:48 +0000
Sent from my iPhone
Begin forwarded message:
From: Monique Beals
Date: October 21, 2021 at 11:36:34 AM EDT
To:
Subject: Request for Comment
Hello,
I am a reporter from The Hill, and I wanted to seek any comment you may have on Ghislaine Maxwell seeking
private screenings of potential jurors.
If you have any statement on this, please feel free to reach out.
I apologize for reaching out to you via your Columbia University email address, but wanted to be sure to reach
you in the event you would like to provide a statement.
Best,
Monique Beals
EFTA00026479


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Telephone calls about Jeffrey Epstein
Date: Thu, 11 Jul 2019 13:54:01 +0000
Importance: Normal
Will do
From:
Sent: Wednesday, July 10, 2019 3:03 PM
To:
Cc:
Subject: Telephone calls about Jeffrey Epstein
We need to get this info to all the SSOs who might answer the phone when
is gone for the day.
If we receive a call that sounds like it is from a victim of Jeffrey Epstein, or someone who says they have information,
please respond this way.
Tell the caller you are going to forward them to a special number for this where they should leave a message with a phone
number where we can call them. Tell them someone will definitely call them. Then forward them to 1-1030.
EFTA00024828


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=== Page 1 ===
From:
(USANYS)"
To: "Kate L. Doniger"
Cc:
)"
"Alexandra Conlon"
, Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Date: Thu, 30 Apr 2020 16:26:55 +0000
Kate,
I hope you are keeping well also. Would a call at 1:45 on Monday, 05/04, work? Please call me at
or I can
circulate a dial-in if helpful.
Thanks,
From: Kate L. Doniger
Sent: Thursday, April 30, 2020 11:15 AM
To:
(USANYS)
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Hope you are keeping well. Thank you very much for this production. We have a few questions for you-are you available
tomorrow or next week to discuss? Please let us know what would be convenient for you. Thanks again,
Kate
Kate L. Doniger Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Tuesday, April 21, 2020 10:55 PM
To: Kate L. Doniger
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: [Not Virus Scanned] RE: Request for Information Relating to Jeffrey Epstein
This message has not been virus scanned because it contains encrypted or otherwise protected data. Please ensure you
know who the message is coming from and that it is virus scanned by your desktop antivirus software.
Kate,
Per our conversation earlier today, please find attached a letter responding to your request for information relating to
Jeffrey Epstein, as well as the set of documents identified in the letter. I will send the password for the document file
separately.
EFTA00025345

=== Page 2 ===
Thank you,
From: Kate L. Doniger
Sent: Wednesday, April 15, 2020 9:09 AM
To:
(USANYS)
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Thanks very much,
Kate L. Doniger I Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Wednesday, April 15, 2020 12:10 AM
To: Kate L. Doniger
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Kate,
Thank you for checking in. I hope you are keeping well also. I do not think we need any additional information from you at
this time. I hope to be able to provide an update early next week.
Thanks,
From: Kate L. Doniger
Sent: Tuesday, April 14, 2020 3:01 PM
To:
(USANYS)
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
We hope that you are keeping well in this very challenging time.
We completely understand that all things are in flux these days, but we just wanted to check in with you about our
request and whether there is any other information you need from us. If it would be helpful to set up a call to discuss, we
are available at your convenience.
Best,
Kate
Kate L. Doniger I Kaplan Hecker & Fink LLP
EFTA00025346

=== Page 3 ===
From:
(USANYS)
Sent: Thursday, February 27, 2020 7:23 PM
To: Alexandra Conlon
>; Roberta Kaplan
Cc: Kate L. Doniger
Subject: RE: Request for Information Relating to Jeffrey Epstein
Alexandra and Robbie,
Thank you for this. I will contact you regarding the request.
Thanks,
From: Alexandra Conlon
Sent: Tuesday, February 25, 2020 7:54 PM
To:
(USANYS)
>; Roberta Kaplan
Cc: Kate L. Doniger
is
Subject: RE: Request for Information Relating to Jeffrey Epstein
SENT ON BEHALF OF ROBERTA KAPLAN
AUSA
Thank you for contacting us. Attached please find a Touhy letter and supporting exhibit requesting documents from the
Department of Justice in connection with our pending litigation against Jeffrey Epstein's estate.
We are happy to schedule a time to talk if it would be helpful to discuss our request.
Best Regards,
Robbie
Alexandra Conlon Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Monday, January 6, 2020 6:59 PM
To: Roberta Kaplan
Cc: Kate L. Doniger
>; Alex Conlon
Subject: Request for Information Relating to Jeffrey Epstein
Dear Ms. Kaplan,
Please find attached a letter regarding the request you discussed with AUSA
for certain information
relating to Jeffrey Epstein. As stated in the letter, please contact me once you have had a chance to review the letter if you
would like to discuss the issues therein further.
EFTA00025347

=== Page 4 ===
Thanks,
Assistant United States Attorney
Southern District of New York
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00025348


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=== Page 1 ===
From
To
Cc
Subject: RE: 5th Production cover letters
Date: Mon, 19 Oct 2020 23:02:53 +0000
Attachments: 2020.10.20_Maxwell_Discovery_Letter.docx
Thanks very much
The MDC cover letters look good to me. Please just change the date to 10/20 because these
will go out tomorrow.
I've revised the counsel cover letter to incorporate some language that
and I previously discussed. The
revised version is attached here
any edits to this before it goes out tomorrow?
Thanks again,
From
Sent: Monday, October 19, 2020 4:06 PM
To:
Cc:
Subject: 5th Production cover letters
Hi, all!
I'm preparing the 5th Production to go out today, and I've attached the cover letter for defense counsel and two cover
letters for Maxwell (one main cover letter to be included with the drive sent to MDC, and one letter containing the
password to be sent in a separate envelope to MDC). Please review at your convenience; once you approve, I'll have both
drives sent out.
Thank you very much!
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
EFTA00027071


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
)"
Subject: SNY.WP.06.29.20.AY.docx
Date: Mon, 06 Jul 2020 17:49:23 +0000
Attachments: SNY.WP.06-29-20.AY.docx
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=== Page 1 ===
From:
)"
To:
Cc:
)"
>, , Jeff Pagliuca
i
,
"
Subject: United States V. Maxwell, 20 Cr. 330 (AJN)
Date: Thu, 02 Jul 2020 16:08:23 +0000
Attachments: 2020-07-02,_United_States_v_Maxwell_20_Cr_330_(AJN)_detention_memorandum.pdf
Dear Judge Nathan,
The Government respectfully submits the attached memorandum in support of detention in the above-captioned case.
We will file the motion on ECF as soon as the docket becomes active. I have copied defense counsel here, and will also
submit a copy of this memorandum to the presiding Magistrate Judge in the District of New Hampshire in connection with
this afternoon's proceedings.
Sincerely,
Assistant United States Attorney
Southern District of New York
EFTA00026526


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=== Page 1 ===
90A-NY-3151227 Serial 38
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Derivative
Date: 08/16/2019
Evidence NYC027711
Approved By: SSA
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) CART-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Derivative Evidence NYC027711: One (1) Seagate
Barracuda 1000GB HDD, ST1000DM003, S/N W1D48Z6E, containing the Clone
Copy of 1B12 hard drive (Seagate Constellation ES 500GB HDD, ST500NM0011,
S/N Z1M1Q1FX), collected via Tableau TX-1, S/N 000ECC58017139. Request ID
112048. Derivative Copy.
Item Type
Description
1B Digital
(U) NYC027711: One (1) Seagate Barracuda 1000GB HDD,
ST1000DM003, S/N W1D48Z6E, containing the Clone Copy of
1B12 hard drive (Seagate Constellation ES 500GB HDD,
ST500NM0011, S/N Z1M1Q1FX), collected via Tableau TX-1,
S/N 000ECC58017139. Request ID 112048. Derivative Copy.
Collected On: 08/12/2019 07:00 PM EDT
Seizing Individual:
Located By:
Device Type: Hard Drive
Designation: Derivative
Number of Devices Collected: 1
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00025433

=== Page 2 ===
90A-NY-3151227 Serial 38
UNCLASSIFIED
Title: (U) Submission of CART Derivative Evidence NYC027711
Re: 90A-NY-3151227, 08/16/2019
UNCLASSIFIED
2
EFTA00025434


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=== Page 1 ===
From:
"
(USANYS) [Contractor]"
To:
)"
Subject: RE:
and
interview notes
,
Date: Fri, 21 Aug 2020 13:29:51 +0000
I've added everything. Just want to confirm that these two were the notes you meant to send. They were in the previous
email as well.
From:
Sent: Friday, August 21, 2020 7:45 AM
To:
(USANYS) [Contractor]
Subject: Fwd:
and
interview notes
Hi
,
Could you please save these in the witness folder? Thanks.
Sent from my iPhone
Begin forwarded message:
From:
To:
(NY) (FBI)"
)"
"
(USANYS)"
Subject:
and
interview notes
,
See attached.
Regarding the
interview from yesterday to summarize it went well. He is very cooperative and willing
to speak again if needed. He recalls in some fashion him and
recruiting and or bringing girls to
Epstein. He recalls that Epstein and only Epstein would pay him $200 for the girls he brought. His interactions
with Maxwell were very limited as he remembers. He didn't seem to think they chatted about bringing girls to
the house. He does recall recruiting
,
and giving her the pre massage speech about how it all goes
down.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
EFTA00026769


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 10621156(1) approved by
now awaiting further approval
Date: Wed, 25 Sep 2019 18:27:13 +0000
Importance: Normal
Dear
Final voucher 10621156(1) has been approved by
, now awaiting further approval.
Trip ID: 10621156
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R19NYS13832 - U.S. V. Epstein (2018R0618) - Victim Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-09-09 - 2019-09-10
Current status: Pending Voucher Approval
Voucher total expenses: 720.32
Estimated trip cost: 910.73
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0010
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00025339


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=== Page 1 ===
From:
To:
Subject: RE:
Date: Wed, 19 Aug 2020 13:39:01 +0000
Hey
- we keep getting a weird vm for him, do you have an email address by any chance? Thanks!
From:
Sent: Wednesday, August 12, 2020 12:09 PM
To:
Subject:
Hi
Plaintiff's Attorney
(who represents several Epstein victims) asked me to reach out to you when I spoke with
him yesterday. Apparently he represents a victim (I think named Mrs.
) of a CFU defendant of yours,
and he's been trying to get in touch with you. He's been very helpful in arranging victim interviews for us, so I agreed to
reach out. Mind if I send an email putting the two of you in touch?
Thanks!
EFTA00023665


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=== Page 1 ===
From:
To:
Subject: Letter to PAE in Epstein FOIA
Date: Wed, 14 Apr 2021 12:42:30 +0000
Attachments: 041321_Times_v_BOP_20cv833_Govt_Letter_v2.docx
All,
In advance of the 10:00 call, please find attached a letter to Judge Engelmayer re: Noel and next steps in the Epstein FOIA.
Please let me know if you have any edits or concerns, or we can discuss on the call.
Thanks,
Assistant United States Attorney
EFTA00026928


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=== Page 1 ===
From:
To:
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: RE: GM -- search warrant returns
Date: Tue, 20 Oct 2020 21:34:25 +0000
Embedded: RE:_GM__search_warrant_returns.msg --
Sender
Subject: RE: GM -- search warrant returns
Message-Id:
<SN5P110MB05421E03E40332DF48C70BA8921F0@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
Cc:
Cc:
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=== Page 1 ===
From:
To:
Subject: Accepted: Call with
counsel
Date: Thu, 20 Feb 2020 17:48:43 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From:
"
To: "
Cc:
"
Bcc:
"
Subject: RE: Maxwell Financial Report Appendices
Date: Fri, 11 Dec 2020 14:42:22 +0000
Embedded: RE:_Maxwell_Financial_Report_Appendices.msg
Sender:
Subject: RE: Maxwell Financial Report Appendices
Message-Id:
<BN3P110MB0260D34AC605D6186FADBA22E3CA0@BN3P110MB0260.NAMP110.PROD.OUTLOOK.CO
M>
To:
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=== Page 1 ===
14
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=== Page 1 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of
records of the business named below, or I am otherwise qualified as a result of my position with
the business named below to make this declaration.
I am in receipt of a Grand Jury Subpoena, dated January 23, 2010, and signed by
Assistant United States Attorney
requesting specified records of the business
named below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby
certify that the records provided herewith and in response to the Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records,
by, or from information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on April 8, 2020
.
(date)
(signature of declarant)
Paralegal Specialist
(name and title of declarant)
Delta Air Lines, Inc.
(name of business)
1030 Delta Blvd., Atlanta, GA 30320
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data
compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business"
as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution,
association, profession, occupation, and calling of every kind, whether or not conducted for profit.
EFTA00023858

=== Page 2 ===
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Primary Ticket:
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Ticket Number:
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Pax Name:
Prmy Tkt Ind:
Y
Issue Date:
Pax Info Txt:
2020-01-18
Excg Ind:
N
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1
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1
Rptg Sys Prvdr Nb:
0066
Nb Of Cpns:
2
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N
Base Fare Amt:
259.53 USD
Medium Type:
E
Ticket Sources
T 18 Jan 2020 09:20:40 PM
Eqvt Fare Paid:
259.53 USD
Transaction Type:
TKT
Received:
CN - 20 Jan 2020 03:50:15 EN
Taxes/Charges:
AY 11.20 USD
Skeletal Indicator:
N
US 19.47 USD
Dome/Intl Ind:
D
FOP Type Code:
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Point of Sale ID:
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TPF TrEvt Typ:
EVST
—
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Rss Typ Cd:
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HRONADMA
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Itinerary Information Coupon State:U Carrier Role:Marketed
Ofcl Std
Ticket Nb
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Img
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wth
Meth
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http://tktviewr.delta.com/tktviewer/action/searchTicket?ticketNumberPrimary=0062415200393&tktDocNb=00624152003938tic.48/2020
EFTA00023859

=== Page 3 ===
0062415200393 - Welcome to New Ticket Viewer
Page 2 of 2
Fare Calculation
Fare Calc
Fare Calc
Rfmd
Typ
Mode
FrCn Ind
Fare Calc Txt
A
6
N
LAX DL LAS110.70QAUNA0MC DL LAX148.83HRONA0MA USD259.53END ZP LAXLAS XF LAX4.5LAS4.5
R
6
N
LAX DL LAS110.70QAUNA0MC DL LAX148.83HRONA0MA USD259.53END ZP LAXLAS XF LAX4.5LAS4.5
Confidential Data Member of Delta Passport Group: Confidential
Copyright 2017 Delta Air Lines. All rights reserved. Proprietary and Confidential to Delta Air Lines Contents of this document may not be reproduced, published, or disclosed without express authorization of Delta Air
Lines
http://iktvievr.delta.com/tktviewer/action/searchTicket?ticketNumberPrimary-0062415200393tktDocN=0062415200393&tic.48/2020
EFTA00023860

=== Page 4 ===
0062415200393 - Welcome to New Ticket Viewer
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prim:
0062415200393 (18 Jan 2020 ,1)
Select View : Psngr Profile
(Prod) Version 1.0 Wed, 08 Apr 2020 04:47:55 PM
Ticket Number:
0062415200393
DL Pax Type:
A
Pax Full Name:
Issue Date: 2020-01-18
Cust Acct Typ Cd:
Pax Info Txt:
Persistent Cust ID:
Sq Nb:
1
SM Acct Nb:
Persistent Cust ID Last Update Gts:
Carrier Client ID:
Tour Code:
Coupon Frequent Flyer Information
Tkt-Cpn Nb
Frequent Flyer Carrier
Frequent Flyer Number
Cust Acc Typ Cd
393-1
TR
393-2
TR
Geographic Address Information
Nb
Address Line 1
Address Line 2
Address Line 3
Address Line 4
Address Line 5
Pstl Area Cd
1
CRAWFORDVILLE FL
32327-3317
Electronic Address Information
Nb
Electronic Address
Cur Ind
No Data Available
Phone Address Information
Nb
Ctry Phone Nb
Ctry Cd
Cur Ind
Diry Chnl Typ
Area Cd
Phone Number
Ext
1
U
Confidential Data . Member of Deita Passport Group: confidential
Copyright 2017 Della Air Lines. All rights reserved. Proprietary and Confidential to Delta Air Lines. Contents of this document may not be reproduced, published, or disclosed without express authorization of Deita Air
Lines.
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EFTA00023861

=== Page 5 ===
0062415200393 - Welcome to New Ticket Viewer
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prim:
0062415200393 (18 Jan 2020
Select View Payment
(Prod) Version 1.0 Wed, 08 Apr 2020 04:48:05 PM
Ticket Number:
062415200393
Base Fare Amt:
259.53 USD
Customer Paid Amt:
0.00 USD
Issue Date:
Equivalent Fare Amt:
259.53 USD
2020-01-18
Rptd Base Amt:
259.53 USD
Tkt Doc Total Amt:
307.80 USD
Rptd Tot Amt:
307.80 USD
Sq Nb:
Base Coltn Amt:
259.53 USD
Crr Agy Sit Amt:
0.00 USD
Collection Nbr:
1
Total Coltn Amt:
307.80 USD
Excg Indicator:
N
Collection Type:
O
Rdmd Non Cash Miles Cnt:
Award Tkt Ind:
N
Tkt Doc Net Miles Cnt:
Tkt Doc Total Miles Cnt:
Payment Information
FOP
Pmt Amt
Nb
Pmt Amt
Sgnd For
Sgnd For
FOP Ref
FOP
FOP
D/CC
Curr Cd
Stt
Amt
Curr Cd
Nb
FOP Trans ID
Vndr
D/CC Acct Nb
D/CC
D/CC
Type
Exp
GTR Acct ID
Cd
Cd
Date
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1
307.80
USD
3
CC
72020
VI
00337B
Original Ticket Information
Nbr
Orig Tkt Nb
Orig Tkt Iss Date
No Data Available
Exchanged Ticket Number Summary
New
Tkt
New Tkt
Excgd
Excgd
New Tkt
New Tkt Nb
New Tkt Iss Date
Sq Nb
Trxns Typ
Excg
Excgd Tkt Doc Nb
Excgd Tkt Iss Dt
Tkt Sq
Excgd Tkt
Tkt
Val
Nb
Trxns Typ
Skitl
Typ
Ind
No Data Available
Event Waiver Information
Evt Wavr
Evt Wavr Short
Evt Wavr
Evt Wavr
Evt Wavr Std
Tkt Doc
Issuing
Tkt Doc Pricing Src
Reprice
Evt Wavr Cd
Name
Evt Wavr Description
Amt
Curr Cd
Amt
Agent
Pricing Src
Process
Security Id
Response ID
Response GTs
Code
ITA
Agent Waiver Information
Agt Wavr Cd
Agt Wavr Amt
Agt Wavr
Agt Wavr Std
Agt Wavr Issg
Amt
Agt Wavr CrCv GTs
Tkt Doc Pricing Src
Tkt Doc Pricing Src
Reprice
Curr Cd
Chnl Id
Response ID
Response GTs
Process
Cd
DC
ITA
Ticket Document Waiver Information
http://tktviewr.delta.com/tktviewer/action/searchPayment
4/8/2020
EFTA00023862

