# docs_fts_content

c1: EFTA00014380
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014380.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: US V. Epstein (SW database)
Date: Fri, 13 Nov 2020 20:07:13 +0000
Hi
and
I hope you're both well! I just wanted to follow up with you both, as I hadn't received an answer from
yet and
wanted to make sure the drives (below) were dealt with today if they're time-sensitive. I received both drives today in the
mail from PAE, and both appear to contain the same materials. Do they need to be copied or sent out?
Thank you!
From:
(USANYS) [Contractor]
Sent: Friday, November 13, 2020 12:35 PM
To:
Subject: RE: US V. Epstein (SW database)
Hi
Just received these two hard drives from PAE. Would you like me to handle next steps? And is this time-sensitive? Thanks!
Happy to chat about this over email or phone
CB
From:
Sent: Tuesday, November 10, 2020 12:21 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS)
>;
)
Subject: Re: US V. Epstein (SW database)
Please send them to
at 1 St Andrews. Thank you
On Nov 10, 2020, at 12:07 PM,
(USANYS) [Contractor]
wrote:
Hello,
All of the productions (production 15 & 16) has been copied to both hard drives. Please let me know who should receive
the hard drives?
Thank you.
From:
Sent: Thursday, November 5, 2020 3:07 PM
To:
(USANYS) [Contractor]
>;
(USANYS)
is
is
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: US V. Epstein (SW database)
Thank you very much.
From:
(USANYS) [Contractor]
Sent: Thursday, November 5, 2020 10:32 AM
To:
)
>;
(USANYS)
i
)
is
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: US V. Epstein (SW database)
Good Morning,
EFTA00014380

=== Page 2 ===
I wanted to let you know that the vendor has finished the stamping of part 5 of the production. Parts 1 - 3 have been
exported from Relativity. The vendor will start the stamping of part 6 of the production shortly.
The vendor has also been able to load the data for the USAO-SDFL files into the other Epstein database:
Please review and let me know if there are any questions.
Thank you.
From:
Sent: Wednesday, November 4, 2020 7:01 PM
To:
(USANYS) [Contractor]
>;
(USANYS)
is
in
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: US V. Epstein (SW database)
Thank you very much,
Looking on Relativity, it appears that part 4 is at least stamped now, which puts us more
than halfway through the stamping. We are planning to ask Judge Nathan for an extension, but given how quickly the
stamping and export appeared to go today, I am hopeful that this may be ready sooner than the November 19th date
we've been discussing.
From:
(USANYS) [Contractor]
Sent: Wednesday, November 4, 2020 11:54 AM
To:
)
>;
(USANYS)
>;
)
>;
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: US V. Epstein (SW database)
Hello,
The vendor had to break up the production into seven parts. As of right now the vendor has finished parts 1- - 3 and is
about to start on the stamping of documents for part 4. The vendor has exported part one to the hard drive and is
currently working on exporting part to two the hard drive right now. Part three just finished about 10 minutes ago and
the export has not started yet. You can review the productions by going to the following searches:
If there are any questions please let me know.
Thank you.
EFTA00014381


c1: EFTA00015963
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015963.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Jack Scarola
Cc: Wetjets
Mary McCann
)"
"
(NY) (FBI)"
Subject: RE:
Date: Thu, 16 Jul 2020 16:41:47 +0000
Jack,
This is very helpful, thanks. We'll be logging into the WebEx individually, primarily so you and your client can most clearly
see the face of whoever is speaking on our end, and we'll explain up front that our discussion will proceed based on the
comfort level of Ms.
at all times. Looking forward to being in touch tomorrow morning, and thanks again.
From: Jack Scarola
Sent: Thursday, July 16, 2020 10:37
To:
Cc: Wetjets
>; Mary McCann
is
)
>;
is
(NY) (FBI)
is
>
Subject: Re:
-
I look forward to our video meeting tomorrow.
Mike, and I will be together (socially distancing)
in a conference room in my office. I am available to talk in advance if that may be helpful.
(
)
Below is a list of persons with whom
interacted in her contact with Epstein. This will probably assist
you in organizing your interview.
- brought
over 1st time.
ex boyfriend of
- Had been with
but
drove
and her to
Epstein Palm Beach residence.
knew
and
going over to Epstein house. (In past
dealings with
I have found him to be less than fully cooperative and less than completely reliable)
ex boyfriend, drove over to Epstein house once or twice in beginning
Ghislaine Maxwell- met about 10 times at Epstein. Saw nude photos of Ghislaine
took her there 1 time,
stayed outside of room while
with Epstein
went with her several times to Epstein house
Called
many times to make appointments and
arrangements. Acted like secretary
thinks she saw her there
2 times
Some older man came over to Epstein's house and
Epstein 1 time while another girl was with them.
- may have been leaving once when
arriving.
- saw him at house
male drivers from Epstein picked her up about 50 times and brought her to house.
Epstein- saw her over 100 times.
, Epstein
several times.
EFTA00015963

=== Page 2 ===
2 housekeeping couples -saw
often. One couple quit as did not want to be there.
Cooks -saw her many times and gave her food in kitchen.
Sent from my iPad
On Jul 15, 2020, at 8:05 PM,
)
wrote:
Jack, Mike,
Thanks very much again for being in touch, and for your assistance with this progress. We will send information to log in
via WebEx, our video conference program, which is secure and has worked well for us so far. The only thing we need is
the email address or any other attendees, so I'm going to include the following email addresses (realizing that you likely
will not log on using all of them), but please let us know if you need us to include any other email addresses for logging
on:
And please let us know if either of you would like to chat tomorrow in advance of the discussion, otherwise we'll look
forward to seeing you electronically on Friday at 9:30.
thanks,
From: Jack Scarola
Sent: Tuesday, July 14, 2020 13:37
To: Wetjets
Cc:
>; Mary McCann
Subject: Re:
That will work.
Mr.
Please provide details as to how you want to handle the connection.
On Jul 14, 2020, at 12:26 PM, Wetjets
wrote:
Jack
I am confirming Friday 7/17/20 at 9:30AM for
to be at your office.
I will pick her up and bring her.
I assume you have video conference abilities in your office, and we of course will bring masks and social distance.
Please advise if any problems.
Michael Danchuk
EFTA00015964