=== Page 6 ===
PCI Token Manager
Page 1 of 2
PPR# 096625200
Logout
DELTA
PCI Token Decode Form
PCI Token
Manager Forms
Credit Card Lookup
Token Decode
Instructions
Type or Paste space- or carriage-return-delimited list of tokens into Items list.
Select Clear to clear contents from the Item list.
Select Submit to retrieve list of associated credit card numbers that will appear in the Results list.
Items to Decode:
Results:
St-Rsn Cd:
Status/Reason Text:
200-250
succeeded
CLEAR
SUBMIT
2018 Delta Air Lines, Inc. I Information Technology. All rights reserved.
https://twp.delta.com/TokenWebPortal/decodeToken.action
4/8/2020
EFTA00023863


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026715.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
STATE
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 13, 2020
BY FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the drive containing discovery materials is
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
Enclosure
EFTA00026715


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=== Page 1 ===
90A-NY-3151227 Serial 5
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Evidence
Date: 08/14/2019
NYC023579
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S), ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From: (U) MCC-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Evidence NYC023579: One (1) Hitachi 500GB HDD,
HDS721050CLA662, S/N JP1572JE36A13K from MCC Nice Vision DVR2
Surveillance System (2 of 18).
Item Type
Description
1B Digital
(U) NYC023579: One (1) Hitachi 500GB HDD,
HDS721050CLA662, S/N JP1572JE36A13K from MCC Nice Vision
DVR2 Surveillance System (2 of 18).
Collected On: 08/10/2019 04:30 PM EDT
Seizing Individual:
Collected By:
Device Type: Hard Drive
Designation: Original
Number of Devices Collected: 1
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00023972


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=== Page 1 ===
From:
)"
To:
Cc:
Subject: To-do list
Date: Thu, 12 Dec 2019 16:40:32 +0000
Following up on yesterday's meeting, below is a list of items that we would like to get done before charging Maxwell.
and I can take the lead in coordinating interviews, but we would appreciate it if you guys would please take
the lead on preparing a photobook/array, tracking down the records, and reviewing the search warrant materials. Please
let us know what subpoenas, etc. you need to track down the records.
Prepare Photobook/Photo array containing photo of
from the 90s, together with photos of females of similar age
and appearance.
Records:
Interlochen records re
,
Epstein, Maxwell
school records for Palm Beach & New York
Maxwell ins/outs for US & UK 1994-1998
ins/outs for US & UK 1994-1996
Maxwell domestic flights 1994-1998
domestic flights 1994-1998
domestic flights 1995-1996
Search Warrant Returns:
Search for photos of
Search all documents/emails/communications for
and
names
Search all documents/emails/communications for Maxwell
Interviews:
mother
brother
Ask for any records/photos from 194-98
mother
Ask for emails with JE/others, any other records/photos from 1994-96
Ask for
journal & any other records/photos from 1995-96
mother
sister
former boyfriend
EFTA00026528

=== Page 2 ===
Ask for complete set of flight logs and any related records
Ask for emails/records related to
Maxwell 1994-98
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00026529


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=== Page 1 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
)
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case No.
)
3 electronic devices seized on July 11, 2019 from 9 East
71st Street, New York, NY
)
)
SEARCH AND SEIZURE WARRANT
To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Southern
District of
New York
(identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
18 U.S.C. 1591; 18 U.S.C. 2422; 18 USC 2423; 18 U.S.C. 371
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before
November 10, 2020
(not to exceed 14 days)
in the daytime 6:00 a.m. to 10 p.m.
at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USMJ Initials
I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box)
for
30 days (not to exceed 30).
Juntil, the facts justifying, the later specific date of
Date and time issued:
October 27, 2020 7:20 pm
Ost Indge signature
City and state: New York, NY
Hon. Ona T. Wang, U.S. Magistrate Judge
Printed name and title
EFTA00024744

=== Page 2 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Case No.:
Date and time warrant executed:
Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
EFTA00024745

=== Page 3 ===
Attachment A
I. Devices Subject to Search and Seizure
The devices that are the subject of this search and seizure warrant (the "Subject Devices")
are described as follows:
The Subject Devices were recovered from a search of JEFFREY EPSTEIN's private
residence located at 9 East 71st Street, New York, New York, which took place on July 11, 2019.
The Subject Devices are particularly described as follows:
a. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E6433822 ("Corrected Subject Device-32");
b. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E6433824 ("Corrected Subject Device-33");
and
c. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E6433821 ("Corrected Subject Device-34").
II. Review of ESI on the Subject Devices
Law enforcement personnel (who may include, in addition to law enforcement officers and
agents, attorneys for the government, attorney support staff, agency personnel assisting the
government in this investigation, and outside technical experts under government control) are
authorized to review the ESI contained on the Subject Device for evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors), 2422 (transportation of minors), 2423 (enticement to travel), and 371 (conspiracy to
commit sex trafficking, transportation of minors, and enticement to travel) (the "Subject
Offenses"), for the period 1994 through August 8, 2019, described as follows:
1.
Evidence concerning the identity or location of the owner(s) or user(s) of the
Subject Devices.
2.
Evidence concerning the identity or location of co-conspirators of JEFFREY
EPSTEIN, including
and GHISLAINE MAXWELL.
3.
Evidence concerning communications to, from, by, and/or among co-conspirators
of JEFFREY EPSTEIN, including
and GHISLAINE MAXWELL.
4.
Any documents or communications with or regarding victims or potential victims
of the Subject Offenses.
2017.08.02
EFTA00024746

=== Page 4 ===
5.
Documents or records reflecting payments to victims and/or co-conspirators
including but not limited to bank and financial records, spreadsheets, ledgers, account listings,
check and wire records, and documents reflecting cash withdrawals.
6.
Documents or records reflecting travel plans or arrangements for victims or
potential victims of the Subject Offenses, or co-conspirators in those Subject Offenses, including
but not limited to itineraries, tickets, receipts, flight manifests, passport or identification
information, and related records.
7.
Any photographs of victims or potential victims of the Subject Offenses.
8.
Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger.
9.
Records or other items that evidence ownership, control, or use of, or access to
devices, storage media, and related electronic equipment used to access, transmit, or store
information relating to the Subject Offenses, including, but not limited to, sales receipts,
warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved
usernames and passwords, user profiles, e-mail contacts, and photographs.
10.
Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. § 2256(8).
If the Government determines that any of the Subject Devices is no longer necessary to retrieve
and preserve the data on the device, and that any of the Subject Devices is not subject to seizure
pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return any such Subject
Device, upon request.
2
2017.08.02
EFTA00024747


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=== Page 1 ===
From:
N. (NY) (FBI)"
To:
)"
Cc:
)"
)"
Subject: GM investigation
Date: Wed, 26 Feb 2020 18:44:19 +0000
Attachments: 20200225_220138.jpg; 20200225_220146.jpg; 20200225_220156.jpg;
20200225_220217.jpg
notes attached. I had to take pictures since I have not been able to scan them. So they're coming in a
couple emails. Here's the first 4 pages
On Feb 24, 2020 9:28 AM,
)"
wrote:
Hi
and
In connection with the Maxwell investigation, I know this is a travel week, but if at all possible, are you able to assist with
the following? It would be great to get some of these in motion this week:
1) Are you able to spend some time reviewing the message pads seized from Epstein's residence, to search for any
messages left by (or regarding) any of the individuals relating to the GM case? In particular, it would be helpful to
know if there are messages relating to:
2) I recognize that we do not have a complete picture of Maxwell's current finances. I don't think it makes sense to
request additional financial information, but it would be helpful to have a snapshot of what we already know
about her current assets. In addition, it would be helpful to know if there are any significant transfers from
Epstein's account to Maxwell since 2005. Along the same line, a check for more recent alerts in FinCEN would be
helpful.
3) On the topic of assets, can you tell us what properties Maxwell currently owns?
4) Could you please send us the current tracking document for the hotline? It would be helpful for us to check
through the leads regarding Maxwell.
5) I think we emailed about this last month, but can you let us know how you know that she has UK and French
citizenship?
6) Could you please send us the notes from the
interview?
Thanks in advance, and sorry to pile on, I know everyone is busy.
EFTA00026802

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00026803


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=== Page 1 ===
Event: Accepted: Epstein Press Meeting
Start Date: 2019-07-01 20:00:00 +0000
End Date: 2019-07-01 21:00:00 +0000
Location: 8th Floor Library
Class: X-PERSONAL
Comment:
Date Created: 2019-07-01 03:01:06 +0000
Date Modified: 2019-07-01 03:01:06 +0000
Priority: 5
DTSTAMP: 2019-07-01 02:57:06 +0000
Attendee:
EFTA00024821


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=== Page 1 ===
From:
)"
To:
Cc:
)"
Subject: Re: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Date: Thu, 11 Mar 2021 15:46:56 +0000
Me too, thanks.
Sent from my iPhone
On Mar 11, 2021, at 10:43 AM,
wrote:
Good for me.
From:
Sent: Thursday, March 11, 2021 10:42 AM
To:
is
Cc:
>;
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Would 3:30 work?
From:
Sent: Thursday, March 11, 2021 10:38 AM
To:
is
Cc:
V.
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Hi
and
Would it be possible to schedule a call to discuss this? We spoke with the civil AUSA on the Radar Online case today, so
we have updates on that as well.
Thanks,
From:
Sent: Thursday, March 11, 2021 9:15 AM
To:
Cc:
)
is
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Thanks,
On the plus side, it would appear that all of these are recent and pertain (in general terms) to the
Epstein investigation we all did and that you are intimately familiar with. Do we have a way of compiling a list of the
requests made to Civ Div and handled by them? They must have a FOIA coordinator or something like that
EFTA00025213

=== Page 2 ===
From:
Sent: Wednesday, March 10, 2021 5:56 PM
To:
is
Cc:
is
Subject: FW: Jeffrey Epstein/Ghislaine Maxwell/FOIA
FYI.
S list has about sixteen cases. I've asked
to check his records to see if there are more. When we have the
full list,
and I will check in with you to see where we should go from here. Two things to note for now:
One of these FOIA requests is from Boies Schiller, and the log notes that BSF has made multiple requests,
including to other districts.
This list only includes FOIA requests directed to our office. It does not include FOIA lawsuits our civil division has
handled, based on FOIA requests to other governmental components (for example, the Radar Online case
referenced in Maxwell's letter).
Thanks,
From:
Sent: Wednesday, March 10, 2021 5:23 PM
To:
Cc:
>;
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
As we just discussed:
Here is what we have in our FOIA tracking database regarding Epstein FOIAs.
And also attached is the letter in PPI about discovery vs FOIA (see p. 8)
From:
Sent: Wednesday, March 10, 2021 5:20 PM
To
Cc
>;
Subject: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Hi Darian,
Hope you're doing well.
and
and I are trying to assemble a list of every FOIA request our office has ever
received (at any point) relating to Jeffrey Epstein and/or Ghislaine Maxwell.
suggested that you'd be the
best point of contact to help us figure this out. Could you please send us the following information:
A list of all FOIA requests our office has received;
For each case, whether a production was made in response to the request; and
Who the AUSA point of contact for the request is.
That would be a big help. Please let us know if you need any information from us to run the search.
Thanks very much,
EFTA00025214

=== Page 3 ===
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00025215


c1: EFTA00024032
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024032.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit A
EFTA00024032

=== Page 2 ===
3/9/2021
EMailCorrespondence.html
START MESSAGE Subject: eFOIA Request Received Sent: 2017-04-20T18:49:46.543923+00:00 Status:
pending Message:
Organization Representative Information
Organization Name
The National Enquirer
Prefix
First Name
James
Middle Name
Last Name
Robertson
Suffix
Email
jrobertson@amilink.com
Phone 2127436555
Location
United States
Domestic Address
Address Line 1
4 New York Plaza
Address Line 2
2nd Floor
City
New York
State
New York
Postal
10004
Agreement to Pay
file://hqrd-sfile-fdps/FDPS_Repository/EFOIA/2195/EMailCorrespondence.html
1/2
EFTA00024033

=== Page 3 ===
3/9/2021
EMailCorrespondence.html
How you will pay
I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter that
maximum amount in the box below.
Allow up to $ 99,999
Proof Of Affiliation for Fee Waiver
Waiver Explanation
The National Enquirer is a news organization. Under 5 U.S.C. §
552(a)(4)(A)(iii), the Enquirer is entitled to a fee waiver because
disclosure of the information sought is in the public interest, is likely to
contribute significantly to public understanding of the operations or
activities of the government, and is not primarily in the commercial
interest of the requester.
Documentation Files
Non-Individual FOIA Request
Request Information
Please see attached pdf for the National Enquirer's FOIA request concerning
the investigation and prosecution of financier Jeffrey Epstein in 2005 and
2006 for crimes relating to sexual trafficking of minors.
Expedite
Expedite Reason
This request has been the subject of the request is of widespread and
exceptional media interest and the information sought involves possible
questions about the government's integrity which affects public confidence.
Specifically; the issue of whether Mr. Epstein's wealth and connections
secured him favorable treatment by the DOJ.
Given that a civil defamation trial between one of Epstein's victims and his
alleged co-conspirator, Ghislaine Maxwell, has just begun, the topic is of
renewed interest to the public and therefore is worthy of expedited
processing.
END MESSAGE
file://hqrd-sfile-fdps/FDPS_Repository/EFOIA/2195/EMailCorrespondence.html
2/2
EFTA00024034

=== Page 4 ===
NATIONAL
ENQUIRER
April 20, 2017
VIA FOIA PORTAL
TO:
Federal Bureau of Investigation
FROM:
James Robertson
Senior Managing Editor
The National Enquirer
4 New York Plaza (2ⁿᵈ Floor)
New York, NY 10004
(212) 743-6555
Dear Sir or Madam,
I am a reporter and editor for The National Enquirer. I request records under the provisions
of the Freedom of Information Act, 5 U.S.C.§ 552.
Request
The Enquirer seeks all documents relating to the FBI's investigation and prosecution of
financier Jeffrey Edward Epstein, who pled guilty to one count of felony solicitation of
prostitution in August 2006.
Background
Jeffrey Epstein is a billionaire financier, philanthropist, and sex offender. In 2005, Epstein
became the subject of an undercover sex trafficking investigation by Palm Beach, Florida
police and the FBI. Dozens of underage women claimed that they had been trafficked by
Epstein to perform sexual acts on him as well as his friends.
Many prominent political figures have been connected to Mr. Epstein's child-trafficking
ring, including former President Bill Clinton and Prince Andrew of the British Royal
Family.
Links: (Bill Clinton) http://www.foxnews.com/us/2016/05/13/flight-logs-show-bill-clinton-
flew-on-sex-offenders-jet-much-more-than-previously-known.html: (Prince Andrew)
https://www.theguardian.com/world/2015/jan/10/jeffrey-epstein-decade-scandal-prince-
andrew
Despite the gravity of his offenses, the Department of Justice agreed to allow Epstein to
plead guilty to a single count of soliciting prostitution from an underage girl under Florida
state law, and served only 13 months in prison. In addition, prosecutors agreed not to bring
charges against Epstein's alleged co-conspirators.
Page 1 of 3
EFTA00024035

=== Page 5 ===
NATIONAL
ENQUIRER
Link: https://www.theguardian.com/world/2015/jan/10/jeffrey-epstein-decade-scandal-
prince-andrew
Papers filed in a 2006 lawsuit alleged that Epstein surreptitiously recorded sexual activity
between prominent individuals and underage girls for purposes of blackmail, leaving many
to wonder whether potential blackmail material played a role in his light sentence:
Link: http://www.ibtimes.com.au/prince-andrew-might-have-been-caught-tape-sex-slave-
1407641
Expedited Processing
This request has been the subject of the request is of widespread and exceptional media
interest and the information sought involves possible questions about the government's
integrity which affects public confidence. Specifically; the issue of whether Mr. Epstein's
wealth and connections secured him favorable treatment by the DOJ.
Given the a civil defamation trial between one of Epstein's victims and his alleged co-
conspirator, Ghislaine Maxwell, is about to begin, the topic is of renewed interest to the
public and therefore is worthy of expedited processing.
Certification
The above information is true and correct to the best of my knowledge.
Fee Waiver
The National Enquirer is a news organization. Under 5 U.S.C. § 552(a)(4)(A)(iii), the
Enquirer is entitled to a fee waiver because disclosure of the information sought is in the
public interest, is likely to contribute significantly to public understanding of the operations
or activities of the government, and is not primarily in the commercial interest of the
requester.
Electronic Records
Please furnish all responsive records in electronic format.
Further Correspondence
All correspondence regarding this request can be directed to me at jrobertson@amilink.com
Please be aware that under 5 U.S.C. § 552(a)(6)(A), a FOIA request is considered
constructively denied after twenty business days.
Page 2 of 3
EFTA00024036

=== Page 6 ===
NATIONAL
ENQUIRER
If you have any questions, do not hesitate to contact me.
Thank you for your prompt attention to this request.
Sincerely,
James Robertson
Senior Managing Editor
Page 3 of 3
EFTA00024037

=== Page 7 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit B
EFTA00024038