=== Page 3 ===
*
I Privileged and Confidential I Electronic communication is not
secure mode of communication and may be
accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola
Barnhart & Shipley,
and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-
2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud.
Admin. 2.420 and information intended only for the use of the individual(s) named above. If the reader of this
message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of
this communication is strictly prohibited. Personal messages express views solely of the sender and shall not be
attributed to the law firm. If you received this communication in error, please notify the sender immediately by
e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank you.
EFTA00015965


c1: EFTA00015511
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015511.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:20-cv-00833-PAE Document 39-1 Filed 01/15/21 Page 1 of 4
New York Times V. BOP, 20 Civ. 833 (SDNY)
Index of Withholdings in Full
Entry
Page count
Description
Status
Withheld in Full (WIF) under 7(A);
Exemptions 6 and 7(C) applicable in
1
2
Incident Report of Jeffrey Epstein's July 23, 2019 Apparent Suicide Attempt
part
WIF under 7(A); Exemptions 5
(Deliberative Process Privilege), 6,
2
37
Psychological Reconstruction of Inmate Death
7(C), 7(E), and 7(F) applicable in part
WIF under 7(A); Exemptions 6, 7(C),
3
23
Overtime Logs for MCC, 07/22/19-07/23/19
and 7(F) applicable in part
WIF under 7(A); Exemptions 6, 7(C),
4
23
Overtime Logs for MCC, 08/09/19-08/10/19
and 7(F) applicable in part
WIF under 7(A), except for one page
released in part; Exemptions 6, 7(C),
5
8
MCC Daily Assignment Roster for 07/22/19
and 7(F) applicable in part
WIF under 7(A), except for one page
released in part; Exemptions 6, 7(C),
6
7
MCC Daily Assignment Roster for 07/23/19
and 7(F) applicable in part
WIF under 7(A), except for one page
released in part; Exemptions 6, 7(C),
7
9
MCC Daily Assignment Roster for 08/09/19
and 7(F) applicable in part
WIF under 7(A), except for one page
released in part; Exemptions 6, 7(C),
8
10
MCC Daily Assignment Roster for 08/10/19
and 7(F) applicable in part
WIF under 7(A); Exemptions 6, 7(C),
9
5
Inmate Investigative Report
7(E), and 7(F) applicable in part
10
4
MCC New York Updates
WIF under 7(A)
WIF under 5 - Deliberative Process
Privilege; Exemptions 6 and 7(C)
11
2
Draft Letters
applicable in part
WIF under 7(A); Exemptions 5
(Deliberative Process Privilege), 6,
12
129
Responses to Psychological Reconstruction of Inmate Death
7(C), 7(E), and 7(F) applicable in part
EFTA00015511

=== Page 2 ===
Case 1:20-cv-00833-PAE Document 39-1 Filed 01/15/21 Page 2 of 4
WIF under 7(A); Exemptions 6, 7(C),
13
2
Letter to Warden dated August 14, 2019
7(E), and 7(F) applicable in part
WIF under 7(A); Exemptions 6 and
14
16
Photo Sheet from 07/23/19 Apparent Suicide Attempt
7(C) applicable in part
WIF under 7(A); Exemptions 6, 7(C),
15
7
Memo and Report from 07/23/19 Apparent Suicide Attempt (Form 583)
7(E), and 7(F) applicable in part
WIF under 7(A); Exemptions 6 and
16
2
Photo Sheet from 07/23 Apparent Suicide Attempt
7(C) applicable in part
WIF under 7(A); Exemptions 6, 7(C),
17
1
Chain of Custody Form from 07/23 Apparent Suicide Attempt
7(E), and 7(F) applicable in part
WIF under 7(A); Exemptions 6, 7(C),
18
4
Reports of 07/23 Apparent Suicide Attempt
7(E), and 7(F) applicable in part
WIF under 7(A); Exemptions 6 and
19
48
Medical and Psychological records of Epstein
7(C) applicable in part
WIF under 7(A); Exemptions 6, 7(C),
20
17
Memo and Reports from 08/10 Suicide (Form 583)
7(E), and 7(F) applicable in part
WIF under 7(A); Exemptions 6 and
21
1
Memo from Unit Manager dated 08/10/19
7(C) applicable in part
WIF under 7(A); Exemptions 6, 7(C),
22
24
Count Documents (e.g., Watch Calls, Body Alarm Records)
and 7(F) applicable in part
WIF under 7(A); Exemptions 6 and
23
145
Count Documents (30 Minute Check Sheets)
7(C) appliable in part
WIF under 7(A); Exemptions 6 and
24
163
Count Documents (e.g., Count Slips, Rosters, Out-Count Forms)
7(C) appliable in part
WIF under 7(A); Exemptions 6 and
25
20
Investigative Documents from Suicide (e.g., Chain of Custody Forms)
7(C) applicable in part
26
Entry Deleted
WIF under 7(A); Exemptions 6 and
27
3
Investigative Documents from Suicide
7(C) applicable in part
WIF under 7(A); Exemptions 6 and
28
4
08/10/2020 TRUINTEL Reports (including email)
7(C) applicable in part
WIF under 7(A); Exemptions 6 and
29
1
Memo to Warden dated 08/13/2019
7(C) applicable in part
WIF under 7(A); Exemptions 6 and
30
24
Count Documents
7(C) applicable in part
EFTA00015512