=== Page 8 ===
U.S. Department of Justice
DEPARTMENT
OF
Justice
FEDERAL BUREAU OF
Federal Bureau of Investigation
Washington, D.C. 20535
April 28, 2017
MR. JAMES ROBERTSON
THE NATIONAL ENQUIRER
2ND FLOOR
4 NEW YORK PLAZA
NEW YORK, NY 10004
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Robertson:
This acknowledges receipt of your Freedom of Information Act (FOIA) request to the FBI. The
FOIPA number listed above has been assigned to your request.
You submitted your request via the FBI's eFOIA system.
We have reviewed your request and determined that it is compliant with
the terms and conditions of the eFOIA system. You will continue to receive
correspondence online.
We have reviewed your request and determined that it is not in compliance with
the terms and conditions of the eFOIA system. Future correspondence will be
mailed to you.
You have requested records concerning one or more third party individuals. The FBI recognizes
an important privacy interest in the requested information. To continue processing your request regarding a
third party, submit one of the following: (1) an authorization and consent from the individual(s) (i.e., express
authorization and consent of the third party); (2) proof of death (i.e., proof that your subject is deceased); or
(3) a justification that the public interest in disclosure outweighs personal privacy (i.e., a clear demonstration
that the public interest in disclosure outweighs personal privacy interests). In the absence of such
information, the FBI can neither confirm nor deny the existence of any records responsive to your request,
which, if they were to exist, would be exempt from disclosure pursuant to FOIA Exemptions (b)(6) and
(b)(7)(C), 5 U.S.C. §§ 552 (b)(6) and (b)(7)(C).
Express authorization and consent. If you seek disclosure of any existing records on this basis,
enclosed is a Certification of Identity form. You may make additional copies of this form if you are
requesting information on more than one individual. The subject of your request should complete this form
and then sign it. Alternatively, the subject may prepare a document containing the required descriptive data
and have it notarized. The original certification of identity or notarized authorization with the descriptive
information must contain a legible, original signature before FBI can conduct an accurate search of our
records.
Proof of death. If you seek disclosure of any existing records on this basis, proof of death can be
a copy of a death certificate, Social Security Death Index, obituary, or another recognized reference source.
Death is presumed if the birth date of the subject is more than 100 years ago.
Public Interest Disclosure. If you seek disclosure of any existing records on this basis, you must
demonstrate that the public interest in disclosure outweighs personal privacy interests. In this regard, you
must show that the public interest sought is a significant one, and that the requested information is likely to
advance that interest.
Fax your request to the Work Process Unit at (540) 868-4997, or mail to 170 Marcel Drive,
Winchester, VA 22602. If we do not receive a response from you within 30 days from the date of this letter,
your request will be closed. You must include the FOIPA request number with any communication
regarding this matter.
EFTA00024039

=== Page 9 ===
For your information, Congress excluded three discrete categories of law enforcement and national
security records from the requirements of the FOIA. See 5 U.S.C. $ 552(c). As such, this response is
limited to those records, if any exist, that are subject to the FOIA. This is a standard notification that is
given to all our requesters and should not be taken as an indication that excluded records do, or do not,
exist.
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you
may submit an appeal through OIP's FOIAonline portal by creating an account on the following web
site: https://foiaonline.regulations.gov/foia/action/public/home. Your appeal must be postmarked or
electronically transmitted within ninety (90) days from the date of this letter in order to be considered timely.
If you submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom of
Information Act Appeal." Please cite the FOIPA Request Number assigned to your request so that it may
be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information
Services (OGIS) at 877-684-6448, or by emailing ogis@nara.gov. Alternatively, you may contact the FBI's
FOIA Public Liaison by emailing foipaquestions@ic.fbi.gov. If you submit your dispute resolution
correspondence by email, the subject heading should clearly state "Dispute Resolution Services." Please
also cite the FOIPA Request Number assigned to your request so that it may be easily identified.
For questions on how to reasonably describe your request, please email us at
foipaquestions@ic.fbi.gov. You may also visit www.fbi.gov and select "Services," "Records Management,"
and "Freedom of Information/Privacy Act" for additional guidance.
Enclosed for your information is a copy of the FBI Fact Sheet and a copy of the Explanation of
Exemptions.
Sincerely,
Bluetz
David M. Hardy
Section Chief,
Record/Information
Dissemination Section
Records Management Division
Enclosure(s)
EFTA00024040

=== Page 10 ===
DEPARTMENT
OF
JUSTICE
FBI FACT SHEET
FEORRAL BUREAU OF DEPARTMENT
The primary functions of the FBI are national security and law enforcement.
The FBI does not keep a file on every citizen of the United States.
The FBI was not established until 1908 and we have very few records prior to the 1920s.
FBI files generally contain reports of FBI investigations of a wide range of matters, including counterterrorism,
counter-intelligence, cyber crime, public corruption, civil rights, organized crime, white collar crime, major thefts,
violent crime, and applicants.
The FBI does not issue clearances or non-clearances for anyone other than its own personnel or persons
having access to FBI facilities. Background investigations for security clearances are conducted by many
different Government agencies. Persons who received a clearance while in the military or employed with some
other government agency should contact that entity. Most government agencies have websites which are
accessible on the internet which have their contact information.
An identity history summary check or "rap sheet" is NOT the same as an "FBI file." It is a listing of
information taken from fingerprint cards and related documents submitted to the FBI in connection with arrests,
federal employment, naturalization or military service. The subject of a "rap sheet" may obtain a copy by
submitting a written request to FBI CJIS Division - Summary Request, 1000 Custer Hollow Road, Clarksburg, WV
26306. Along with a specific written request, the individual must submit a new full set of his/her fingerprints in
order to locate the record, establish positive identification, and ensure that an individual's records are not
disseminated to an unauthorized person. The fingerprint submission must include the subject's name, date and
place of birth. There is a required fee of $18 for this service, which must be submitted by money order or
certified check made payable to the Treasury of the United States. A credit card payment option is also
available. Forms for this option and additional directions may be obtained by accessing the FBI Web site at
www.fbi.gov/about-us/cjis/identity-history-summary-checks.
The National Name Check Program (NNCP) conducts a search of the FBI's Universal Index (UNI) to identify
any information contained in FBI records that may be associated with an individual and provides the results of that
search to a requesting federal, state or local agency. Names are searched in a multitude of combinations and
phonetic spellings to ensure all records are located. The NNCP also searches for both "main" and "cross
reference" files. A main file is an entry that carries the name corresponding to the subject of a file, while a cross
reference is merely a mention of an individual contained in a file. The results from a search of this magnitude
can result in several "hits" and "idents" on an individual. In each instance where UNI has identified a name
variation or reference, information must be reviewed to determine if it is applicable to the individual in question.
The Record/Information Dissemination Section (RIDS) searches for records and provides copies of FBI files
responsive to Freedom of Information or Privacy Act (FOIPA) requests for information. RIDS provides
responsive documents to requesters seeking "reasonably described information." For a FOIPA search, the
subject's name, event, activity, or business is searched to determine whether there is an associated investigative
file. This is called a "main file search" and differs from the NNCP search.
FOR GENERAL INFORMATION ABOUT THE FBI, VISIT OUR WEBSITE AT
www.fbi.gov
7/18/16
EFTA00024041

=== Page 11 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the
matters be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding
or refers to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records
or information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a
fair trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D)
could reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any
private institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign
policy, for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or
privilege under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity
would be held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant
to the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024042

=== Page 12 ===
U.S Department of Justice
Certification of Identity
FORM APPROVED OMB NO. 1103-0016
EXPIRES 03/31/17
Privacy Act Statement. In accordance with 28 CFR Section 16.41(d) personal data sufficient to identify the individuals submitting requests by
mail under the Privacy Act of 1974, 5 U.S.C. Section 552a. is required. The purpose of this solicitation is to ensure that the records of individuals
who are the subject of U.S. Department of Justice systems of records are not wrongfully disclosed by the Department. Requests will not be
processed if this information is not furnished False information on this form may subject the requester to criminal penalties under 18 U.S.C.
Section 1001 and/or 5 U.S.C. Section 552a(i)(3).
Public reporting burden for this collection of information is estimated to average 0.50 hours per response, including the time for reviewing
instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of
information Suggestions for reducing this burden may be submitted to the Office of Information and Regulatory Affairs, Office of Management
and Budget, Public Use Reports Project (1103-0016), Washington, DC 20503.
Full Name of Requester 1
Citizenship Status 2
Social Security Number 3
Current Address
Date of Birth
Place of Birth
OPTIONAL: Authorization to Release Information to Another Person
This form is also to be completed by a requester who is authorizing information relating to himself or herself to be released to another person.
Further, pursuant to 5 U.S.C. Section 552a(b), I authorize the U.S. Department of Justice to release any and all information relating to me to:
Print or Type Name
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct, and that I am the person
named above, and I understand that any falsification of this statement is punishable under the provisions of 18 U.S.C. Section 1001 by a fine of
not more than $10,000 or by imprisonment of not more than five years or both, and that requesting or obtaining any record(s) under false
pretenses is punishable under the provisions of 5 U.S.C. 552a(i)(3) by a fine of not more than $5,000.
Signature 4
Date
1
Name of individual who is the subject of the record(s) sought.
2
Individual submitting a request under the Privacy Act of 1974 must be either "a citizen of the United States or an alien lawfully
admitted for permanent residence," pursuant to 5 U.S.C. Section 552a(a)(2). Requests will be processed as Freedom of Information Act
requests pursuant to 5 U.S.C. Section 552, rather than Privacy Act requests, for individuals who are not United States citizens or aliens
lawfully admitted for permanent residence.
3
Providing your social security number is voluntary. You are asked to provide your social security number only to facilitate the
identification of records relating to you Without your social security number, the Department may be unable to locate any or all records
pertaining to you.
4
Signature of individual who is the subject of the record sought.
FORM DOJ-361
EFTA00024043

=== Page 13 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit C
EFTA00024044

=== Page 14 ===
U.S. Department of Justice
INSURANCE OF
FEDERAL BUREAU of DEPARTMENT
Federal Bureau of Investigation
Washington, D.C. 20535
October 11, 2017
MR. DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
18 U.S. C. Section 3059(d),
(b)(7)(D)
(k)(2)
Federal Rules of Criminal
(b)(7)(E)
(k)(3)
Procedure Rule 6(e)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
296 pages were reviewed and 38 pages are being released.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024045

=== Page 15 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the FOIA. See 5 U.S. C. § 552(c) (2006 & Supp. IV (2010). This response is
limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is given
to all our requesters and should not be taken as an indication that excluded records do, or do not, exist. Enclosed for
your information is a copy of the Explanation of Exemptions.
Although your request is in litigation, we are required by 5 USC $ 552 (a)(6)(A) to provide you the following
information concerning your right to appeal. You may file an appeal by writing to the Director, Office of Information
Policy (OIP), United States Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C.
20530-0001, or you may submit an appeal through OIP's FOIAonline portal by creating an account on the following
web site: https://foiaonline.regulations.gov/foia/action/public/home Your appeal must be postmarked or
electronically transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you
submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act
Appeal." Please cite the FOIPA Request Number assigned to your request so that it may be easily identified.
The enclosed material is from the main investigative file(s) in which the subject(s) of your request was the
focus of the investigation. Our search located additional references, in files relating to other individuals, or
matters, which may or may not be about your subject(s). Our experience has shown when ident, references
usually contain information similar to the information processed in the main file(s). Because of our significant
backlog, we have given priority to processing only the main investigative file(s). If you want the references, you
must submit a separate request for them in writing, and they will be reviewed at a later date, as time and resources
permit.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Records Management Division
Enclosures
The enclosed documents contained in this release represent the first interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
Duplicate copies of the same document were not processed.
For your information, sealed court records are not eligible for release under the Freedom of Information
Act. Material responsive to your request has been withheld and marked "OTHER-Sealed" pursuant to appropriate
order(s) issued by federal district courts.
Your request for a waiver of fees has been granted.
For questions regarding our determinations, visit the www.fbi.gov/foia website under "Contact Us."
The FOIPA Request Number listed above has been assigned to your request. Please use this number in all
correspondence concerning your request. Your patience is appreciated.
EFTA00024046

=== Page 16 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024047

=== Page 17 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit D
EFTA00024048

=== Page 18 ===
U.S. Department of Justice
DUPARTMENT of Justice OF
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
November 1, 2017
MR. DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
18 U.S. C. Section 3059(d),
(b)(7)(D)
(k)(2)
Federal Rules of Criminal
(b)(7)(E)
(k)(3)
Procedure Rule 6(e)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
527 pages were reviewed and 25 pages are being released.
Document(s) were located which originated with, or contained information concerning, other
Government Agency (ies) [OGA].
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024049

=== Page 19 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the FOIA. See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). This response is
limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is
given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.
Enclosed for your information is a copy of the Explanation of Exemptions.
Although your request is in litigation, we are required by 5 USC § 552 (a)(6)(A) to provide you the following
information concerning your right to appeal. You may file an appeal by writing to the Director, Office of Information
Policy (OIP), United States Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C.
20530-0001, or you may submit an appeal through OIP's FOIAonline portal by creating an account on the following
web site: https://foiaonline.regulations.gov/foia/action/public/home. Your appeal must be postmarked or
electronically transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you
submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act
Appeal." Please cite the FOIPA Request Number assigned to your request so that it may be easily identified.
The enclosed material is from the main investigative file(s) in which the subject(s) of your request was
the focus of the investigation. Our search located additional references, in files relating to other
individuals, or matters, which may or may not be about your subject(s). Our experience has shown
when ident, references usually contain information similar to the information processed in the main
file(s). Because of our significant backlog, we have given priority to processing only the main
investigative file(s). If you want the references, you must submit a separate request for them in writing,
and they will be reviewed at a later date, as time and resources permit.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Records Management Division
Enclosures
The enclosed documents contained in this release represent the second interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
Duplicate copies of the same document were not processed.
For questions regarding our determinations, visit the www.fbi.gov/foia website under "Contact Us."
The FOIPA Request Number listed above has been assigned to your request. Please use this number in all
correspondence concerning your request. Your patience is appreciated.
EFTA00024050

=== Page 20 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person who
furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024051

=== Page 21 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit E
EFTA00024052

=== Page 22 ===
U.S. Department of Justice
DEPARTMENT OF JUSTICE OF
TERMAN BUREAU OF DEPARTMENT
Federal Bureau of Investigation
Washington, D.C. 20535
December 1, 2017
MR. DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Below you will find check boxes under the appropriate statue headings which indicate the types
of exemptions asserted to protect information which is exempt from disclosure. The appropriate exemptions are
noted on the enclosed pages next to redacted information. In addition, a deleted page information sheet was
inserted to indicate where pages were withheld entirely and identify which exemptions were applied. The checked
exemptions boxes used to withhold information are further explained in the enclosed Explanation of Exemptions.
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
18 U.S. C. Section 3059(d),
(b)(7)(D)
(k)(2)
Federal Rules of Criminal
(b)(7)(E)
(k)(3)
Procedure Rule 6(e)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
562 page(s) were reviewed and 94 page(s) are being released.
Below you will also find additional informational paragraphs about your request. Where applicable, check
boxes are used to provide you with more information about the processing of your request. Please read each item
carefully.
Document(s) were located which originated with, or contained information concerning, other
Government Agency [OGA].
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024053

=== Page 23 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the Freedom of Information Act (FOIA). See 5 U.S.C. § 552(c) (2006 & Supp. IV
(2010). This response is limited to those records that are subject to the requirements of the FOIA. This is a
standard notification given to all our requesters and should not be taken as an indication that excluded records do,
or do not, exist. Enclosed for your information is a copy of the Explanation of Exemptions.
Although your request is in litigation, we are required by 5 USC § 552 (a)(6)(A) to provide you the following
information concerning your right to appeal. You may file an appeal by writing to the Director, Office of Information
Policy (OIP), United States Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C.
20530-0001, or you may submit an appeal through OIP's FOIAonline portal by creating an account on the following
web site: https://foiaonline.regulations.gov/foia/action/public/home. Your appeal must be postmarked or
electronically transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you
submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act
Appeal." Please cite the FOIPA Request Number assigned to your request so that it may be easily identified.
The enclosed material is from the main investigative file(s), meaning the subject(s) of your request was
the focus of the investigation. Our search located additional references, in files relating to other
individuals, or matters, which may or may not be about your subject(s). Our experience has shown
such additional references, if identified to the same subject of the main investigative file, usually contain
information similar to the information processed in the main file(s). As such, we have given priority to
processing only the main investigative file(s) given our significant backlog. If you would like to receive
any references to the subject(s) of your request, please submit a separate request for the reference
material in writing. The references will be reviewed at a later date, as time and resources permit.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Records Management Division
Enclosure(s)
The enclosed documents contained in this release represent the third interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
As previously indicated, document(s) were located which originated with, or contained information
concerning another agency. We are consulting with the other agency and are awaiting their response. Our office
has processed all other information currently in our possession. The FBI will correspond with you regarding those
documents when the consultation is completed.
Duplicate copies of the same document were not processed.
For questions regarding our determinations, visit the www.fbi.gov/foia website under "Contact Us."
The FOIPA Request Number listed above has been assigned to your request. Please use this number in all
correspondence concerning your request. Your patience is appreciated.
EFTA00024054

=== Page 24 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person who
furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024055

=== Page 25 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit F
EFTA00024056

=== Page 26 ===
U.S. Department of Justice
DUPARTMENT OF JUSTICE OF
FEDERAL BUREAU OF
Federal Bureau of Investigation
Washington, D.C. 20535
January 2, 2018
MR. DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Below you will find check boxes under the appropriate statute headings which indicate the types
of exemptions asserted to protect information which is exempt from disclosure. The appropriate exemptions are
noted on the enclosed pages next to redacted information. In addition, a deleted page information sheet was
inserted to indicate where pages were withheld entirely and identify which exemptions were applied. The checked
exemptions boxes used to withhold information are further explained in the enclosed Explanation of Exemptions.
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
18 U.S.C. Section 3059(d)
(b)(7)(D)
(k)(2)
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
556 page(s) were reviewed and 38 page(s) are being released.
Below you will also find additional informational paragraphs about your request. Where applicable, check
boxes are used to provide you with more information about the processing of your request. Please read each item
carefully.
Document(s) were located which originated with, or contained information concerning, other
Government Agency [OGA].
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/jj)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024057

=== Page 27 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the Freedom of Information Act (FOIA). See 5 U.S.C. § 552(c) (2006 & Supp. IV
(2010). This response is limited to those records that are subject to the requirements of the FOIA. This is a
standard notification given to all our requesters and should not be taken as an indication that excluded records do,
or do not, exist. Enclosed for your information is a copy of the Explanation of Exemptions.
Although your request is in litigation, we are required by 5 USC § 552 (a)(6)(A) to provide you the following
information concerning your right to appeal. You may file an appeal by writing to the Director, Office of Information
Policy (OIP), United States Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C.
20530-0001, or you may submit an appeal through OIP's FOIAonline portal by creating an account on the following
web site: https://foiaonline.regulations.gov/foia/action/public/home. Your appeal must be postmarked or
electronically transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you
submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act
Appeal." Please cite the FOIPA Request Number assigned to your request so that it may be easily identified.
The enclosed material is from the main investigative file(s), meaning the subject(s) of your request was
the focus of the investigation. Our search located additional references, in files relating to other
individuals, or matters, which may or may not be about your subject(s). Our experience has shown
such additional references, if identified to the same subject of the main investigative file, usually contain
information similar to the information processed in the main file(s). As such, we have given priority to
processing only the main investigative file(s) given our significant backlog. If you would like to receive
any references to the subject(s) of your request, please submit a separate request for the reference
material in writing. The references will be reviewed at a later date, as time and resources permit.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Records Management Division
Enclosure(s)
The enclosed documents contained in this release represent the fourth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
Duplicate copies of the same document were not processed.
For questions regarding our determinations, visit the www.fbi.gov/foia website under "Contact Us."
The FOIPA Request Number listed above has been assigned to your request. Please use this number in all
correspondence concerning your request. Your patience is appreciated.
EFTA00024058