=== Page 3 ===
Case 1:20-cv-00833-PAE Document 39-1 Filed 01/15/21 Page 3 of 4
WIF under 7(A); Exemptions 6 and
31
5
Investigative Documents from Suicide
7(C) applicable in part
WIF under 7(A); Exemptions 6, 7(C),
32
8
TRUINTEL Reports (8/9/19-8/10/19)
and 7(F) applicable in part
WIF under 7(A); Exemptions 6 and
33
5
Count Documents (30 Minute Check Sheets)
7(C) applicable in part
34
Entry Deleted
WIF under 7(A); Exemptions 6 and
35
46
Photo Sheets from 08/10/19 Suicide
7(C) applicable in part
WIF under 7(A); Exemptions 6 and
36
14
Photo Sheets from 07/23/19 Apparent Suicide Attempt
7(C) applicable in part
37
Entry Deleted
WIF under 7(A); Exemptions 6, 7(C),
38
27
SHU Weekly Review (08/08/2019)
and 7(F) applicable in part
WIF under 7(A); Exemptions 6 and
39
1
Cop Out Note
7(C) applicable in part
WIF under 7(A); Exemptions 6 and
40
2
SHU Computer Screenshots
7(C) applicable in part
WIF under 7(A); Exemptions 5
(Deliberative Process Privilege), 6,
41
4
Psychological Reconstruction Responses
and 7(C) applicable in part
WIF under 7(A); Exemptions 6 and
42
1
SHU Computer Screenshot
7(C) applicable in part
WIF under 7(A); Exemptions 6 and
43
4
24-hour death report and death notification (including email)
7(C) applicable in part
WIF under 7(A); Exemptions 6 and
44
13
Office of Chief Medical Examiner Documents
7(C) applicable in part
WIF under 7(A); Exemptions 6 and
45
40
Psych Observation Logs
7(C) applicable in part
WIF under 7(A); Exemptions 6 and
46
16
Suicide Watch Logs (including one SENTRY page)
7(C) applicable in part
WIF under 7(A); Exemptions 6 and
47
1
SHU Computer Screenshots
7(C) applicable in part
WIF under 7(A); Exemptions 6 and
48
1
Memo dated 08/12/2019
7(C) applicable in part
EFTA00015513

=== Page 4 ===
Case 1:20-cv-00833-PAE Document 39-1 Filed 01/15/21 Page 4 of 4
WIF under 7(A); Exemptions 6, 7(C),
49
7
Lieutenant's Log (08/09-08/10)
7(E), and 7(F) applicable in part
50
1
Scan of sign
WIF under 7(A)
WIF under 7(A); Exemptions 6 and
51
2
Memo dated 08/10/2019
7(C) applicable in part
WIF under 7(A); Exemptions 5
Approximately
Emails pertaining to Epstein's July 23, 2019 apparent suicide attempt, Epstein's mental
(Deliberative Process Privilege), 6,
52
969
health, and Epstein's incarceration prior to his suicide.
7(C), 7(E), and 7(F) applicable in part
WIF under 7(A); Exemptions 5
Approximately
Emails relating to Epstein's death, investigations into Epstein's death, the circumstances
(Deliberative Process Privilege), 6,
53
1,133
of his suicide, and the Bureau of Prisons's response to Epstein's death
7(C), 7(E), and 7(F) applicable in part
54
Entry Deleted
WIF under 7(A); Exemptions 6, 7(C),
55
32
Count slips and associated inmate rosters
7(F) applicable in part
WIF under 7(A), Exemptions 6, 7(C),
56
17
MCC Daily Assignment Rosters for July 23, 2019; August 9, 2019, and August 10, 2019
and 7(F) applicable in part
WIF under 7(A), Exemptions 6, 7(C),
57
4
Psychological notes on Epstein
and 7(F) applicable in part
58
2
Records showing transferors of wire transfers to Epstein
WIF under Exemptions 6 and 7(C)
Pages from inmate census rosters for 07/23/19, 07/24/19, 07/25/19, 07/27/19,
59
274
07/28/19, 07/29/19, 07/30/19, 07/31/19, 08/01/19, 08/02/19, 08/03/19, 08/04/19,
WIF under Exemptions 6 and 7(C)
WIF under 7(A); Exemptions 6, 7(C),
60
58
TRUINTEL Log Entries for 08/09/19 and 08/10/19
an 7(F) applicable in part
EFTA00015514


c1: EFTA00014884
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014884.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Jeff Pagliuca
>, , Laura Menninger
Cc:
Subject: Redactions
Date: Wed, 24 Nov 2021 23:31:48 +0000
Attachments: 2021.11.22_20cr330_Hall Temp_Seal._Mem._Op._&_Order_11.2221_[proposed_redactio
ns].pdf; Mot_to_Exclude
eply_Br._final_[proposed_redactions]].pdf;
Motion_to_preclude
et_al_[proposed_redactions].pdf;
2021.11.19_Maxwell_Response_to_Gov_Motion_to_Preclude_Expert_Testimony_Ipropose
d_redactions].pdf
Counsel,
We're required to propose and docket any redactions to the filings related to
I
and the other experts today. (See
Dkt. No. 495). We've attached our proposed redactions, and we propose to seal Exhibit B to the Government's motion in
full.
Please let us know if you have any proposed redactions. Per our previous process, we'll file a cover letter and send the
redactions to the Court, file redacted versions of our motion, wait for you to file a redacted opposition, and then file our
redacted reply.
Thanks,
Assistant United States Attorney
Southern District of New York
6
EFTA00014884


c1: EFTA00014351
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014351.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Subject: SW
Date: Wed, 07 Aug 2019 20:52:41 +0000
Attachments: USVI_SW.v2.docx
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00014351


c1: EFTA00016876
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016876.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
LAST WILL AND TESTAMENT
OF
JEFFREY E. EPSTEIN
I, JEFFREY E. EPSTEIN, of Little St. James Island, St. Thomas, United States Virgin Islands, do make, publish
and declare this to be my Will hereby revoking all prior Wills and Codicils made by me.
FIRST:
A.
I direct my Executor to pay from my estate all expenses of my last
illness, my funeral and burial expenses, the administration expenses of my estate and all of my debts duly proven
and allowed against my estate.
B.
I direct my Executor to pay from my estate, as compensation
to each Executor for serving as Executor hereunder, the sum of Two Hundred Fifty Thousand Dollars ($250,000) to
each Executor upon the completion of probate of my estate. No Executor shall receive any other compensation for
serving as Executor hereunder; provided, however, that my Executor shall be reimbursed from my estate for all
reasonable costs, expenses, charges, and liabilities incurred or paid in respect thereto, including fees and expenses
of counsel or any other agents hired by my Executor, and my Executor shall not be liable therefor individually.
C.
I direct my Executor to pay from my estate the federal and
state transfer taxes described in Paragraph B(1) of Article SEVENTH.
D.
I direct my Executor to pay from my estate all expenses of
storing, insuring, packing, shipping and delivering my tangible personal property in accordance with Article
SECOND.
SECOND: I give all of my property, real and personal, wherever situated, after the
payments and distributions provided in Article FIRST, to the then acting Trustees of The Jeffrey E. Epstein 2013
Trust (the "Trust") created under that certain Trust Agreement (the "Trust Agreement") dated September 16, 2013,
as the same may be amended from time to time, to be held in accordance with the provisions comprising the Trust
Agreement at the time of my death.
THIRD:
A.
J. appoint DARREN K. INDYKE, JOSEPH PAGANO and JAMES E.
STALEY to be the Executors of this Will. If any one or more of my Executors fails to qualify or ceases to act, I
appoint DAVID MITCHELL as successor Executor. I authorize the last acting Executor to designate his successor
as Executor.
B.
If my estate must be administered in whole or in part in any
jurisdiction other than the state or territory of my domicile at the date of my death and if my Executor is unable or
unwilling to serve in such jurisdiction, then I appoint the successor Executor of my estate designated in Paragraph
A of Article THIRD provided that he is able and willing to serve in such jurisdiction. If no Executor or successor
Executor is able and willing to serve in such jurisdiction, my Executor shall designate a successor Executor to serve
2657367.1
GJ_000151
EFTA00016876

=== Page 2 ===
in such jurisdiction. Such designation shall be made by written instrument delivered to such successor Executor.
C.
No bond or other security shall be required of any Executor in
any jurisdiction.
D.
Any Executor may resign in the manner provided for by the
governing statutes of the state or territory having jurisdiction of the administration of my estate or, in the absence of
such statutory guidance, by filing a written notice of resignation with the Court having jurisdiction of the
administration of my estate. Any Executor who resigns shall not be entitled to any compensation hereunder for any
services rendered as Executor prior to his resignation.
E.
My Executor shall not be accountable or responsible to any
person interested in my estate for the manner in which my Executor in good faith exercises or declines to exercise
any discretionary authority or power of my Executor. My Executor shall not be liable for any loss or depreciation in
value occasioned by reason of any negligence, error or mistake of judgment in entering into any transaction, in
making any sale or investment, in continuing to hold any property or by reason of any action or omission, whether
by my Executor or any other fiduciary, unless my Executor has acted in bad faith. In the absence of proof by
affirmative evidence to the contrary, each Executor shall be deemed to have acted within the scope of my
Executor's authority, to have exercised reasonable care, diligence and prudence and to have acted impartially as to
all interested persons. An Executor shall not be liable for the acts or defaults of another Executor.
FOURTH:
The following provisions shall apply to my estate and to my Executor, except as
is otherwise specifically provided in this Will:
A.
My Executor has the entire care and custody of all assets of
my estate. My Executor has the power to do everything my Executor in good faith deems advisable without
necessity of any judicial authorization or approval, even though but for this power it would not be authorized or
appropriate for fiduciaries under any statutory or other rule of law. My Executor shall exercise my Executor's best
judgment and discretion for what my Executor believes to be in the best interests of the beneficiaries hereunder. If
more than two Executors are empowered to participate in the decision to exercise or not exercise any fiduciary
power granted by this Will or by law, a majority of such Executors shall be empowered to make such decision.
B.
Except as otherwise provided herein, my Executor shall have
the power:
(1)
to enter upon and take possession of the assets of my
estate and collect the income and profits from such assets, and to invest and reinvest such assets in real, personal
or mixed assets (including the common trust funds of a corporate fiduciary) or in undivided interests therein
without being limited by any present or future investment laws;
(2)
to retain all or any part of the assets of my estate
(without regard to the proportion that any one asset or class of assets may bear to the whole) in the form in which
such assets were received or acquired by my Executor;
(3)
to sell or dispose of, exchange, transfer, invest or
loan all or any part of the assets of my estate which may, at any time, be held by my Executor for such sums or
upon such terms as to payment, security or otherwise as my Executor determines, either by public or private
transactions;
(4)
to buy and sell options, warrants, puts, calls or other
rights to purchase or sell (collectively "options") relating to any security or securities, regardless of whether such
security or securities are then held by my Executor, and whether such options are purchased or sold on a national
securities exchange, and to exercise with respect to such options all powers which an individual owner thereof
could exercise, including, without limitation, the right to allow the same to expire;
2
GJ_000152
EFTA00016877