=== Page 28 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person who
furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024059

=== Page 29 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit G
EFTA00024060

=== Page 30 ===
U.S. Department of Justice
DUPARTMENT OF JUSTICE OF
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
February 1, 2018
MR. DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Below you will find check boxes under the appropriate statute headings which indicate the types
of exemptions asserted to protect information which is exempt from disclosure. The appropriate exemptions are
noted on the enclosed pages next to redacted information. In addition, a deleted page information sheet was
inserted to indicate where pages were withheld entirely and identify which exemptions were applied. The checked
exemptions boxes used to withhold information are further explained in the enclosed Explanation of Exemptions.
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
18 U.S.C. Section 3059(d)
(b)(7)(D)
(k)(2)
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
525 page(s) were reviewed and 0 page(s) are being released.
Below you will also find additional informational paragraphs about your request. Where applicable, check
boxes are used to provide you with more information about the processing of your request. Please read each item
carefully.
Document(s) were located which originated with, or contained information concerning, other
Government Agency [OGA].
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. § 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024061

=== Page 31 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the Freedom of Information Act (FOIA). See 5 U.S.C. § 552(c) (2006 & Supp. IV
(2010). This response is limited to those records that are subject to the requirements of the FOIA. This is a
standard notification given to all our requesters and should not be taken as an indication that excluded records do,
or do not, exist. Enclosed for your information is a copy of the Explanation of Exemptions.
Although your request is in litigation, we are required by law to provide you the following information:
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may submit
an appeal through OIP's FOIA online portal by creating an account on the following web
site: https://foiaonline.regulations.gov/foia/action/public/home. Your appeal must be postmarked or electronically
transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you submit your
appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act Appeal."
Please cite the FOIPA Request Number assigned to your request so that it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS) at 877-684-6448, or by emailing ogis@nara.gov. Alternatively, you may contact the FBI's FOIA Public
Liaison by emailing foipaquestions@fbi.gov. If you submit your dispute resolution correspondence by email, the
subject heading should clearly state "Dispute Resolution Services." Please also cite the FOIPA Request Number
assigned to your request so it may be easily identified.
The enclosed material is from the main investigative file(s), meaning the subject(s) of your request was
the focus of the investigation. Our search located additional references, in files relating to other
individuals, or matters, which may or may not be about your subject(s). Our experience has shown
such additional references, if identified to the same subject of the main investigative file, usually contain
information similar to the information processed in the main file(s). As such, we have given priority to
processing only the main investigative file(s) given our significant backlog. If you would like to receive
any references to the subject(s) of your request, please submit a separate request for the reference
material in writing. The references will be reviewed at a later date, as time and resources permit.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Records Management Division
Enclosure(s)
The enclosed documents contained in this release represent the fifth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
For questions regarding our determinations, visit the www.fbi.gov/foia website under "Contact Us."
The FOIPA Request Number listed above has been assigned to your request. Please use this number in all
correspondence concerning your request. Your patience is appreciated.
EFTA00024062

=== Page 32 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person who
furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024063

=== Page 33 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit H
EFTA00024064

=== Page 34 ===
U.S. Department of Justice
DUPARTMENT of Justice OF
FEDERAL BUREAU OF
Federal Bureau of Investigation
Washington, D.C. 20535
March 1, 2018
MR. DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Below you will find check boxes under the appropriate statute headings which indicate the types
of exemptions asserted to protect information which is exempt from disclosure. The appropriate exemptions are
noted on the enclosed pages next to redacted information. In addition, a deleted page information sheet was
inserted to indicate where pages were withheld entirely and identify which exemptions were applied. The checked
exemptions boxes used to withhold information are further explained in the enclosed Explanation of Exemptions.
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
18 U.S.C. Section 3059(d)
(b)(7)(D)
(k)(2)
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
527 page(s) were reviewed and 8 page(s) are being released.
Below you will also find additional informational paragraphs about your request. Where applicable, check
boxes are used to provide you with more information about the processing of your request. Please read each item
carefully.
Document(s) were located which originated with, or contained information concerning, other
Government Agency [OGA].
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024065

=== Page 35 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the Freedom of Information Act (FOIA). See 5 U.S.C. § 552(c) (2006 & Supp. IV
(2010). This response is limited to those records that are subject to the requirements of the FOIA. This is a
standard notification given to all our requesters and should not be taken as an indication that excluded records do,
or do not, exist. Enclosed for your information is a copy of the Explanation of Exemptions.
Although your request is in litigation, we are required by law to provide you the following information:
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may submit
an appeal through OIP's FOIA online portal by creating an account on the following web
site: https://foiaonline.regulations.gov/foia/action/public/home. Your appeal must be postmarked or electronically
transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you submit your
appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act Appeal."
Please cite the FOIPA Request Number assigned to your request so that it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS) at 877-684-6448, or by emailing ogis@nara.gov. Alternatively, you may contact the FBI's FOIA Public
Liaison by emailing foipaquestions@fbi.gov. If you submit your dispute resolution correspondence by email, the
subject heading should clearly state "Dispute Resolution Services." Please also cite the FOIPA Request Number
assigned to your request so it may be easily identified.
The enclosed material is from the main investigative file(s), meaning the subject(s) of your request was
the focus of the investigation. Our search located additional references, in files relating to other
individuals, or matters, which may or may not be about your subject(s). Our experience has shown
such additional references, if identified to the same subject of the main investigative file, usually contain
information similar to the information processed in the main file(s). As such, we have given priority to
processing only the main investigative file(s) given our significant backlog. If you would like to receive
any references to the subject(s) of your request, please submit a separate request for the reference
material in writing. The references will be reviewed at a later date, as time and resources permit.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Records Management Division
Enclosure(s)
The enclosed documents contained in this release represent the sixth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
For questions regarding our determinations, visit the www.fbi.gov/foia website under "Contact Us."
The FOIPA Request Number listed above has been assigned to your request. Please use this number in all
correspondence concerning your request. Your patience is appreciated.
EFTA00024066

=== Page 36 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person who
furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024067

=== Page 37 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit I
EFTA00024068

=== Page 38 ===
U.S. Department of Justice
INSURANCE OF
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
March 30, 2018
MR. DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Below you will find check boxes under the appropriate statute headings which indicate the types
of exemptions asserted to protect information which is exempt from disclosure. The appropriate exemptions are
noted on the enclosed pages next to redacted information. In addition, a deleted page information sheet was
inserted to indicate where pages were withheld entirely and identify which exemptions were applied. The checked
exemptions boxes used to withhold information are further explained in the enclosed Explanation of Exemptions.
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
18 U.S.C. Section 3509(d)
(b)(7)(D)
(k)(2)
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
520 page(s) were reviewed and 0 page(s) are being released.
Below you will also find additional informational paragraphs about your request. Where applicable, check
boxes are used to provide you with more information about the processing of your request. Please read each item
carefully.
Document(s) were located which originated with, or contained information concerning, other
Government Agency [OGA].
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024069

=== Page 39 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the Freedom of Information Act (FOIA). See 5 U.S.C. § 552(c) (2006 & Supp. IV
(2010). This response is limited to those records that are subject to the requirements of the FOIA. This is a
standard notification given to all our requesters and should not be taken as an indication that excluded records do,
or do not, exist. Enclosed for your information is a copy of the Explanation of Exemptions.
Although your request is in litigation, we are required by law to provide you the following information:
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may submit
an appeal through OIP's FOIA online portal by creating an account on the following web
site: https://foiaonline.regulations.gov/foia/action/public/home. Your appeal must be postmarked or electronically
transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you submit your
appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act Appeal."
Please cite the FOIPA Request Number assigned to your request so that it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS) at 877-684-6448, or by emailing ogis@nara.gov. Alternatively, you may contact the FBI's FOIA Public
Liaison by emailing foipaquestions@fbi.gov. If you submit your dispute resolution correspondence by email, the
subject heading should clearly state "Dispute Resolution Services." Please also cite the FOIPA Request Number
assigned to your request so it may be easily identified.
The enclosed material is from the main investigative file(s), meaning the subject(s) of your request was
the focus of the investigation. Our search located additional references, in files relating to other
individuals, or matters, which may or may not be about your subject(s). Our experience has shown
such additional references, if identified to the same subject of the main investigative file, usually contain
information similar to the information processed in the main file(s). As such, we have given priority to
processing only the main investigative file(s) given our significant backlog. If you would like to receive
any references to the subject(s) of your request, please submit a separate request for the reference
material in writing. The references will be reviewed at a later date, as time and resources permit.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Records Management Division
Enclosure(s)
The enclosed documents contained in this release represent the seventh interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
For questions regarding our determinations, visit the www.fbi.gov/foia website under "Contact Us."
The FOIPA Request Number listed above has been assigned to your request. Please use this number in all
correspondence concerning your request. Your patience is appreciated.
EFTA00024070

=== Page 40 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person who
furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024071

=== Page 41 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit J
EFTA00024072

=== Page 42 ===
U.S. Department of Justice
DEPARTMENT of JusTice OF
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
May 1, 2018
MR. DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Below you will find check boxes under the appropriate statute headings which indicate the types
of exemptions asserted to protect information which is exempt from disclosure. The appropriate exemptions are
noted on the enclosed pages next to redacted information. In addition, a deleted page information sheet was
inserted to indicate where pages were withheld entirely and identify which exemptions were applied. The checked
exemptions boxes used to withhold information are further explained in the enclosed Explanation of Exemptions.
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
18 U.S.C. Section 3509(d);
(b)(7)(D)
(k)(2)
Federal Rules of Criminal
(b)(7)(E)
(k)(3)
Procedure, Rule 6(e)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
567 page(s) were reviewed and 0 page(s) are being released.
Below you will also find additional informational paragraphs about your request. Where applicable, check
boxes are used to provide you with more information about the processing of your request. Please read each item
carefully.
Document(s) were located which originated with, or contained information concerning, other
Government Agency [OGA].
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
EFTA00024073

=== Page 43 ===
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. § 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the Freedom of Information Act (FOIA). See 5 U.S.C. $ 552(c) (2006 & Supp. IV
(2010). This response is limited to those records that are subject to the requirements of the FOIA. This is a
standard notification given to all our requesters and should not be taken as an indication that excluded records do,
or do not, exist. Enclosed for your information is a copy of the Explanation of Exemptions.
Although your request is in litigation, we are required by law to provide you the following information:
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may
submit an appeal through OIP's FOIAonline portal by creating an account on the following
website: https://foiaonline.regulations.gov/foia/action/public/home. Your appeal must be postmarked or
electronically transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you
submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act
Appeal." Please cite the FOIPA Request Number assigned to your request so it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS) at 877-684-6448, or by emailing ogis@nara.gov. Alternatively, you may contact the FBI's FOIA Public
Liaison by emailing foipaquestions@fbi.gov. If you submit your dispute resolution correspondence by email, the
subject heading should clearly state "Dispute Resolution Services." Please also cite the FOIPA Request Number
assigned to your request so it may be easily identified.
The enclosed material is from the main investigative file(s), meaning the subject(s) of your request was
the focus of the investigation. Our search located additional references, in files relating to other
individuals, or matters, which may or may not be about your subject(s). Our experience has shown
such additional references, if identified to the same subject of the main investigative file, usually contain
information similar to the information processed in the main file(s). As such, we have given priority to
processing only the main investigative file(s) given our significant backlog. If you would like to receive
any references to the subject(s) of your request, please submit a separate request for the reference
material in writing. The references will be reviewed at a later date, as time and resources permit.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Records Management Division
Enclosure(s)
The enclosed documents contained in this release represent the eighth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
For questions regarding our determinations, visit the www.fbi.gov/foia website under "Contact Us." The
FOIPA Request Number listed above has been assigned to your request. Please use this number in all
correspondence concerning your request. Your patience is appreciated.
EFTA00024074

=== Page 44 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person who
furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024075

=== Page 45 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit K
EFTA00024076

=== Page 46 ===
U.S. Department of Justice
DEPARTMENT of Juance OF
FEDERAL BUREAU OF
Federal Bureau of Investigation
Washington, D.C. 20535
June 1, 2018
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d);
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
574 pages were reviewed and 0 pages are being released.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. § 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024077

=== Page 47 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the FOIA. See 5 U.S. C. § 552(c) (2006 & Supp. IV (2010). This response is
limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is given
to all our requesters and should not be taken as an indication that excluded records do, or do not, exist. Enclosed for
your information is a copy of the Explanation of Exemptions.
Although your request is in litigation, we are required by law to provide you the following information:
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may submit
an appeal through OIP's FOIAonline portal by creating an account on the following website:
https://foiaonline.regulations.gov/foia/action/public/home Your appeal must be postmarked or electronically
transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you submit your
appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act Appeal."
Please cite the FOIPA Request Number assigned to your request so it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS) at 877-684-6448, or by emailing ogis@nara.gov. Alternatively, you may contact the FBI's FOIA Public Liaison
by emailing foipaquestions@fbi.gov. If you submit your dispute resolution correspondence by email, the subject
heading should clearly state "Dispute Resolution Services."
The enclosed material is from the main investigative file(s) in which the subject(s) of your request was the
focus of the investigation. Our search located additional references, in files relating to other individuals, or
matters, which may or may not be about your subject(s). Our experience has shown when ident, references
usually contain information similar to the information processed in the main file(s). Because of our significant
backlog, we have given priority to processing only the main investigative file(s). If you want the references, you
must submit a separate request for them in writing, and they will be reviewed at a later date, as time and resources
permit.
See additional information which follows.
Sincerely,
Blutz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Records Management Division
Enclosures
The enclosed documents contained in this release represent the nineth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
EFTA00024078

=== Page 48 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024079

=== Page 49 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit L
EFTA00024080

=== Page 50 ===
U.S. Department of Justice
DURATMENT of JusTice OF
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
July 2, 2018
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d);
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
547 pages were reviewed and 0 pages are being released.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. § 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024081

=== Page 51 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the FOIA. See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). This response is
limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is
given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.
Enclosed for your information is a copy of the Explanation of Exemptions.
Although your request is in litigation, we are required by law to provide you the following information:
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may submit
an appeal through OIP's FOIAonline portal by creating an account on the following website:
https://oiaonline.regulations.gov/foia/action/public/home Your appeal must be postmarked or electronically
transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you submit your
appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act Appeal."
Please cite the FOIPA Request Number assigned to your request so it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS) at 877-684-6448, or by emailing ogis@nara.gov. Alternatively, you may contact the FBI's FOIA Public Liaison
by emailing foipaquestions@fbi.gov. If you submit your dispute resolution correspondence by email, the subject
heading should clearly state "Dispute Resolution Services."
The enclosed material is from the main investigative file(s) in which the subject(s) of your request was the
focus of the investigation. Our search located additional references, in files relating to other individuals, or
matters, which may or may not be about your subject(s). Our experience has shown when ident, references
usually contain information similar to the information processed in the main file(s). Because of our significant
backlog, we have given priority to processing only the main investigative file(s). If you want the references, you
must submit a separate request for them in writing, and they will be reviewed at a later date, as time and resources
permit.
See additional information which follows.
Sincerely,
Blutz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Records Management Division
Enclosures
The enclosed documents contained in this release represent the tenth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
EFTA00024082

=== Page 52 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024083

=== Page 53 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit M
EFTA00024084

=== Page 54 ===
U.S. Department of Justice
DEPARTMENT of Juance OF
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
August 1, 2018
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d);
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
526 pages were reviewed and 0 pages are being released.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024085

=== Page 55 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the FOIA. See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). This response is
limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is
given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.
Enclosed for your information is a copy of the Explanation of Exemptions.
Although your request is in litigation, we are required by law to provide you the following information:
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may submit
an appeal through OIP's FOIAonline portal by creating an account on the following website:
https:/foiaonline.regulations.gov/foia/action/public/home. Your appeal must be postmarked or electronically
transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you submit your
appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act Appeal."
Please cite the FOIPA Request Number assigned to your request so it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS) at 877-684-6448, or by emailing ogis@nara.gov. Alternatively, you may contact the FBI's FOIA Public Liaison
by emailing foipaquestions@fbi.gov. If you submit your dispute resolution correspondence by email, the subject
heading should clearly state "Dispute Resolution Services."
The enclosed material is from the main investigative file(s) in which the subject(s) of your request was the
focus of the investigation. Our search located additional references, in files relating to other individuals, or
matters, which may or may not be about your subject(s). Our experience has shown when ident, references
usually contain information similar to the information processed in the main file(s). Because of our significant
backlog, we have given priority to processing only the main investigative file(s). If you want the references, you
must submit a separate request for them in writing, and they will be reviewed at a later date, as time and resources
permit.
See additional information which follows.
Sincerely,
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Records Management Division
Enclosures
The enclosed documents contained in this release represent the eleventh interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
EFTA00024086

=== Page 56 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024087

=== Page 57 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit N
EFTA00024088

=== Page 58 ===
U.S. Department of Justice
INSURANCE OF
FEDERAL BUREAU OF
Federal Bureau of Investigation
Washington, D.C. 20535
August 31, 2018
MR. DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d)
18 U.S.C. Section 5038
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
508 pages were reviewed and 160 pages are being released.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024089

=== Page 59 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the FOIA. See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). This response is
limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is
given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.
Enclosed for your information is a copy of the Explanation of Exemptions.
Although your request is in litigation, we are required by law to provide you the following information:
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may submit
an appeal through OIP's FOIAonline portal by creating an account on the following website:
https://oiaonline.regulations.gov/foia/action/public/home. Your appeal must be postmarked or electronically
transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you submit your
appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act Appeal."
Please cite the FOIPA Request Number assigned to your request so it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS) at 877-684-6448, or by emailing ogis@nara.gov. Alternatively, you may contact the FBI's FOIA Public Liaison
by emailing foipaquestions@fbi.gov. If you submit your dispute resolution correspondence by email, the subject
heading should clearly state "Dispute Resolution Services."
The enclosed material is from the main investigative file(s) in which the subject(s) of your request was the
focus of the investigation. Our search located additional references, in files relating to other individuals, or
matters, which may or may not be about your subject(s). Our experience has shown when ident, references
usually contain information similar to the information processed in the main file(s). Because of our significant
backlog, we have given priority to processing only the main investigative file(s). If you want the references, you
must submit a separate request for them in writing, and they will be reviewed at a later date, as time and resources
permit.
See additional information which follows.
Sincerely,
Blutz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Records Management Division
Enclosures
The enclosed documents contained in this release represent the twelfth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
EFTA00024090

=== Page 60 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024091

=== Page 61 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit O
EFTA00024092

=== Page 62 ===
U.S. Department of Justice
INSURANCE OF
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
September 28, 2018
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIPA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d);
Rule 6(e) FRCP
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
532 pages were reviewed and 0 pages are being released.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/jj)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024093

=== Page 63 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the FOIA. See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). This response is
limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is
given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.
Enclosed for your information is a copy of the Explanation of Exemptions.
Although your request is in litigation, we are required by law to provide you the following information:
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may submit
an appeal through OIP's FOIAonline portal by creating an account on the following website:
https://foiaonline.regulations.gov/foia/action/public/home Your appeal must be postmarked or electronically
transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you submit your
appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act Appeal."
Please cite the FOIPA Request Number assigned to your request so it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS) at 877-684-6448, or by emailing ogis@nara.gov. Alternatively, you may contact the FBI's FOIA Public Liaison
by emailing foipaquestions@fbi.gov. If you submit your dispute resolution correspondence by email, the subject
heading should clearly state "Dispute Resolution Services."
The enclosed material is from the main investigative file(s) in which the subject(s) of your request was the
focus of the investigation. Our search located additional references, in files relating to other individuals, or
matters, which may or may not be about your subject(s). Our experience has shown when ident, references
usually contain information similar to the information processed in the main file(s). Because of our significant
backlog, we have given priority to processing only the main investigative file(s). If you want the references, you
must submit a separate request for them in writing, and they will be reviewed at a later date, as time and resources
permit.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Records Management Division
Enclosures
The enclosed documents contained in this release represent the thirteenth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
EFTA00024094

=== Page 64 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024095

=== Page 65 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit P
EFTA00024096

=== Page 66 ===
U.S. Department of Justice
INSURANCE OF
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
October 31, 2018
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d);
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
500 pages were reviewed and 174 pages are being released.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. § 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024097

=== Page 67 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the FOIA. See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). This response is
limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is
given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.
Enclosed for your information is a copy of the Explanation of Exemptions.
Please direct any further inquiries about this case to the attorney representing the Government in this
matter. Please use the FOIA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
The enclosed material is from the main investigative file(s) in which the subject(s) of your request was the
focus of the investigation. Our search located additional references, in files relating to other individuals, or
matters, which may or may not be about your subject(s). Our experience has shown when ident, references
usually contain information similar to the information processed in the main file(s). Because of our significant
backlog, we have given priority to processing only the main investigative file(s). If you want the references, you
must submit a separate request for them in writing, and they will be reviewed at a later date, as time and resources
permit.
See additional information which follows.
Sincerely,
Blutz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures
The enclosed documents contained in this release represent the fourteenth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
EFTA00024098

=== Page 68 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024099

=== Page 69 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit
Q
EFTA00024100

=== Page 70 ===
U.S. Department of Justice
DEPARTMENT OF of Justice
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
November 30, 2018
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d);
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
518 pages were reviewed and 7 pages are being released.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. § 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024101

=== Page 71 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the FOIA. See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). This response is
limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is
given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.
Enclosed for your information is a copy of the Explanation of Exemptions.
Please direct any further inquiries about this case to the attorney representing the Government in this
matter. Please use the FOIA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
The enclosed material is from the main investigative file(s) in which the subject(s) of your request was the
focus of the investigation. Our search located additional references, in files relating to other individuals, or
matters, which may or may not be about your subject(s). Our experience has shown when ident, references
usually contain information similar to the information processed in the main file(s). Because of our significant
backlog, we have given priority to processing only the main investigative file(s). If you want the references, you
must submit a separate request for them in writing, and they will be reviewed at a later date, as time and resources
permit.
See additional information which follows.
Sincerely,
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures
The enclosed documents contained in this release represent the fifteenth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
EFTA00024102

=== Page 72 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024103

=== Page 73 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit R
EFTA00024104

=== Page 74 ===
U.S. Department of Justice
DUPARTMENT of Juance OF
FEDERAL BUREAU OF
Federal Bureau of Investigation
Washington, D.C. 20535
December 28, 2018
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d);
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
519 pages were reviewed and 4 pages are being released.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024105

=== Page 75 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the FOIA. See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). This response is
limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is
given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.
Enclosed for your information is a copy of the Explanation of Exemptions.
Please direct any further inquiries about this case to the attorney representing the Government in this
matter. Please use the FOIA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
The enclosed material is from the main investigative file(s) in which the subject(s) of your request was the
focus of the investigation. Our search located additional references, in files relating to other individuals, or
matters, which may or may not be about your subject(s). Our experience has shown when ident, references
usually contain information similar to the information processed in the main file(s). Because of our significant
backlog, we have given priority to processing only the main investigative file(s). If you want the references, you
must submit a separate request for them in writing, and they will be reviewed at a later date, as time and resources
permit.
See additional information which follows.
Sincerely,
Duetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures
The enclosed documents contained in this release represent the sixteenth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
EFTA00024106

=== Page 76 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024107

=== Page 77 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit S
EFTA00024108

=== Page 78 ===
U.S. Department of Justice
DUPARTMENT OF of Justice
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
March 1, 2019
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d);
Rule 6(e) FRCP
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
574 pages were reviewed and 209 pages are being released.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/jj)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024109

=== Page 79 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the FOIA. See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). This response is
limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is
given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.
Enclosed for your information is a copy of the Explanation of Exemptions.
Please direct any further inquiries about this case to the attorney representing the Government in this
matter. Please use the FOIA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
The enclosed material is from the main investigative file(s) in which the subject(s) of your request was the
focus of the investigation. Our search located additional references, in files relating to other individuals, or
matters, which may or may not be about your subject(s). Our experience has shown when ident, references
usually contain information similar to the information processed in the main file(s). Because of our significant
backlog, we have given priority to processing only the main investigative file(s). If you want the references, you
must submit a separate request for them in writing, and they will be reviewed at a later date, as time and resources
permit.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures
The enclosed documents contained in this release represent the seventeenth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
To minimize costs to you and the FBI, duplicate copies of the same document were not processed.
EFTA00024110

=== Page 80 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024111

=== Page 81 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit T
EFTA00024112

=== Page 82 ===
U.S. Department of Justice
UNITED OF
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
April 1, 2019
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d);
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
515 pages were reviewed and 232 pages are being released.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/jj)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024113

=== Page 83 ===
For your information, Congress excluded three discrete categories of law enforcement and national security
records from the requirements of the FOIA. See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). This response is
limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is
given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.
Enclosed for your information is a copy of the Explanation of Exemptions.
Please direct any further inquiries about this case to the attorney representing the Government in this
matter. Please use the FOIA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
The enclosed material is from the main investigative file(s) in which the subject(s) of your request was the
focus of the investigation. Our search located additional references, in files relating to other individuals, or
matters, which may or may not be about your subject(s). Our experience has shown when ident, references
usually contain information similar to the information processed in the main file(s). Because of our significant
backlog, we have given priority to processing only the main investigative file(s). If you want the references, you
must submit a separate request for them in writing, and they will be reviewed at a later date, as time and resources
permit.
See additional information which follows.
Sincerely,
Blutz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures
The enclosed documents contained in this release represent the eighteenth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
To minimize costs to you and the FBI, duplicate copies of the same document were not processed.
EFTA00024114

=== Page 84 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024115

=== Page 85 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit U
EFTA00024116

=== Page 86 ===
U.S. Department of Justice
DUPARTMENT OF JUSTICE OF
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
May 1, 2019
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d);
Rule 6(e) FRCP
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
540 pages were reviewed and 65 pages are being released.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/jj)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024117

=== Page 87 ===
Please refer to the enclosed FBI FOIPA Addendum for additional standard responses applicable to your
request. The "Standard Responses to Requests" section of the Addendum applies to all requests. If the subject
of your request is a person, the "Standard Responses to Requests for Individuals" section also applies. The
"General Information" section includes useful information about FBI records.
Please direct any further inquiries about this case to the attorney representing the Government in this
matter. Please use the FOIA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures(s)
The enclosed documents contained in this release represent the nineteenth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
To minimize costs to you and the FBI, duplicate copies of the same document were not processed.
EFTA00024118

=== Page 88 ===
FBI FOIPA Addendum
As referenced in our letter, the FBI FOIPA Addendum includes information applicable to your request. Part 1 of the
Addendum includes standard responses that apply to all requests. If you submitted a request regarding yourself or another
person, Part 2 includes additional standard responses that apply to requests for individuals. If you have questions regarding
the standard responses in Parts 1 or 2, visit the www.fbi.gov/foia website under "Contact Us." Previously mentioned appeal
and dispute resolution services are also available. Part 3 includes general information about FBI records that you may find
useful.
Part 1: Standard Responses to All Requests: See Below for all Requests
(i)
5 U.S.C. § 552(c). Congress excluded three categories of law enforcement and national security records from the
requirements of the Freedom of Information Act (FOIA). See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). FBI responses
are limited to those records subject to the requirements of the FOIA. Additional information about the FBI and the FOIPA
can be found on the fbi.gov website.
(ii)
National Security/Intelligence Records. The FBI can neither confirm nor deny the existence of national security and
foreign intelligence records pursuant to FOIA exemptions (b)(1) and (b)(3) and PA exemption (j)(2) as applicable to requests
for records about individuals [5 U.S.C. §§ 552/552a (b)(1), (b3), and (j)(2); 50 U.S.C § 3024(i)(1)]. The mere
acknowledgment of the existence or nonexistence of such records is itself a classified fact protected by FOIA exemption (b)(1)
and/or would reveal intelligence sources, methods, or activities protected by exemption (b)(3); 50 USC $ 3024(i)(1). This is
a standard response and should not be read to indicate that national security or foreign intelligence records do or do not
exist.
Part 2: Standard Responses to Requests for Individuals: See Below for all Requests for Individuals
(i)
Requests for Records about any Individual-Watch Lists. The FBI can neither confirm nor deny the existence of
any individual's name on a watch list pursuant to FOIA exemption (b)(7)(E) and PA exemption (j)(2) [5 U.S.C. §§
552/552a (b)(7)(E), (j)(2]. This is a standard response and should not be read to indicate that watch list records do or
do not exist.
(ii)
Requests for Records for Incarcerated Individuals. The FBI can neither confirm nor deny the existence of records
which could reasonably be expected to endanger the life or physical safety of any incarcerated individual pursuant to
FOIA exemptions (b)(7)(E) and (b)(7)(F) and PA exemption (j)(2) [5 U.S.C. §§ 552/552a (b)(7)(E), (b)(7)(F), and (j)(2)].
This is a standard response and should not be read to indicate that such records do or do not exist.
Part 3: General Information:
(i)
Record Searches. The Record/Information Dissemination Section (RIDS) searches for reasonably described records by
searching those systems or locations where responsive records would reasonably be found. Most requests are satisfied by
searching the Central Record System (CRS), an extensive system of records consisting of applicant, investigative,
intelligence, personnel, administrative, and general files compiled and maintained by the FBI in the course of fulfilling its
dual law enforcement and intelligence mission as well as the performance of agency administrative and personnel
functions. The CRS spans the entire FBI organization and encompasses the records of FBI Headquarters ("FBIHQ"), FBI
Field Offices, and FBI Legal Attaché Offices ("Legats") worldwide. A CRS search includes Electronic Surveillance (ELSUR)
records.
(ii)
FBI Records
Founded in 1908, the FBI carries out a dual law enforcement and national security mission. As part of this dual mission,
the FBI creates and maintains records on various subjects; however, the FBI does not maintain records on every person,
subject, or entity.
(iii)
Requests for Criminal History Records or "Rap Sheets." The Criminal Justice Information Services (CJIS) Division
provides Identity History Summary Checks -often referred to as a criminal history record or "rap sheets." These
criminal history records are not the same as material in an investigative "FBI file." An Identity History Summary Check
is a listing of information taken from fingerprint cards and documents submitted to the FBI in connection with arrests,
federal employment, naturalization, or military service. For a fee, individuals can request a copy of their Identity History
Summary Check. Forms and directions can be accessed at www.fbi.gov/about-us/cjis/identity-history-summary-checks.
Additionally, requests can be submitted electronically at www.edo.cjis.gov. For additional information, please contact
CJIS directly at (304) 625-5590.
The National Name Check Program (NNCP). The mission of NNCP is to analyze and report information in response to name check
requests received from federal agencies, for the purpose of protecting the United States from foreign and domestic threats to national
security. Please be advised that this is a service provided to other federal agencies. Private citizens cannot request a name check.
EFTA00024119

=== Page 89 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024120

=== Page 90 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit V
EFTA00024121

=== Page 91 ===
U.S. Department of Justice
DURATMENT of Justice OF
FEDERAL BUREAU OF
Federal Bureau of Investigation
Washington, D.C. 20535
May 31, 2019
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information Act (FOIA), Title 5, United States
Code, Section 552. Deletions have been made to protect information which is exempt from disclosure, with the
appropriate exemptions noted on the page next to the excision. In addition, a deleted page information sheet was
inserted in the file to indicate where pages were withheld entirely. The exemptions used to withhold information are
marked below and explained on the enclosed Explanation of Exemptions:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d)
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
519 pages were reviewed and 12 pages are being released.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024122

=== Page 92 ===
Please refer to the enclosed FBI FOIPA Addendum for additional standard responses applicable to your
request. The "Standard Responses to Requests" section of the Addendum applies to all requests. If the subject
of your request is a person, the "Standard Responses to Requests for Individuals" section also applies. The
"General Information" section includes useful information about FBI records.
Please direct any further inquiries about this case to the attorney representing the Government in this
matter. Please use the FOIA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures(s)
The enclosed documents contained in this release represent the twentieth interim release of information
responsive to your April 21, 2017 Freedom of Information Act (FOIA) request.
To minimize costs to you and the FBI, duplicate copies of the same document were not processed.
EFTA00024123

=== Page 93 ===
FBI FOIPA Addendum
As referenced in our letter, the FBI FOIPA Addendum includes information applicable to your request. Part 1 of the
Addendum includes standard responses that apply to all requests. If you submitted a request regarding yourself or another
person, Part 2 includes additional standard responses that apply to requests for individuals. If you have questions regarding
the standard responses in Parts 1 or 2, visit the www.fbi.gov/foia website under "Contact Us." Previously mentioned appeal
and dispute resolution services are also available. Part 3 includes general information about FBI records that you may find
useful.
Part 1: Standard Responses to All Requests: See Below for all Requests
(i)
5 U.S.C. § 552(c). Congress excluded three categories of law enforcement and national security records from the
requirements of the Freedom of Information Act (FOIA). See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). FBI responses
are limited to those records subject to the requirements of the FOIA. Additional information about the FBI and the FOIPA
can be found on the fbi.gov website.
(ii)
National Security/Intelligence Records. The FBI can neither confirm nor deny the existence of national security and
foreign intelligence records pursuant to FOIA exemptions (b)(1) and (b)(3) and PA exemption (j)(2) as applicable to requests
for records about individuals [5 U.S.C. §§ 552/552a (b)(1), (b3), and (j)(2); 50 U.S.C $ 3024(i)(1)]. The mere
acknowledgment of the existence or nonexistence of such records is itself a classified fact protected by FOIA exemption (b)(1)
and/or would reveal intelligence sources, methods, or activities protected by exemption (b)(3); 50 USC $ 3024(i)(1). This is
a standard response and should not be read to indicate that national security or foreign intelligence records do or do not
exist.
Part 2: Standard Responses to Requests for Individuals: See Below for all Requests for Individuals
(i)
Requests for Records about any Individual-Watch Lists. The FBI can neither confirm nor deny the existence of
any individual's name on a watch list pursuant to FOIA exemption (b)(7)(E) and PA exemption (j)(2) [5 U.S.C. §§
552/552a (b)(7)(E), (j)(2]. This is a standard response and should not be read to indicate that watch list records do or
do not exist.
(ii)
Requests for Records for Incarcerated Individuals. The FBI can neither confirm nor deny the existence of records
which could reasonably be expected to endanger the life or physical safety of any incarcerated individual pursuant to
FOIA exemptions (b)(7)(E) and (b)(7)(F) and PA exemption (j)(2) [5 U.S.C. §§ 552/552a (b)(7)(E), (b)(7)(F), and (j)(2)].
This is a standard response and should not be read to indicate that such records do or do not exist.
Part 3: General Information:
(i)
Record Searches. The Record/Information Dissemination Section (RIDS) searches for reasonably described records by
searching those systems or locations where responsive records would reasonably be found. Most requests are satisfied by
searching the Central Record System (CRS), an extensive system of records consisting of applicant, investigative,
intelligence, personnel, administrative, and general files compiled and maintained by the FBI in the course of fulfilling its
dual law enforcement and intelligence mission as well as the performance of agency administrative and personnel
functions. The CRS spans the entire FBI organization and encompasses the records of FBI Headquarters ("FBIHQ"), FBI
Field Offices, and FBI Legal Attaché Offices ("Legats") worldwide. A CRS search includes Electronic Surveillance (ELSUR)
records.
(ii)
FBI Records
Founded in 1908, the FBI carries out a dual law enforcement and national security mission. As part of this dual mission,
the FBI creates and maintains records on various subjects; however, the FBI does not maintain records on every person,
subject, or entity.
(iii)
Requests for Criminal History Records or "Rap Sheets." The Criminal Justice Information Services (CJIS) Division
provides Identity History Summary Checks -often referred to as a criminal history record or "rap sheets." These
criminal history records are not the same as material in an investigative "FBI file." An Identity History Summary Check
is a listing of information taken from fingerprint cards and documents submitted to the FBI in connection with arrests,
federal employment, naturalization, or military service. For a fee, individuals can request a copy of their Identity History
Summary Check. Forms and directions can be accessed at www.fbi.gov/about-us/cjis/identity-history-summary-checks.
Additionally, requests can be submitted electronically at www.edo.cjis.gov. For additional information, please contact
CJIS directly at (304) 625-5590.
The National Name Check Program (NNCP). The mission of NNCP is to analyze and report information in response to name check
requests received from federal agencies, for the purpose of protecting the United States from foreign and domestic threats to national
security. Please be advised that this is a service provided to other federal agencies. Private citizens cannot request a name check.
EFTA00024124