=== Page 3 ===
(5) with respect to oil, natural gas, minerals, and all
other natural resources and rights to and interests therein (together with all equipment pertaining thereto)
including, without limiting the generality of the foregoing, oil and gas royalties, leases, or other oil and gas
interests of any character, whether owned in fee, as lessee, lessor, licensee, concessionaire or otherwise, or alone
or jointly with others as partner, joint tenant, or joint venture in any other noncorporate manner, (a) to make oil,
gas and mineral leases or subleases; (b) to pay delay rentals, lease bonuses, royalties, overriding royalties, taxes,
assessments, and all other charges; (c) to sell, lease, exchange, mortgage, pledge or otherwise hypothecate any or
all of such rights and interests; (d) to surrender or abandon, with or without consideration, any or all of such rights
and interests; (e) to make farm-out, pooling, and unitization agreements; (f) to make reservations or impose
conditions on the transfer of any such rights or interests; (g) to employ the most advantageous business form in
which properly to exploit such rights and interests, whether as corporations, partnerships, limited partnerships,
mining partnerships, joint ventures, co-tenancies, or otherwise exploit any and all such rights and interests; (h) to
produce, process, sell or exchange all products recovered through the exploitation of such rights and interests, and
to enter into contracts and agreements for or in respect of the installation or operation of absorption, reprocessing
or other processing plants; (i) to carry any or all such interests in the name or names of a nominee or nominees; (j)
to delegate, to the extent permitted by law, any or all of the powers set forth herein to the operator of such
property; and (k) to employ personnel, rent office space, buy or lease office equipment, contract and pay for
geological surveys and studies, procure appraisals, and generally to conduct and engage in any and all activities
incident to the foregoing powers, with full power to borrow and pledge in order to finance such activities; together
with the power to allocate between principal and income any net proceeds received as consideration, whether as
royalties or otherwise, for the permanent severance from lands of oil, natural gas, minerals, and all other natural
resources;
(6)
to hold all or any part of the assets of my estate in
cash or in bank accounts without the necessity of investing the same;
(7)
to improve, repair, partition, plat or subdivide all or
any part of the assets of my estate;
(8)
to litigate, defend, compromise, settle, abandon or
submit to arbitration on such terms and conditions as my Executor determines, to propose or accept a compromise
with respect to any claims in favor of or against my estate or the assets of my estate;
(9)
to loan or borrow money in such amounts and upon
such terms and conditions as my Executor determines, assume such obligations or give such guarantees as my
Executor determines, for the purpose of the acquisition, improvement, protection, retention or preservation of the
assets of my estate, or for the welfare of the beneficiaries of my estate;
(10)
to carry on for as long and in such manner as my
Executor determines any business enterprise in which I owned any interest at my death, either individually, or as a
partner, joint venture, stockholder or trust beneficiary; to sell such business enterprise as an ongoing business; to
consolidate, merge, encumber, dissolve, liquidate or undertake any other extraordinary corporate transaction
relating to such business enterprise;
(11)
to vote in person or by proxy any and all stock or
securities. and to become a party to any voting trusts, reorganization, consolidation or other capital or debt
readjustment of any corporation, association, partnership, limited liability partnership, limited liability company or
individual with respect to stocks, securities or debts held by my estate;
(12)
except as provided in paragraphs B(19) and B(20) of
this Article FOURTH, to enter into any good faith transactions with my Executor individually or with any
corporation, partnership or other entity in which my Executor has an ownership interest;
3
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(13) to lease, mortgage, pledge, grant a security interest
in or otherwise encumber all or any part of the assets of my estate for any term of years whether or not beyond the
duration of my estate (including, without limitation, any such action for the benefit of any of the beneficiaries of my
estate);
(14) to abandon any property of my estate, real or
personal, which my Executor may deem worthless or not of sufficient value to warrant keeping or protecting; to
abstain from the payment of taxes, water rents or assessments and to forego making repairs, maintaining or keeping
up any such property; and to permit such property to be lost by tax sale or other proceedings or to convey any such
property for a nominal consideration or without consideration so as to prevent the imposition of any liability by
reason of the continued ownership thereof;
(15) to elect the mode of distribution of the proceeds
payable to my estate from any profit-sharing plan, pension plan, employee benefit plan, individual retirement plan,
insurance contract or annuity contract pursuant to the terms of such plan;
(16) to allocate, in my Executors discretion, any
adjustment to basis provided to my estate under the provisions of Federal and State law with respect to property
comprising my estate, without any obligation to make a compensatory adjustment among the beneficiaries
hereunder on account of such allocation;
(17) to conduct any audit, assessment or investigation
with respect to any asset of my estate regarding compliance with any law or regulation having as its object
protection of public health, natural resources or the environment ("Environmental Laws"); to pay from the assets of
my estate to remedy any failure to comply with any Environmental Law (even to the exhaustion of all of the assets
of my estate); and, as may be required in my Executor's judgment by any Environmental Law, to notify any
governmental authority of any past, present or future non-compliance with any Environmental Law; and
(18) to sell to the Trustee under the Trust Agreement any
stocks, bonds, securities, real or personal property or other assets or borrow from the Trustee under the Trust
Agreement even though the same person or persons occupy the office of the Executor of my estate and the Trustee
under the Trust Agreement.
(19) No executor shall directly or indirectly buy or sell any
property for the estate from or to himself, or from or to his relative, employer, employee, partner, or other business
associate.
(20) No executor shall lend estate funds to himself, or to
his relative, employer, employee, partner, or other business associate.
C.
Except as otherwise provided herein, my Executor shall have
the power:
(1)
to employ agents, attorneys-at-law, consultants,
investment advisers (to whom my Executor has discretion to delegate my Executor's investment authority and
responsibility), other executors and other fiduciaries in the administration of my Executor's duties; to delegate to
such persons, or to one or more of my Executors, the custody, control or management of any part of my estate as
my Executor determines and to pay for such services from the assets of my estate, without obtaining judicial
authorization or approval;
(2)
to delegate, in whole or in part, to any person or
persons the authority and power to (a) sign checks, drafts or orders for the payment or withdrawal of funds,
securities and other assets from any bank, brokerage, custody or other account in which funds, securities or other
assets of my estate shall be deposited, (b) endorse for sale, transfer or delivery, or sell, transfer or deliver, or
4
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=== Page 5 ===
purchase or otherwise acquire, any and all property, stocks, stock warrants, stock rights, options, bonds or other
securities whatsoever, (c) gain access to any safe deposit box or boxes in which my assets or assets of my estate
may be located or which may be in the name of my Executor and remove part or all of the contents of any such safe
deposit box or boxes and release and surrender the same, and (d) take any other action that my Executor may have
the power to take with respect to my estate and the property thereof; no person or corporation acting in reliance on
any such delegation shall be charged with notice of any revocation or change of such delegation unless such person
or corporation receives actual notice thereof;
(3)
to pay any property distributable to a beneficiary
under a legal disability, without liability to my Executor, by paying such property (a) to such beneficiary, (b) for the
use of such beneficiary, (c) to a legal representative of such beneficiary appointed by a court or if none, to a relative
for the use of such beneficiary, or (d) to a custodian for such beneficiary designated by my Executor;
(4)
to distribute to any of the beneficiaries of my estate
in kind or in cash, or partly in kind and partly in cash, and to allocate different kinds or disproportionate shares of
assets or undivided interests in assets among all of such beneficiaries;
(5) to have evidence of ownership of any security
maintained in the records of a Federal Reserve Bank under the Federal Reserve Book Entry System; to deposit
funds in any bank or trust company; to carry in the name of my Executor or the nominee or nominees of my
Executor and with or without designation of fiduciary capacity, or to hold in bearer form, securities or other
property requiring or permitting of registration; and to cause any securities to be held by a depository corporation
of which an Executor is a member or by an agent under a safekeeping contract; provided, however, that the books
and records of my Executor shall at all times show that such investments are part of my estate;
(6)
to renounce and disclaim, in whole or in part, and in:
accordance with applicable law, any assets, interests, rights or powers (including any power of appointment) which
are payable to (or exercisable by) me or my estate, which are includible in my estate or Gross Estate or over which I
have any right, title, interest or power; and
(7)
to make, execute and deliver any and all such
instruments in writing as shall be necessary or proper to carry out any power, right, duty or obligation of my
Executor or any disposition whatsoever of my estate or any asset of my estate and to exercise any and all other
powers incidental or necessary to carry out or to fulfill the terms, provisions and purposes of my estate.
D.
In connection with any insurance policy or annuity on the life
of an Executor which is included in my estate, such Executor shall not participate in the decision to exercise or not