=== Page 94 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024125

=== Page 95 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit W
EFTA00024126

=== Page 96 ===
U.S. Department of Justice
DUPARTMENT of JusTice OF
FEDERAL BUREAU OF
Federal Bureau of Investigation
Washington, D.C. 20535
June 28, 2019
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information/Privacy Acts (FOIPA), Title 5,
United States Code, Section 552/552a. Below you will find checked boxes under applicable statutes for the
exemptions asserted to protect information exempt from disclosure. The appropriate exemptions are noted on the
processed pages next to redacted information. In addition, a deleted page information sheet was inserted to indicate
where pages were withheld entirely pursuant to applicable exemptions. An Explanation of Exemptions is enclosed to
further explain justification for withheld information.
:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d)
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
527 pages were reviewed and 107 pages are being released.
Please see the paragraphs below for relevant information specific to your request and the enclosed FBI
FOIPA Addendum for standard responses applicable to all requests.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024127

=== Page 97 ===
Please refer to the enclosed FBI FOIPA Addendum for additional standard responses applicable to your
request. "Part 1" of the Addendum includes standard responses that apply to all requests. "Part 2" includes
additional standard responses that apply to all requests for records on individuals. "Part 3" includes general
information about FBI records that you may find useful. Also enclosed is our Explanation of Exemptions.
Please direct any further inquiries about this case to the Attorney representing the Government in this
matter. Please use the FOIPA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
See additional information which follows.
Sincerely,
Blutz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures(s)
The enclosed documents contained in this release represent the twenty-first interim release of information
responsive to your April 21, 2017 FOIPA request.
To minimize costs to you and the FBI, duplicate copies of the same document were not processed.
EFTA00024128

=== Page 98 ===
FBI FOIPA Addendum
As referenced in our letter, the FBI FOIPA Addendum includes information applicable to your request. Part 1 of the
Addendum includes standard responses that apply to all requests. If you submitted a request regarding yourself or another
person, Part 2 includes additional standard responses that apply to requests for individuals. If you have questions regarding
the standard responses in Parts 1 or 2, visit the www.fbi.gov/foia website under "Contact Us." Previously mentioned appeal
and dispute resolution services are also available. Part 3 includes general information about FBI records that you may find
useful.
Part 1: Standard Responses to All Requests: See Below for all Requests
(i)
5 U.S.C. § 552(c). Congress excluded three categories of law enforcement and national security records from the
requirements of the Freedom of Information Act (FOIA). See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). FBI responses
are limited to those records subject to the requirements of the FOIA. Additional information about the FBI and the FOIPA
can be found on the fbi.gov website.
(ii)
National Security/Intelligence Records. The FBI can neither confirm nor deny the existence of national security and
foreign intelligence records pursuant to FOIA exemptions (b)(1) and (b)(3) and PA exemption (j)(2) as applicable to requests
for records about individuals [5 U.S.C. §§ 552/552a (b)(1), (b3), and (j)(2); 50 U.S.C $ 3024(i)(1)]. The mere
acknowledgment of the existence or nonexistence of such records is itself a classified fact protected by FOIA exemption (b)(1)
and/or would reveal intelligence sources, methods, or activities protected by exemption (b)(3); 50 USC $ 3024(i)(1). This is
a standard response and should not be read to indicate that national security or foreign intelligence records do or do not
exist.
Part 2: Standard Responses to Requests for Individuals: See Below for all Requests for Individuals
(i)
Requests for Records about any Individual-Watch Lists. The FBI can neither confirm nor deny the existence of
any individual's name on a watch list pursuant to FOIA exemption (b)(7)(E) and PA exemption (j)(2) [5 U.S.C. §§
552/552a (b)(7)(E), (j)(2]. This is a standard response and should not be read to indicate that watch list records do or
do not exist.
(ii)
Requests for Records for Incarcerated Individuals. The FBI can neither confirm nor deny the existence of records
which could reasonably be expected to endanger the life or physical safety of any incarcerated individual pursuant to
FOIA exemptions (b)(7)(E) and (b)(7)(F) and PA exemption (j)(2) [5 U.S.C. §§ 552/552a (b)(7)(E), (b)(7)(F), and (j)(2)].
This is a standard response and should not be read to indicate that such records do or do not exist.
Part 3: General Information:
(i)
Record Searches. The Record/Information Dissemination Section (RIDS) searches for reasonably described records by
searching those systems or locations where responsive records would reasonably be found. Most requests are satisfied by
searching the Central Record System (CRS), an extensive system of records consisting of applicant, investigative,
intelligence, personnel, administrative, and general files compiled and maintained by the FBI in the course of fulfilling its
dual law enforcement and intelligence mission as well as the performance of agency administrative and personnel
functions. The CRS spans the entire FBI organization and encompasses the records of FBI Headquarters ("FBIHQ"), FBI
Field Offices, and FBI Legal Attaché Offices ("Legats") worldwide. A CRS search includes Electronic Surveillance (ELSUR)
records.
(ii)
FBI Records
Founded in 1908, the FBI carries out a dual law enforcement and national security mission. As part of this dual mission,
the FBI creates and maintains records on various subjects; however, the FBI does not maintain records on every person,
subject, or entity.
(iii)
Requests for Criminal History Records or "Rap Sheets." The Criminal Justice Information Services (CJIS) Division
provides Identity History Summary Checks -often referred to as a criminal history record or "rap sheets." These
criminal history records are not the same as material in an investigative "FBI file." An Identity History Summary Check
is a listing of information taken from fingerprint cards and documents submitted to the FBI in connection with arrests,
federal employment, naturalization, or military service. For a fee, individuals can request a copy of their Identity History
Summary Check. Forms and directions can be accessed at www.fbi.gov/about-us/cjis/identity-history-summary-checks.
Additionally, requests can be submitted electronically at www.edo.cjis.gov. For additional information, please contact
CJIS directly at (304) 625-5590.
The National Name Check Program (NNCP). The mission of NNCP is to analyze and report information in response to name check
requests received from federal agencies, for the purpose of protecting the United States from foreign and domestic threats to national
security. Please be advised that this is a service provided to other federal agencies. Private citizens cannot request a name check.
EFTA00024129

=== Page 99 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024130

=== Page 100 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit X
EFTA00024131

=== Page 101 ===
U.S. Department of Justice
OF
FEDERAL BUREAU OF I
Federal Bureau of Investigation
Washington, D.C. 20535
August 1, 2019
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The FBI carefully examined records under the Freedom of Information/Privacy Acts (FOIPA), Title 5, United
States Code, Section 552/552a. The FBI determined the information is exempt from disclosure pursuant to FOIA
Exemptions (b)(7)(A), (b)(7)(B), and also asserted the exemptions indicated below as additional grounds for
withholding the information. An Explanation of Exemptions is enclosed to further explain justification for withheld
information.
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d)
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
Please see the paragraphs below for relevant information specific to your request and the enclosed FBI
FOIPA Addendum for standard responses applicable to all requests.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024132

=== Page 102 ===
Please refer to the enclosed FBI FOIPA Addendum for additional standard responses applicable to your
request. "Part 1" of the Addendum includes standard responses that apply to all requests. "Part 2" includes
additional standard responses that apply to all requests for records on individuals. "Part 3" includes general
information about FBI records that you may find useful. Also enclosed is our Explanation of Exemptions.
Please direct any further inquiries about this case to the Attorney representing the Government in this
matter. Please use the FOIPA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
See additional information which follows.
Sincerely,
Duetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures(s)
The enclosed documents contained in this release represent the twenty-second interim release of
information responsive to your April 21, 2017 FOIPA request.
EFTA00024133

=== Page 103 ===
FBI FOIPA Addendum
As referenced in our letter, the FBI FOIPA Addendum includes information applicable to your request. Part 1 of the
Addendum includes standard responses that apply to all requests. If you submitted a request regarding yourself or another
person, Part 2 includes additional standard responses that apply to requests for individuals. If you have questions regarding
the standard responses in Parts 1 or 2, visit the www.fbi.gov/foia website under "Contact Us." Previously mentioned appeal
and dispute resolution services are also available. Part 3 includes general information about FBI records that you may find
useful.
Part 1: Standard Responses to All Requests: See Below for all Requests
(i)
5 U.S.C. § 552(c). Congress excluded three categories of law enforcement and national security records from the
requirements of the Freedom of Information Act (FOIA). See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). FBI responses
are limited to those records subject to the requirements of the FOIA. Additional information about the FBI and the FOIPA
can be found on the fbi.gov website.
(ii)
National Security/Intelligence Records. The FBI can neither confirm nor deny the existence of national security and
foreign intelligence records pursuant to FOIA exemptions (b)(1) and (b)(3) and PA exemption (j)(2) as applicable to requests
for records about individuals [5 U.S.C. §§ 552/552a (b)(1), (b3), and (j)(2); 50 U.S.C $ 3024(i)(1)]. The mere
acknowledgment of the existence or nonexistence of such records is itself a classified fact protected by FOIA exemption (b)(1)
and/or would reveal intelligence sources, methods, or activities protected by exemption (b)(3); 50 USC $ 3024(i)(1). This is
a standard response and should not be read to indicate that national security or foreign intelligence records do or do not
exist.
Part 2: Standard Responses to Requests for Individuals: See Below for all Requests for Individuals
(i)
Requests for Records about any Individual-Watch Lists. The FBI can neither confirm nor deny the existence of
any individual's name on a watch list pursuant to FOIA exemption (b)(7)(E) and PA exemption (j)(2) [5 U.S.C. §§
552/552a (b)(7)(E), (j)(2]. This is a standard response and should not be read to indicate that watch list records do or
do not exist.
(ii)
Requests for Records for Incarcerated Individuals. The FBI can neither confirm nor deny the existence of records
which could reasonably be expected to endanger the life or physical safety of any incarcerated individual pursuant to
FOIA exemptions (b)(7)(E) and (b)(7)(F) and PA exemption (j)(2) [5 U.S.C. §§ 552/552a (b)(7)(E), (b)(7)(F), and (j)(2)].
This is a standard response and should not be read to indicate that such records do or do not exist.
Part 3: General Information:
(i)
Record Searches. The Record/Information Dissemination Section (RIDS) searches for reasonably described records by
searching those systems or locations where responsive records would reasonably be found. Most requests are satisfied by
searching the Central Record System (CRS), an extensive system of records consisting of applicant, investigative,
intelligence, personnel, administrative, and general files compiled and maintained by the FBI in the course of fulfilling its
dual law enforcement and intelligence mission as well as the performance of agency administrative and personnel
functions. The CRS spans the entire FBI organization and encompasses the records of FBI Headquarters ("FBIHQ"), FBI
Field Offices, and FBI Legal Attaché Offices ("Legats") worldwide. A CRS search includes Electronic Surveillance (ELSUR)
records.
(ii)
FBI Records
Founded in 1908, the FBI carries out a dual law enforcement and national security mission. As part of this dual mission,
the FBI creates and maintains records on various subjects; however, the FBI does not maintain records on every person,
subject, or entity.
(iii)
Requests for Criminal History Records or "Rap Sheets." The Criminal Justice Information Services (CJIS) Division
provides Identity History Summary Checks -often referred to as a criminal history record or "rap sheets." These
criminal history records are not the same as material in an investigative "FBI file." An Identity History Summary Check
is a listing of information taken from fingerprint cards and documents submitted to the FBI in connection with arrests,
federal employment, naturalization, or military service. For a fee, individuals can request a copy of their Identity History
Summary Check. Forms and directions can be accessed at www.fbi.gov/about-us/cjis/identity-history-summary-checks.
Additionally, requests can be submitted electronically at www.edo.cjis.gov. For additional information, please contact
CJIS directly at (304) 625-5590.
(iv)
The National Name Check Program (NNCP). The mission of NNCP is to analyze and report information in response
to name check requests received from federal agencies, for the purpose of protecting the United States from foreign and
domestic threats to national security. Please be advised that this is a service provided to other federal agencies.
Private citizens cannot request a name check.
EFTA00024134

=== Page 104 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024135

=== Page 105 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit Y
EFTA00024136

=== Page 106 ===
U.S. Department of Justice
INSURANCE OF
FEDERAL BUREAU OF
Federal Bureau of Investigation
Washington, D.C. 20535
August 30, 2019
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The FBI carefully examined records under the Freedom of Information/Privacy Acts (FOIPA), Title 5, United
States Code, Section 552/552a. The FBI determined the information is exempt from disclosure pursuant to FOIA
Exemption (b)(7)(A), and also asserted the exemptions indicated below as additional grounds for withholding the
information. An Explanation of Exemptions is enclosed to further explain justification for withheld information.
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d)
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
Please see the paragraphs below for relevant information specific to your request and the enclosed FBI
FOIPA Addendum for standard responses applicable to all requests.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
In accordance with standard FBI practice and pursuant to FOIA exemption (b)(7)(E) and Privacy Act
exemption (j)(2) [5 U.S.C. $ 552/552a (b)(7)(E)/(j)(2)], this response neither confirms nor denies the
existence of your subject's name on any watch lists.
EFTA00024137

=== Page 107 ===
Please refer to the enclosed FBI FOIPA Addendum for additional standard responses applicable to your
request. "Part 1" of the Addendum includes standard responses that apply to all requests. "Part 2" includes
additional standard responses that apply to all requests for records on individuals. "Part 3" includes general
information about FBI records that you may find useful. Also enclosed is our Explanation of Exemptions.
Although your request is in litigation, we are required by law to provide you with the following:
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may submit
an appeal through OIP's FOIA online portal by creating an account on the following
website: https://www.foiaonline.gov/foiaonline/action/public/home. Your appeal must be postmarked or
electronically transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you
submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act
Appeal." Please cite the FOIPA Request Number assigned to your request so it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS). The contact information for OGIS is as follows: Office of Government Information Services, National
Archives and Records Administration, 8601 Adelphi Road-OGIS, College Park, Maryland 20740-6001, e-mail at
ogis@nara.gov; telephone at 202-741-5770; toll free at 1-877-684-6448; or facsimile at 202-741-5769. Alternatively,
you may contact the FBI's FOIA Public Liaison by emailing foipaquestions@fbi.gov. If you submit your dispute
resolution correspondence by email, the subject heading should clearly state "Dispute Resolution Services." Please
also cite the FOIPA Request Number assigned to your request so it may be easily identified.
Please direct any further inquiries about this case to the Attorney representing the Government in this
matter. Please use the FOIPA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
See additional information which follows.
Sincerely,
Blutz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures(s)
The enclosed documents contained in this release represent the twenty-third interim release of information
responsive to your April 21, 2017 FOIPA request.
EFTA00024138

=== Page 108 ===
FBI FOIPA Addendum
As referenced in our letter, the FBI FOIPA Addendum includes information applicable to your request. Part 1 of the
Addendum includes standard responses that apply to all requests. If you submitted a request regarding yourself or another
person, Part 2 includes additional standard responses that apply to requests for individuals. If you have questions regarding
the standard responses in Parts 1 or 2, visit the www.fbi.gov/foia website under "Contact Us." Previously mentioned appeal
and dispute resolution services are also available. Part 3 includes general information about FBI records that you may find
useful.
Part 1: Standard Responses to All Requests: See Below for all Requests
(i)
5 U.S.C. § 552(c). Congress excluded three categories of law enforcement and national security records from the
requirements of the Freedom of Information Act (FOIA). See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). FBI responses
are limited to those records subject to the requirements of the FOIA. Additional information about the FBI and the FOIPA
can be found on the fbi.gov website.
(ii)
National Security/Intelligence Records. The FBI can neither confirm nor deny the existence of national security and
foreign intelligence records pursuant to FOIA exemptions (b)(1) and (b)(3) and PA exemption (j)(2) as applicable to requests
for records about individuals [5 U.S.C. §§ 552/552a (b)(1), (b3), and (j)(2); 50 U.S.C $ 3024(i)(1)]. The mere
acknowledgment of the existence or nonexistence of such records is itself a classified fact protected by FOIA exemption (b)(1)
and/or would reveal intelligence sources, methods, or activities protected by exemption (b)(3); 50 USC $ 3024(i)(1). This is
a standard response and should not be read to indicate that national security or foreign intelligence records do or do not
exist.
Part 2: Standard Responses to Requests for Individuals: See Below for all Requests for Individuals
(i)
Requests for Records about any Individual-Watch Lists. The FBI can neither confirm nor deny the existence of
any individual's name on a watch list pursuant to FOIA exemption (b)(7)(E) and PA exemption (j)(2) [5 U.S.C. §§
552/552a (b)(7)(E), (j)(2]. This is a standard response and should not be read to indicate that watch list records do or
do not exist.
(ii)
Requests for Records for Incarcerated Individuals. The FBI can neither confirm nor deny the existence of records
which could reasonably be expected to endanger the life or physical safety of any incarcerated individual pursuant to
FOIA exemptions (b)(7)(E) and (b)(7)(F) and PA exemption (j)(2) [5 U.S.C. §§ 552/552a (b)(7)(E), (b)(7)(F), and (j)(2)].
This is a standard response and should not be read to indicate that such records do or do not exist.
Part 3: General Information:
(i)
Record Searches. The Record/Information Dissemination Section (RIDS) searches for reasonably described records by
searching those systems or locations where responsive records would reasonably be found. Most requests are satisfied by
searching the Central Record System (CRS), an extensive system of records consisting of applicant, investigative,
intelligence, personnel, administrative, and general files compiled and maintained by the FBI in the course of fulfilling its
dual law enforcement and intelligence mission as well as the performance of agency administrative and personnel
functions. The CRS spans the entire FBI organization and encompasses the records of FBI Headquarters ("FBIHQ"), FBI
Field Offices, and FBI Legal Attaché Offices ("Legats") worldwide. A CRS search includes Electronic Surveillance (ELSUR)
records.
(ii)
FBI Records
Founded in 1908, the FBI carries out a dual law enforcement and national security mission. As part of this dual mission,
the FBI creates and maintains records on various subjects; however, the FBI does not maintain records on every person,
subject, or entity.
(iii)
Requests for Criminal History Records or "Rap Sheets." The Criminal Justice Information Services (CJIS) Division
provides Identity History Summary Checks -often referred to as a criminal history record or "rap sheets." These
criminal history records are not the same as material in an investigative "FBI file." An Identity History Summary Check
is a listing of information taken from fingerprint cards and documents submitted to the FBI in connection with arrests,
federal employment, naturalization, or military service. For a fee, individuals can request a copy of their Identity History
Summary Check. Forms and directions can be accessed at www.fbi.gov/about-us/cjis/identity-history-summary-checks.
Additionally, requests can be submitted electronically at www.edo.cjis.gov. For additional information, please contact
CJIS directly at (304) 625-5590.
(iv)
The National Name Check Program (NNCP). The mission of NNCP is to analyze and report information in response
to name check requests received from federal agencies, for the purpose of protecting the United States from foreign and
domestic threats to national security. Please be advised that this is a service provided to other federal agencies.
Private citizens cannot request a name check.
EFTA00024139

=== Page 109 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024140

=== Page 110 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit Z
EFTA00024141

=== Page 111 ===
U.S. Department of Justice
Student OF
FEDERAL BUREAU OF
Federal Bureau of Investigation
Washington, D.C. 20535
October 1, 2019
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The FBI carefully examined records under the Freedom of Information/Privacy Acts (FOIPA), Title 5, United
States Code, Section 552/552a. The FBI determined the information is exempt from disclosure pursuant to FOIA
Exemption (b)(7)(A) and also asserted the exemptions indicated below as additional grounds for withholding the
information. An Explanation of Exemptions is enclosed to further explain justification for withheld information.
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d)
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
Please see the paragraphs below for relevant information specific to your request and the enclosed FBI
FOIPA Addendum for standard responses applicable to all requests.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
Please refer to the enclosed FBI FOIPA Addendum for additional standard responses applicable to your
request. "Part 1" of the Addendum includes standard responses that apply to all requests. "Part 2" includes
additional standard responses that apply to all requests for records on individuals. "Part 3" includes general
information about FBI records that you may find useful. Also enclosed is our Explanation of Exemptions.
EFTA00024142

=== Page 112 ===
Although your request is in litigation, we are required by law to provide you with the following:
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may submit
an appeal through OIP's FOIA online portal by creating an account on the following
website: https://www.foiaonline.gov/foiaonline/action/public/home. Your appeal must be postmarked or
electronically transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you
submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act
Appeal." Please cite the FOIPA Request Number assigned to your request so it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS). The contact information for OGIS is as follows: Office of Government Information Services, National
Archives and Records Administration, 8601 Adelphi Road-OGIS, College Park, Maryland 20740-6001, e-mail at
ogis@nara.gov; telephone at 202-741-5770; toll free at 1-877-684-6448; or facsimile at 202-741-5769. Alternatively,
you may contact the FBI's FOIA Public Liaison by emailing foipaquestions@fbi.gov. If you submit your dispute
resolution correspondence by email, the subject heading should clearly state "Dispute Resolution Services." Please
also cite the FOIPA Request Number assigned to your request so it may be easily identified.
Please direct any further inquiries about this case to the Attorney representing the Government in this
matter. Please use the FOIPA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures(s)
The enclosed documents contained in this release represent the twenty-fourth interim release of information
responsive to your April 21, 2017 FOIPA request.
EFTA00024143

=== Page 113 ===
FBI FOIPA Addendum
As referenced in our letter, the FBI FOIPA Addendum includes information applicable to your request. Part 1 of the
Addendum includes standard responses that apply to all requests. If you submitted a request regarding yourself or another
person, Part 2 includes additional standard responses that apply to requests for individuals. If you have questions regarding
the standard responses in Parts 1 or 2, visit the www.fbi.gov/foia website under "Contact Us." Previously mentioned appeal
and dispute resolution services are also available. Part 3 includes general information about FBI records that you may find
useful.
Part 1: Standard Responses to All Requests: See Below for all Requests
(i)
5 U.S.C. § 552(c). Congress excluded three categories of law enforcement and national security records from the
requirements of the Freedom of Information Act (FOIA). See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). FBI responses
are limited to those records subject to the requirements of the FOIA. Additional information about the FBI and the FOIPA
can be found on the fbi.gov website.
(ii)
National Security/Intelligence Records. The FBI can neither confirm nor deny the existence of national security and
foreign intelligence records pursuant to FOIA exemptions (b)(1) and (b)(3) and PA exemption (j)(2) as applicable to requests
for records about individuals [5 U.S.C. §§ 552/552a (b)(1), (b3), and (j)(2); 50 U.S.C $ 3024(i)(1)]. The mere
acknowledgment of the existence or nonexistence of such records is itself a classified fact protected by FOIA exemption (b)(1)
and/or would reveal intelligence sources, methods, or activities protected by exemption (b)(3); 50 USC $ 3024(i)(1). This is
a standard response and should not be read to indicate that national security or foreign intelligence records do or do not
exist.
Part 2: Standard Responses to Requests for Individuals: See Below for all Requests for Individuals
(i)
Requests for Records about any Individual-Watch Lists. The FBI can neither confirm nor deny the existence of
any individual's name on a watch list pursuant to FOIA exemption (b)(7)(E) and PA exemption (j)(2) [5 U.S.C. §§
552/552a (b)(7)(E), (j)(2]. This is a standard response and should not be read to indicate that watch list records do or
do not exist.
(ii)
Requests for Records for Incarcerated Individuals. The FBI can neither confirm nor deny the existence of records
which could reasonably be expected to endanger the life or physical safety of any incarcerated individual pursuant to
FOIA exemptions (b)(7)(E) and (b)(7)(F) and PA exemption (j)(2) [5 U.S.C. §§ 552/552a (b)(7)(E), (b)(7)(F), and (j)(2)].
This is a standard response and should not be read to indicate that such records do or do not exist.
Part 3: General Information:
(i)
Record Searches. The Record/Information Dissemination Section (RIDS) searches for reasonably described records by
searching those systems or locations where responsive records would reasonably be found. Most requests are satisfied by
searching the Central Record System (CRS), an extensive system of records consisting of applicant, investigative,
intelligence, personnel, administrative, and general files compiled and maintained by the FBI in the course of fulfilling its
dual law enforcement and intelligence mission as well as the performance of agency administrative and personnel
functions. The CRS spans the entire FBI organization and encompasses the records of FBI Headquarters ("FBIHQ"), FBI
Field Offices, and FBI Legal Attaché Offices ("Legats") worldwide. A CRS search includes Electronic Surveillance (ELSUR)
records.
(ii)
FBI Records
Founded in 1908, the FBI carries out a dual law enforcement and national security mission. As part of this dual mission,
the FBI creates and maintains records on various subjects; however, the FBI does not maintain records on every person,
subject, or entity.
(iii)
Requests for Criminal History Records or "Rap Sheets." The Criminal Justice Information Services (CJIS) Division
provides Identity History Summary Checks -often referred to as a criminal history record or "rap sheets." These
criminal history records are not the same as material in an investigative "FBI file." An Identity History Summary Check
is a listing of information taken from fingerprint cards and documents submitted to the FBI in connection with arrests,
federal employment, naturalization, or military service. For a fee, individuals can request a copy of their Identity History
Summary Check. Forms and directions can be accessed at www.fbi.gov/about-us/cjis/identity-history-summary-checks.
Additionally, requests can be submitted electronically at www.edo.cjis.gov. For additional information, please contact
CJIS directly at (304) 625-5590.
(iv)
The National Name Check Program (NNCP). The mission of NNCP is to analyze and report information in response
to name check requests received from federal agencies, for the purpose of protecting the United States from foreign and
domestic threats to national security. Please be advised that this is a service provided to other federal agencies.
Private citizens cannot request a name check.
EFTA00024144

=== Page 114 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024145

=== Page 115 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit AA
EFTA00024146

=== Page 116 ===
U.S. Department of Justice
INSURANCE OF
TERMAN BUREAU OF
Federal Bureau of Investigation
Washington, D.C. 20535
November 1, 2019
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The FBI carefully examined records under the Freedom of Information/Privacy Acts (FOIPA), Title 5, United
States Code, Section 552/552a. The FBI determined the information is exempt from disclosure pursuant to FOIA
Exemption (b)(7)(A) and also asserted the exemptions indicated below as additional grounds for withholding the
information. An Explanation of Exemptions is enclosed to further explain justification for withheld information.
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d)
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
Please see the paragraphs below for relevant information specific to your request and the enclosed FBI
FOIPA Addendum for standard responses applicable to all requests.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
Please refer to the enclosed FBI FOIPA Addendum for additional standard responses applicable to your
request. "Part 1" of the Addendum includes standard responses that apply to all requests. "Part 2" includes
additional standard responses that apply to all requests for records on individuals. "Part 3" includes general
information about FBI records that you may find useful. Also enclosed is our Explanation of Exemptions.
Although your request is in litigation, we are required by law to provide you with the following:
EFTA00024147

=== Page 117 ===
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may submit
an appeal through OIP's FOIA online portal by creating an account on the following
website: https://www.foiaonline.gov/foiaonline/action/public/home. Your appeal must be postmarked or
electronically transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you
submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act
Appeal." Please cite the FOIPA Request Number assigned to your request so it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS). The contact information for OGIS is as follows: Office of Government Information Services, National
Archives and Records Administration, 8601 Adelphi Road-OGIS, College Park, Maryland 20740-6001, e-mail at
ogis@nara.gov; telephone at 202-741-5770; toll free at 1-877-684-6448; or facsimile at 202-741-5769. Alternatively,
you may contact the FBI's FOIA Public Liaison by emailing foipaquestions@fbi.gov. If you submit your dispute
resolution correspondence by email, the subject heading should clearly state "Dispute Resolution Services." Please
also cite the FOIPA Request Number assigned to your request so it may be easily identified.
Please direct any further inquiries about this case to the Attorney representing the Government in this
matter. Please use the FOIPA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures(s)
The enclosed documents contained in this release represent the twenty-fifth interim release of information
responsive to your April 21, 2017 FOIPA request.
EFTA00024148

=== Page 118 ===
FBI FOIPA Addendum
As referenced in our letter, the FBI FOIPA Addendum includes information applicable to your request. Part 1 of the
Addendum includes standard responses that apply to all requests. If you submitted a request regarding yourself or another
person, Part 2 includes additional standard responses that apply to requests for individuals. If you have questions regarding
the standard responses in Parts 1 or 2, visit the www.fbi.gov/foia website under "Contact Us." Previously mentioned appeal
and dispute resolution services are also available. Part 3 includes general information about FBI records that you may find
useful.
Part 1: Standard Responses to All Requests: See Below for all Requests
(i)
5 U.S.C. § 552(c). Congress excluded three categories of law enforcement and national security records from the
requirements of the Freedom of Information Act (FOIA). See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). FBI responses
are limited to those records subject to the requirements of the FOIA. Additional information about the FBI and the FOIPA
can be found on the fbi.gov website.
(ii)
National Security/Intelligence Records. The FBI can neither confirm nor deny the existence of national security and
foreign intelligence records pursuant to FOIA exemptions (b)(1) and (b)(3) and PA exemption (j)(2) as applicable to requests
for records about individuals [5 U.S.C. §§ 552/552a (b)(1), (b3), and (j)(2); 50 U.S.C $ 3024(i)(1)]. The mere
acknowledgment of the existence or nonexistence of such records is itself a classified fact protected by FOIA exemption (b)(1)
and/or would reveal intelligence sources, methods, or activities protected by exemption (b)(3); 50 USC $ 3024(i)(1). This is
a standard response and should not be read to indicate that national security or foreign intelligence records do or do not
exist.
Part 2: Standard Responses to Requests for Individuals: See Below for all Requests for Individuals
(i)
Requests for Records about any Individual-Watch Lists. The FBI can neither confirm nor deny the existence of
any individual's name on a watch list pursuant to FOIA exemption (b)(7)(E) and PA exemption (j)(2) [5 U.S.C. §§
552/552a (b)(7)(E), (j)(2]. This is a standard response and should not be read to indicate that watch list records do or
do not exist.
(ii)
Requests for Records for Incarcerated Individuals. The FBI can neither confirm nor deny the existence of records
which could reasonably be expected to endanger the life or physical safety of any incarcerated individual pursuant to
FOIA exemptions (b)(7)(E) and (b)(7)(F) and PA exemption (j)(2) [5 U.S.C. §§ 552/552a (b)(7)(E), (b)(7)(F), and (j)(2)].
This is a standard response and should not be read to indicate that such records do or do not exist.
Part 3: General Information:
(i)
Record Searches. The Record/Information Dissemination Section (RIDS) searches for reasonably described records by
searching those systems or locations where responsive records would reasonably be found. Most requests are satisfied by
searching the Central Record System (CRS), an extensive system of records consisting of applicant, investigative,
intelligence, personnel, administrative, and general files compiled and maintained by the FBI in the course of fulfilling its
dual law enforcement and intelligence mission as well as the performance of agency administrative and personnel
functions. The CRS spans the entire FBI organization and encompasses the records of FBI Headquarters ("FBIHQ"), FBI
Field Offices, and FBI Legal Attaché Offices ("Legats") worldwide. A CRS search includes Electronic Surveillance (ELSUR)
records.
(ii)
FBI Records
Founded in 1908, the FBI carries out a dual law enforcement and national security mission. As part of this dual mission,
the FBI creates and maintains records on various subjects; however, the FBI does not maintain records on every person,
subject, or entity.
(iii)
Requests for Criminal History Records or "Rap Sheets." The Criminal Justice Information Services (CJIS) Division
provides Identity History Summary Checks -often referred to as a criminal history record or "rap sheets." These
criminal history records are not the same as material in an investigative "FBI file." An Identity History Summary Check
is a listing of information taken from fingerprint cards and documents submitted to the FBI in connection with arrests,
federal employment, naturalization, or military service. For a fee, individuals can request a copy of their Identity History
Summary Check. Forms and directions can be accessed at www.fbi.gov/about-us/cjis/identity-history-summary-checks.
Additionally, requests can be submitted electronically at www.edo.cjis.gov. For additional information, please contact
CJIS directly at (304) 625-5590.
(iv)
The National Name Check Program (NNCP). The mission of NNCP is to analyze and report information in response
to name check requests received from federal agencies, for the purpose of protecting the United States from foreign and
domestic threats to national security. Please be advised that this is a service provided to other federal agencies.
Private citizens cannot request a name check.
EFTA00024149

=== Page 119 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024150

=== Page 120 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit BB
EFTA00024151

=== Page 121 ===
U.S. Department of Justice
DUPARTMENT OF JUSTICE OF
FEDERAL BUREAU OF
Federal Bureau of Investigation
Washington, D.C. 20535
November 27, 2019
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The FBI carefully examined records under the Freedom of Information/Privacy Acts (FOIPA), Title 5, United
States Code, Section 552/552a. The FBI determined the information is exempt from disclosure pursuant to FOIA
Exemption (b)(7)(A) and also asserted the exemptions indicated below as additional grounds for withholding the
information. An Explanation of Exemptions is enclosed to further explain justification for withheld information.
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d)
Federal Rule of Criminal
(b)(7)(E)
(k)(3)
Procedure, 6(e)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
Please see the paragraphs below for relevant information specific to your request and the enclosed FBI
FOIPA Addendum for standard responses applicable to all requests.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
Please refer to the enclosed FBI FOIPA Addendum for additional standard responses applicable to your
request. "Part 1" of the Addendum includes standard responses that apply to all requests. "Part 2" includes
additional standard responses that apply to all requests for records on individuals. "Part 3" includes general
information about FBI records that you may find useful. Also enclosed is our Explanation of Exemptions.
Although your request is in litigation, we are required by law to provide you with the following:
EFTA00024152

=== Page 122 ===
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may submit
an appeal through OIP's FOIA online portal by creating an account on the following
website: https://www.foiaonline.gov/foiaonline/action/public/home. Your appeal must be postmarked or
electronically transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you
submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act
Appeal." Please cite the FOIPA Request Number assigned to your request so it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS). The contact information for OGIS is as follows: Office of Government Information Services, National
Archives and Records Administration, 8601 Adelphi Road-OGIS, College Park, Maryland 20740-6001, e-mail at
ogis@nara.gov; telephone at 202-741-5770; toll free at 1-877-684-6448; or facsimile at 202-741-5769. Alternatively,
you may contact the FBI's FOIA Public Liaison by emailing foipaquestions@fbi.gov. If you submit your dispute
resolution correspondence by email, the subject heading should clearly state "Dispute Resolution Services." Please
also cite the FOIPA Request Number assigned to your request so it may be easily identified.
Please direct any further inquiries about this case to the Attorney representing the Government in this
matter. Please use the FOIPA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
See additional information which follows.
Sincerely,
Blutz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures(s)
The enclosed documents contained in this release represent the twenty-sixth interim release of information
responsive to your April 21, 2017 FOIPA request.
EFTA00024153

=== Page 123 ===
FBI FOIPA Addendum
As referenced in our letter, the FBI FOIPA Addendum includes information applicable to your request. Part 1 of the
Addendum includes standard responses that apply to all requests. If you submitted a request regarding yourself or another
person, Part 2 includes additional standard responses that apply to requests for individuals. If you have questions regarding
the standard responses in Parts 1 or 2, visit the www.fbi.gov/foia website under "Contact Us." Previously mentioned appeal
and dispute resolution services are also available. Part 3 includes general information about FBI records that you may find
useful.
Part 1: Standard Responses to All Requests: See Below for all Requests
(i)
5 U.S.C. § 552(c). Congress excluded three categories of law enforcement and national security records from the
requirements of the Freedom of Information Act (FOIA). See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). FBI responses
are limited to those records subject to the requirements of the FOIA. Additional information about the FBI and the FOIPA
can be found on the fbi.gov website.
(ii)
National Security/Intelligence Records. The FBI can neither confirm nor deny the existence of national security and
foreign intelligence records pursuant to FOIA exemptions (b)(1) and (b)(3) and PA exemption (j)(2) as applicable to requests
for records about individuals [5 U.S.C. §§ 552/552a (b)(1), (b3), and (j)(2); 50 U.S.C $ 3024(i)(1)]. The mere
acknowledgment of the existence or nonexistence of such records is itself a classified fact protected by FOIA exemption (b)(1)
and/or would reveal intelligence sources, methods, or activities protected by exemption (b)(3); 50 USC $ 3024(i)(1). This is
a standard response and should not be read to indicate that national security or foreign intelligence records do or do not
exist.
Part 2: Standard Responses to Requests for Individuals: See Below for all Requests for Individuals
(i)
Requests for Records about any Individual-Watch Lists. The FBI can neither confirm nor deny the existence of
any individual's name on a watch list pursuant to FOIA exemption (b)(7)(E) and PA exemption (j)(2) [5 U.S.C. §§
552/552a (b)(7)(E), (j)(2]. This is a standard response and should not be read to indicate that watch list records do or
do not exist.
(ii)
Requests for Records for Incarcerated Individuals. The FBI can neither confirm nor deny the existence of records
which could reasonably be expected to endanger the life or physical safety of any incarcerated individual pursuant to
FOIA exemptions (b)(7)(E) and (b)(7)(F) and PA exemption (j)(2) [5 U.S.C. §§ 552/552a (b)(7)(E), (b)(7)(F), and (j)(2)].
This is a standard response and should not be read to indicate that such records do or do not exist.
Part 3: General Information:
(i)
Record Searches. The Record/Information Dissemination Section (RIDS) searches for reasonably described records by
searching those systems or locations where responsive records would reasonably be found. Most requests are satisfied by
searching the Central Record System (CRS), an extensive system of records consisting of applicant, investigative,
intelligence, personnel, administrative, and general files compiled and maintained by the FBI in the course of fulfilling its
dual law enforcement and intelligence mission as well as the performance of agency administrative and personnel
functions. The CRS spans the entire FBI organization and encompasses the records of FBI Headquarters ("FBIHQ"), FBI
Field Offices, and FBI Legal Attaché Offices ("Legats") worldwide. A CRS search includes Electronic Surveillance (ELSUR)
records.
(ii)
FBI Records
Founded in 1908, the FBI carries out a dual law enforcement and national security mission. As part of this dual mission,
the FBI creates and maintains records on various subjects; however, the FBI does not maintain records on every person,
subject, or entity.
(iii)
Requests for Criminal History Records or "Rap Sheets." The Criminal Justice Information Services (CJIS) Division
provides Identity History Summary Checks -often referred to as a criminal history record or "rap sheets." These
criminal history records are not the same as material in an investigative "FBI file." An Identity History Summary Check
is a listing of information taken from fingerprint cards and documents submitted to the FBI in connection with arrests,
federal employment, naturalization, or military service. For a fee, individuals can request a copy of their Identity History
Summary Check. Forms and directions can be accessed at www.fbi.gov/about-us/cjis/identity-history-summary-checks.
Additionally, requests can be submitted electronically at www.edo.cjis.gov. For additional information, please contact
CJIS directly at (304) 625-5590.
(iv)
The National Name Check Program (NNCP). The mission of NNCP is to analyze and report information in response
to name check requests received from federal agencies, for the purpose of protecting the United States from foreign and
domestic threats to national security. Please be advised that this is a service provided to other federal agencies.
Private citizens cannot request a name check.
EFTA00024154