exercise any fiduciary power in connection with any incidents of ownership for such policy or annuity, including,
without limitation, any decision to continue, assign, terminate or convert such policy or annuity or to name the
beneficiary of such policy or annuity.
E.
An Executor hereunder may by a written notice delivered to
the other Executor (or Executors) decline to participate in the decision to exercise or not exercise any fiduciary
power granted by this Will or by law.
F.
If an Executor is not empowered (because of a conflict of
interest, declination to act or otherwise) to participate in the decision to exercise or not exercise any fiduciary power
granted by this Will or by law, then the remaining Executor or Executors shall be empowered to make such
decision. If no Executor is empowered to participate in such decision, then the successor Executor of my estate
designated in Paragraph A of Article THIRD and able and willing to act shall be empowered to make such decision.
If no Executor or successor Executor is empowered to participate in such decision, my Executor may designate a
successor Executor to serve as Executor of my estate who shall be empowered to make such decision but shall have
Executor. no other power or authority of my Executor. Such designation shall be by written notice delivered to such successor
5
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=== Page 6 ===
G.
(1)
Except as otherwise specifically provided herein and
except as provided in Paragraph G(2) of this Article, my Executor shall allocate receipts and disbursements in
accordance with sound trust accounting principles and shall have discretion to allocate receipts and disbursements
when the treatment is uncertain under applicable laws or generally accepted accounting principles in the judgment
of my Executor.
(2)
Except as otherwise specifically provided in this
Will, my Executor shall not treat any part of the principal amount of the proceeds of sale of any asset of my estate
as income distributable to or for the benefit of any beneficiary entitled to distributions of income; provided,
however, that my Executor shall treat a portion of any proceeds of sale of any financial instrument originally issued
or acquired at a discount equal to the amount which (a) has previously been characterized as ordinary income for
income tax purposes or (b) will be characterized as ordinary income for income tax purposes in the year of such
sale, as income for trust accounting purposes.
FIFTH:
Where a party to any proceeding with respect to my estate has the same interest
as a person under a disability, it shall not be necessary to serve legal process on the person under a disability.
SIXTH:
If any beneficiary under the Trust shall in any way directly or indirectly (a)
contest or object to the probate of my Will or to the validity of any disposition or provision of my Will or of the
Trust or (b) institute or prosecute, or be in any way directly or indirectly instrumental in the institution or
prosecution of, any action, proceeding, contest, objection or claim for the purpose of setting aside or invalidating
my Will or the Trust or any disposition therein or provision thereof, then I direct that (a) any and all provisions in
the Trust for such beneficiary and his issue in any degree shall be null and void and (b) my estate, whether passing
under my Will or the Trust or pursuant to the laws of intestacy, shall be disposed of as if such beneficiary and his
issue in any degree had all failed to survive me.
SEVENTH:
A.
As used herein:
(1)
The term "Executor" of a person's estate means all
persons or entities who occupy the office of executor, administrator, personal representative, or ancillary
administrator while such persons or entities occupy such office, whether one or more persons or entities occupy
such office at the same time or times, and includes any successor or successors to that office. The term "Trustee"
means all persons or entities who occupy the office of Trustee under the Trust Agreement while such persons or
entities occupy such office, whether one or more persons or entities occupy the office of Trustee at the same time or
times, and includes any successor Trustee or Trustees. A reference to a person's estate or probate estate means that
person's cstate which is subject to probate administration. A reference to a person's Will means such person's Last
Will and Testament and any Codicil or Codicils thereto.
(2)
The term "IRC section" means a section of the
Internal Revenue Code of 1986, as amended, or the corresponding provision of any successor Internal Revenue law,
as in effect as of the date of my death.
(1)
A. reference to any tax also includes any interest or
penalties thereon A reference to a person's "Gross Estate" means such person's gross estate as finally determined
for purposes of computing such person's federal estate tax.
(4)
Whenever the singular number is used, the same-
shall include the plural, and the masculine gender shall include the feminine and neuter genders.
B.
(1)
The federal and state transfer taxes which my
Executor shall be obligated to pay pursuant to Paragraph C of Article FIRST shall consist of all federal and state
estate, inheritance, succession, and similar taxes (including any federal or state generation-skipping transfer tax)
imposed upon my probate estate or by reason of my death in respect to all assets which pass under this Will or the
Trust Agreement. Subject to Paragraph B(2) of this Article, all federal estate taxes with respect to assets not passing
6
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=== Page 7 ===
under this Will or the Trust Agreement (such assets are referred to as the "Apportionment Assets") and any
applicable state estate taxes with respect to the Apportionment Assets shall be apportioned among all persons
interested in the Apportionment Assets. My Executor shall make reasonable efforts to collect all federal estate taxes
and state estate, inheritance, succession and similar taxes allocable to the Apportionment Assets from the recipients
of the Apportionment Assets. Without changing the apportionment of taxes in this Paragraph B(1), my Executor has
discretion, but is not required, to pay all or part of such taxes allocable to the Apportionment Assets. To the extent
my Executor pays such taxes allocable to the Apportionment Assets, my Executor shall seek reimbursement for
such taxes from the recipients of the Apportionment Assets. My Executor shall not be personally liable for any of
such taxes if my Executor is unable, with reasonable efforts, to collect payment (or reimbursement) from any
recipient of any Apportionment Assets for any or all of such taxes allocable to such assets.
(2)
My Executor has discretion to direct the Trustee of
the Trust Agreement to pay all or any portion of the taxes which my Executor is directed or obligated to pay
pursuant to Paragraph B of Article FIRST and this Paragraph B pursuant to a written direction delivered to the
Trustee under the Trust Agreement. Any taxes which my Executor directs the Trustee under the Trust Agreement to
pay shall be allocated and paid from the trusts under the Trust Agreement as provided under the Trust Agreement.
C.
Except as otherwise specifically provided in this Will, a
bequest or devise to an individual who does not survive me shall lapse notwithstanding any law to the contrary.
D.
To the extent that the distribution to the Trustee under the
Trust Agreement pursuant to Article SECOND shall not be effective, I give all the rest of my property, real and
personal, wherever situated, after the payments and distributions provided in Article FIRST, to the person or
persons named as Trustee or Trustees under the Trust Agreement, be to held in trust under this Will in accordance
with the provisions comprising the Trust Agreement at the time of my death, which provisions are incorporated in
this Will by reference.
IN WITNESS WHEREOF, I have duly executed this Will the 16th day of September, 2013
JEFFREY G E EPSTEIN
The foregoing written instrument was on the date thereof, signed, published and
declared by the Testator therein named as the Testator's Will in the presence of us and of each
of us: who, at the Testator's request, in the Testator's presence and in the presence of each
other, have subscribed our names as witnesses thereto.
Jeonne Bunnor residing
at
St. Thomas USVI
CRde residing at
St. Thomas VI
7
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=== Page 8 ===
We, JEFFREY E. EPSTEIN, CEGLE DE JONSH and, JEANNE BRENNAN the Testator and the witnesses,
respectively, whose names are signed to the foregoing instrument, having been sworn, declared to the undersigned
officer that the Testator, in the presence of the witnesses, signed the instrument as his Will, that he signed, and that
each of the witnesses, in the presence of the Testator and in the presence of each other, signed the Will as a witness.
JEFFREY E. EPSTEIN
CRde J
a Bundan
TERRITORY OF THE UNITED STATES VIRGIN ISLANDS)
)ss:
DIVISION OF ST. THOMAS AND ST. JOHN
)
Subscribed and sworn to before me by JEFFREY E. EPSTEIN, the Testator, who is personally known to me or who
has produced
as identification, and by CECILE DE JONEH
, a witness who is personally
known to me or who has produced
as identification, and JEANNE BRENNAN
, a
witness who is personally known to me or who has produced
as identification, on September 16,
2013.
Sworn to before me this 16th day of
September, 2013.
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
Notary & Public
Commission Expires 05/02/2014
Territory of the U.S. Virgin Islands
8
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=== Page 1 ===
From:
To: "Quigley, Brendan"
Subject: RE: Rodgers
Date: Wed, 12 May 2021 22:17:42 +0000
Attachments: 2021.05.11,_GM,_scheduling_order.pdf
Inline-Images: image001.jpg; image002.jpg
Hi Brendan,
Thanks again for discussing scheduling with me last week. As an update, the Court has issued a scheduling order for the
trial (attached). Jury selection will occur during the week of November 15th, and the trial will begin on November 29th.
Thanks,
From: Quigley, Brendan
Sent: Monday, May 10, 2021 8:50 AM
To:
Subject: Rodgers
Thanks for your call last week. Neither Mr. Rodgers nor I currently have any un-movable commitments between
September and December. As I mentioned, I'm waiting for trial dates for 1-2 trials as courts open back up, so please let
me know when the Maxwell trial gets scheduled.
Brendan F. Quigley [bio]
Partner
Baker Botts L.L.P.
T
New York, NY 10112
Confidentiality Notice:
The information contained in this email and any attachments is intended only for the recipient[s] listed above and may be privileged
and confidential. Any dissemination, copying, or use of or reliance upon such information by or to anyone other than the recipient[s]
listed above is prohibited. If you have received this message in error, please notify the sender immediately at the email address above
and destroy any and all copies of this message.
EFTA00014668