=== Page 124 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024155

=== Page 125 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit CC
EFTA00024156

=== Page 126 ===
U.S. Department of Justice
DEPARTMENT of Juance OF
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
December 31, 2019
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The FBI carefully examined records under the Freedom of Information/Privacy Acts (FOIPA), Title 5, United
States Code, Section 552/552a. The FBI determined the information is exempt from disclosure pursuant to FOIA
Exemption (b)(7)(A) and also asserted the exemptions indicated below as additional grounds for withholding the
information. An Explanation of Exemptions is enclosed to further explain justification for withheld information.
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
18 U.S.C. Section 3509(d)
Federal Rule of Criminal
(b)(7)(E)
(k)(3)
Procedure, 6(e)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
Please see the paragraphs below for relevant information specific to your request and the enclosed FBI
FOIPA Addendum for standard responses applicable to all requests.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
Please refer to the enclosed FBI FOIPA Addendum for additional standard responses applicable to your
request. "Part 1" of the Addendum includes standard responses that apply to all requests. "Part 2" includes
additional standard responses that apply to all requests for records on individuals. "Part 3" includes general
information about FBI records that you may find useful. Also enclosed is our Explanation of Exemptions.
Although your request is in litigation, we are required by law to provide you with the following:
EFTA00024157

=== Page 127 ===
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you may submit
an appeal through OIP's FOIA online portal by creating an account on the following
website: https://www.foiaonline.gov/foiaonline/action/public/home. Your appeal must be postmarked or
electronically transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you
submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act
Appeal." Please cite the FOIPA Request Number assigned to your request so it may be easily identified.
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS). The contact information for OGIS is as follows: Office of Government Information Services, National
Archives and Records Administration, 8601 Adelphi Road-OGIS, College Park, Maryland 20740-6001, e-mail at
ogis@nara.gov; telephone at 202-741-5770; toll free at 1-877-684-6448; or facsimile at 202-741-5769. Alternatively,
you may contact the FBI's FOIA Public Liaison by emailing foipaquestions@fbi.gov. If you submit your dispute
resolution correspondence by email, the subject heading should clearly state "Dispute Resolution Services." Please
also cite the FOIPA Request Number assigned to your request so it may be easily identified.
Please direct any further inquiries about this case to the Attorney representing the Government in this
matter. Please use the FOIPA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
See additional information which follows.
Sincerely,
Blutz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures(s)
The enclosed documents contained in this release represent the twenty-seventh interim release of
information responsive to your April 21, 2017 FOIPA request.
EFTA00024158

=== Page 128 ===
FBI FOIPA Addendum
As referenced in our letter, the FBI FOIPA Addendum includes information applicable to your request. Part 1 of the
Addendum includes standard responses that apply to all requests. If you submitted a request regarding yourself or another
person, Part 2 includes additional standard responses that apply to requests for individuals. If you have questions regarding
the standard responses in Parts 1 or 2, visit the www.fbi.gov/foia website under "Contact Us." Previously mentioned appeal
and dispute resolution services are also available. Part 3 includes general information about FBI records that you may find
useful.
Part 1: Standard Responses to All Requests: See Below for all Requests
(i)
5 U.S.C. § 552(c). Congress excluded three categories of law enforcement and national security records from the
requirements of the Freedom of Information Act (FOIA). See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). FBI responses
are limited to those records subject to the requirements of the FOIA. Additional information about the FBI and the FOIPA
can be found on the fbi.gov website.
(ii)
National Security/Intelligence Records. The FBI can neither confirm nor deny the existence of national security and
foreign intelligence records pursuant to FOIA exemptions (b)(1) and (b)(3) and PA exemption (j)(2) as applicable to requests
for records about individuals [5 U.S.C. §§ 552/552a (b)(1), (b3), and (j)(2); 50 U.S.C $ 3024(i)(1)]. The mere
acknowledgment of the existence or nonexistence of such records is itself a classified fact protected by FOIA exemption (b)(1)
and/or would reveal intelligence sources, methods, or activities protected by exemption (b)(3); 50 USC $ 3024(i)(1). This is
a standard response and should not be read to indicate that national security or foreign intelligence records do or do not
exist.
Part 2: Standard Responses to Requests for Individuals: See Below for all Requests for Individuals
(i)
Requests for Records about any Individual-Watch Lists. The FBI can neither confirm nor deny the existence of
any individual's name on a watch list pursuant to FOIA exemption (b)(7)(E) and PA exemption (j)(2) [5 U.S.C. §§
552/552a (b)(7)(E), (j)(2]. This is a standard response and should not be read to indicate that watch list records do or
do not exist.
(ii)
Requests for Records for Incarcerated Individuals. The FBI can neither confirm nor deny the existence of records
which could reasonably be expected to endanger the life or physical safety of any incarcerated individual pursuant to
FOIA exemptions (b)(7)(E) and (b)(7)(F) and PA exemption (j)(2) [5 U.S.C. §§ 552/552a (b)(7)(E), (b)(7)(F), and (j)(2)].
This is a standard response and should not be read to indicate that such records do or do not exist.
Part 3: General Information:
(i)
Record Searches. The Record/Information Dissemination Section (RIDS) searches for reasonably described records by
searching those systems or locations where responsive records would reasonably be found. Most requests are satisfied by
searching the Central Record System (CRS), an extensive system of records consisting of applicant, investigative,
intelligence, personnel, administrative, and general files compiled and maintained by the FBI in the course of fulfilling its
dual law enforcement and intelligence mission as well as the performance of agency administrative and personnel
functions. The CRS spans the entire FBI organization and encompasses the records of FBI Headquarters ("FBIHQ"), FBI
Field Offices, and FBI Legal Attaché Offices ("Legats") worldwide. A CRS search includes Electronic Surveillance (ELSUR)
records.
(ii)
FBI Records
Founded in 1908, the FBI carries out a dual law enforcement and national security mission. As part of this dual mission,
the FBI creates and maintains records on various subjects; however, the FBI does not maintain records on every person,
subject, or entity.
(iii)
Requests for Criminal History Records or "Rap Sheets." The Criminal Justice Information Services (CJIS) Division
provides Identity History Summary Checks -often referred to as a criminal history record or "rap sheets." These
criminal history records are not the same as material in an investigative "FBI file." An Identity History Summary Check
is a listing of information taken from fingerprint cards and documents submitted to the FBI in connection with arrests,
federal employment, naturalization, or military service. For a fee, individuals can request a copy of their Identity History
Summary Check. Forms and directions can be accessed at www.fbi.gov/about-us/cjis/identity-history-summary-checks.
Additionally, requests can be submitted electronically at www.edo.cjis.gov. For additional information, please contact
CJIS directly at (304) 625-5590.
(iv)
The National Name Check Program (NNCP). The mission of NNCP is to analyze and report information in response
to name check requests received from federal agencies, for the purpose of protecting the United States from foreign and
domestic threats to national security. Please be advised that this is a service provided to other federal agencies.
Private citizens cannot request a name check.
EFTA00024159

=== Page 129 ===
EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
EFTA00024160

=== Page 130 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
Exhibit DD
EFTA00024161

=== Page 131 ===
U.S. Department of Justice
DUPARTMENT OF JUSTICE OF
FEDERAL BUREAU of
Federal Bureau of Investigation
Washington, D.C. 20535
January 31, 2020
MR DANIEL NOVACK
ON BEHALF OF RADAR ONLINE
LAW OFFICE OF DANIEL R. NOVACK
6 GLENWILD ROAD
MADISON, NJ 07940
Civil Action No.: 17-cv-03956
FOIA Request No.: 1372398-000
Subject: EPSTEIN, JEFFREY
Dear Mr. Novack:
The enclosed documents were reviewed under the Freedom of Information/Privacy Acts (FOIPA), Title 5,
United States Code, Section 552/552a. Below you will find checked boxes under applicable statutes for the
exemptions asserted to protect information exempt from disclosure. The appropriate exemptions are noted on the
processed pages next to redacted information. In addition, a deleted page information sheet was inserted to indicate
where pages were withheld entirely pursuant to applicable exemptions. An Explanation of Exemptions is enclosed to
further explain justification for withheld information.
:
Section 552
Section 552a
(b)(1)
(b)(7)(A)
(d)(5)
(b)(2)
(b)(7)(B)
(j)(2)
(b)(3)
(b)(7)(C)
(k)(1)
(b)(7)(D)
(k)(2)
(b)(7)(E)
(k)(3)
(b)(7)(F)
(k)(4)
(b)(4)
(b)(8)
(k)(5)
(b)(5)
(b)(9)
(k)(6)
(b)(6)
(k)(7)
46 pages are being released.
Please see the paragraphs below for relevant information specific to your request and the enclosed FBI
FOIPA Addendum for standard responses applicable to all requests.
Documents were located which originated with, or contained information concerning, other Government
Agencies.
This information has been referred to the OGA(s) for review and direct response to you.
We are consulting with another agency. The FBI will correspond with you regarding this information
when the consultation is completed.
Please refer to the enclosed FBI FOIPA Addendum for additional standard responses applicable to your
request. "Part 1" of the Addendum includes standard responses that apply to all requests. "Part 2" includes
additional standard responses that apply to all requests for records on individuals. "Part 3" includes general
information about FBI records that you may find useful. Also enclosed is our Explanation of Exemptions.
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Please direct any further inquiries about this case to the Attorney representing the Government in this
matter. Please use the FOIPA Request Number and/or Civil Action Number in all correspondence or inquiries
concerning your request.
See additional information which follows.
Sincerely,
Bluetz
David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division
Enclosures(s)
The enclosed documents represent the twenty-eighth and final release of information responsive to your
April 21, 2017 FOIPA request.
To minimize costs to you and the FBI, duplicate copies of the same document were not processed.
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FBI FOIPA Addendum
As referenced in our letter, the FBI FOIPA Addendum includes information applicable to your request. Part 1 of the
Addendum includes standard responses that apply to all requests. If you submitted a request regarding yourself or another
person, Part 2 includes additional standard responses that apply to requests for individuals. If you have questions regarding
the standard responses in Parts 1 or 2, visit the www.fbi.gov/foia website under "Contact Us." Previously mentioned appeal
and dispute resolution services are also available. Part 3 includes general information about FBI records that you may find
useful.
Part 1: Standard Responses to All Requests: See Below for all Requests
(i)
5 U.S.C. § 552(c). Congress excluded three categories of law enforcement and national security records from the
requirements of the Freedom of Information Act (FOIA). See 5 U.S. C. $ 552(c) (2006 & Supp. IV (2010). FBI responses
are limited to those records subject to the requirements of the FOIA. Additional information about the FBI and the FOIPA
can be found on the fbi.gov website.
(ii)
National Security/Intelligence Records. The FBI can neither confirm nor deny the existence of national security and
foreign intelligence records pursuant to FOIA exemptions (b)(1) and (b)(3) and PA exemption (j)(2) as applicable to requests
for records about individuals [5 U.S.C. §§ 552/552a (b)(1), (b3), and (j)(2); 50 U.S.C § 3024(i)(1)]. The mere
acknowledgment of the existence or nonexistence of such records is itself a classified fact protected by FOIA exemption (b)(1)
and/or would reveal intelligence sources, methods, or activities protected by exemption (b)(3); 50 USC $ 3024(i)(1). This is
a standard response and should not be read to indicate that national security or foreign intelligence records do or do not
exist.
Part 2: Standard Responses to Requests for Individuals: See Below for all Requests for Individuals
(i)
Requests for Records about any Individual-Watch Lists. The FBI can neither confirm nor deny the existence of
any individual's name on a watch list pursuant to FOIA exemption (b)(7)(E) and PA exemption (j)(2) [5 U.S.C. §§
552/552a (b)(7)(E), (j)(2]. This is a standard response and should not be read to indicate that watch list records do or
do not exist.
(ii)
Requests for Records for Incarcerated Individuals. The FBI can neither confirm nor deny the existence of records
which could reasonably be expected to endanger the life or physical safety of any incarcerated individual pursuant to
FOIA exemptions (b)(7)(E) and (b)(7)(F) and PA exemption (j)(2) [5 U.S.C. §§ 552/552a (b)(7)(E), (b)(7)(F), and (j)(2)].
This is a standard response and should not be read to indicate that such records do or do not exist.
Part 3: General Information:
(i)
Record Searches. The Record/Information Dissemination Section (RIDS) searches for reasonably described records by
searching those systems or locations where responsive records would reasonably be found. Most requests are satisfied by
searching the Central Record System (CRS), an extensive system of records consisting of applicant, investigative,
intelligence, personnel, administrative, and general files compiled and maintained by the FBI in the course of fulfilling its
dual law enforcement and intelligence mission as well as the performance of agency administrative and personnel
functions. The CRS spans the entire FBI organization and encompasses the records of FBI Headquarters ("FBIHQ"), FBI
Field Offices, and FBI Legal Attaché Offices ("Legats") worldwide. A CRS search includes Electronic Surveillance (ELSUR)
records.
(ii)
FBI Records
Founded in 1908, the FBI carries out a dual law enforcement and national security mission. As part of this dual mission,
the FBI creates and maintains records on various subjects; however, the FBI does not maintain records on every person,
subject, or entity.
(iii)
Requests for Criminal History Records or "Rap Sheets." The Criminal Justice Information Services (CJIS) Division
provides Identity History Summary Checks -often referred to as a criminal history record or "rap sheets." These
criminal history records are not the same as material in an investigative "FBI file." An Identity History Summary Check
is a listing of information taken from fingerprint cards and documents submitted to the FBI in connection with arrests,
federal employment, naturalization, or military service. For a fee, individuals can request a copy of their Identity History
Summary Check. Forms and directions can be accessed at www.fbi.gov/about-us/cjis/identity-history-summary-checks.
Additionally, requests can be submitted electronically at www.edo.cjis.gov. For additional information, please contact
CJIS directly at (304) 625-5590.
The National Name Check Program (NNCP). The mission of NNCP is to analyze and report information in response to name check
requests received from federal agencies, for the purpose of protecting the United States from foreign and domestic threats to national
security. Please be advised that this is a service provided to other federal agencies. Private citizens cannot request a name check.
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EXPLANATION OF EXEMPTIONS
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552
(b)(1)
(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign
policy and (B) are in fact properly classified to such Executive order;
(b)(2)
related solely to the internal personnel rules and practices of an agency;
(b)(3)
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters
be withheld from the public in such a manner as to leave no discretion on issue, or (B) establishes particular criteria for withholding or refers
to particular types of matters to be withheld;
(b)(4)
trade secrets and commercial or financial information obtained from a person and privileged or confidential;
(b)(5)
inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with
the agency;
(b)(6)
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
(b)(7)
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or
information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair
trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could
reasonably be expected to disclose the identity of confidential source, including a State, local, or foreign agency or authority or any private
institution which furnished information on a confidential basis, and, in the case of record or information compiled by a criminal law
enforcement authority in the course of a criminal investigation, or by an agency conducting a lawful national security intelligence
investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could
reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any
individual;
(b)(8)
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for
the regulation or supervision of financial institutions; or
(b)(9)
geological and geophysical information and data, including maps, concerning wells.
SUBSECTIONS OF TITLE 5, UNITED STATES CODE, SECTION 552a
(d)(5)
information compiled in reasonable anticipation of a civil action proceeding;
(j)(2)
material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime
or apprehend criminals;
(k)(1)
information which is currently and properly classified pursuant to an Executive order in the interest of the national defense or foreign policy,
for example, information involving intelligence sources or methods;
(k)(2)
investigatory material compiled for law enforcement purposes, other than criminal, which did not result in loss of a right, benefit or privilege
under Federal programs, or which would identify a source who furnished information pursuant to a promise that his/her identity would be
held in confidence;
(k)(3)
material maintained in connection with providing protective services to the President of the United States or any other individual pursuant to
the authority of Title 18, United States Code, Section 3056;
(k)(4)
required by statute to be maintained and used solely as statistical records;
(k)(5)
investigatory material compiled solely for the purpose of determining suitability, eligibility, or qualifications for Federal civilian
employment or for access to classified information, the disclosure of which would reveal the identity of the person who furnished
information pursuant to a promise that his/her identity would be held in confidence;
(k)(6)
testing or examination material used to determine individual qualifications for appointment or promotion in Federal Government service he
release of which would compromise the testing or examination process;
(k)(7)
material used to determine potential for promotion in the armed services, the disclosure of which would reveal the identity of the person
who furnished the material pursuant to a promise that his/her identity would be held in confidence.
FBI/DOJ
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