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=== Page 1 ===
From:
"
"
To:
"
(USANYS)"
(NY)
(FBI)"
"
(NY) (FBI)"
Cc:
"
)"
Subject:
[EXTERNAL] Re: GM - Witnesses
Date:
Wed, 06 Oct 2021 18:27:34 +0000
Hey guys,
Can you provide us with a little more information on the following witnesses. DOB's would be great or
approximate age but if not maybe who they are, why they are testifying, city or state they are from?
is
attached to this email, and she is assisting us with doing all the checks for the witnesses.
Thanks!
Detective
NYPD/FBI
Child Exploitation Human Trafficking Task Force
Office:
From:
(USANYS)
Sent: Monday, October 4, 2021 2:45 PM
To:
is
(NY) (FBI)
Cc:
Subject: GM - Witnesses
CAUTION! EXTERNAL SENDER
STOP WHEN UNSURE. Never click on links or open attachments if sender is unknown, and never provide
user ID or password. Suspicious? Please report to this email address: reportphishing@nypd.org
Below is the list of potential testifying witnesses as discussed. Please run rap sheets as discussed. Do you think you could
get them to us by Wednesday or Thursday? Call if you have any questions, thanks!
1
2.
3.
4.
5.
6.
7.
8.
9.
10.
EFTA00015028

=== Page 2 ===
11
12
13.
14.
15.
16.
17.
18.
19.
20.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00015029


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: US V. Maxwell, 20 Cr. 330 (AJN) - Joint Proposed Juror Questionnaire and Voir Dire
Date: Tue, 12 Oct 2021 23:31:35 +0000
Attachments: 2021.10.11_Letter_re_Jury_Questionnaire_and_Voir_Dire_[to_Court].pdf
Counsel,
Please let us know if you consent to us publicly filing the letter referenced in the Court's email below this evening
(reattached here for your convenience) or if you intend to file a letter seeking sealing.
Thanks,
From: Nathan NYSD Chambers
Sent: Tuesday, October 12, 2021 5:32 PM
To:
Subject: Re: US V. Maxwell, 20 Cr. 330 (AJN) - Joint Proposed Juror Questionnaire and Voir Dire
Counsel:
Consistent with the Court's Individual Rules, if one or both sides are requesting sealing, the letter making that
request must be docketed on ECF unless counsel is also seeking, with explanation and justification, to file the
letter under seal.
The Court would also like a copy of the Jencks Act material and exhibits.
Sincerely,
Chambers of the Hon. Alison J. Nathan
From:
Sent: Monday, October 11, 2021 7:53 PM
To: Nathan NYSD Chambers
EFTA00016714

=== Page 2 ===
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Joint Proposed Juror Questionnaire and Voir Dire
CAUTION - EXTERNAL:
Good evening,
Attached please find the parties' joint proposed juror questionnaire and voir dire. Per the attached letter, the parties
respectfully request that the Court accept the joint proposed juror questionnaire and voir dire under seal.
In addition, the Government has produced Jencks Act material and exhibits to the defense today. If the Court would like a
copy, we would be happy to provide it.
Respectfully submitted,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York. New York 10007
Tel:
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
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=== Page 1 ===
From:
)"
To:
)"
Subject: FW: Epstein investigation
Date: Wed, 12 Feb 2020 16:51:34 +0000
Inline-Images: image001.jpg; image002.jpg
On my way back.
From: Jill Greenfield
Sent: Wednesday, February 12, 2020 11:50 AM
To:
Cc:
Subject: RE: Epstein investigation
Sorry - I was stuck on a call - here now
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
From:
Sent: Wednesday, February 12, 2020 4:38 PM
To: Jill Greenfield
Cc:
Subject: RE: Epstein investigation
No problem - we just tried calling, but didn't catch you. Let us know when you're free and we'll give you a try back.
thank you,
From: Jill Greenfield
Sent: Wednesday, February 12, 2020 09:52
To:
)
Subject: RE: Epstein investigation
Ok - If I am not at my desk I am stuck on a con call and will e mail you when I am free
thanks
EFTA00014387

=== Page 2 ===
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
From:
Sent: Wednesday, February 12, 2020 2:51 PM
To: Jill Greenfield
Cc:
is
Subject: Re: Epstein investigation
Jill,
That works, thank you - we'll plan to call you at 4.30 GMT, or just let us know if you prefer a different time,
otherwise we'll look forward to speaking with you then.
thanks,
On Feb 12, 2020, at 04:42, Jill Greenfield
wrote:
Hi
Yes a discussion would be fine - I am around after 4.00 GMT, 11.00 am Eastern if that helps.
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
From:
Sent: Tuesday, February 11, 2020 3:10 PM
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
is
is
Subject: RE: Epstein investigation
Jill,
We wanted to briefly follow up, particularly because I think when we first spoke with you there was a possibility your
client was going to be interviewed by the metro police this week. Would it make sense to chat regarding any of the
below?
EFTA00014388

=== Page 3 ===
thanks,
From:
Sent: Saturday, February 08, 2020 14:25
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
is
is
)
Subject: RE: Epstein investigation
Jill,
Thanks for circling back, and we'll do our best to answer these questions. In terms of who would be in the room, the
most likely answer is that it would be two of the prosecutors and the two law enforcement officers on the case. The
only reason I saw "most likely" rather than having a definitive answer is that when we're interviewing in a foreign
country, it sometimes is the case the local law enforcement also insists on having representatives present. I don't
believe that's required in the U.K., but we can check on it and give you a definitive answer in the coming days if that's
useful. (Also, if she preferred to be interviewed in the U.S., we certainly could guarantee that the room would be just
the case team, and we could arrange for travel and lodging for her. Let us know if that's the case, but otherwise we're of
course happy to travel to her.)
Regarding access to notes, it would principally be the investigative team-so again, the prosecutors and the FBI team
working on the case. Our respective supervisors also theoretically have access to our files, but the reports are not
generally widely disseminated. The basic logistics are that an agent takes notes during an interview, and then types up
those notes into a formal report (called an FBI Form 302). We don't ordinarily share notes with other entities, but I can
also check on that to see if I can make a more specific representation with respect to your client.
With respect to anonymity, I confess that I'm not familiar with the distinction you're referring to. In terms of our
investigation, we don't publicly disclose the names of individuals we meet with, and we don't disclose to any other
witnesses, for example, the identities of victims or witnesses we are meeting with. (And our policies on that don't
change even for individuals who are in the position of your client, who have been widely publicly reported to have been
connected to Epstein and/or his employees or associates). But if that doesn't answer your question, we're of course
happy to discuss further. Let me know if it might be useful to have a call? Or if not, also happy to address any follow-up
via email.
thanks,
From: Jill Greenfield
Sent: Saturday, February 08, 2020 13:17
To:
Cc: Kyle Phillips
>; Louise Scott
is
is
)
Subject: Re: Epstein investigation
Hi
Thanks for this. I've been asked who would be in the room and thereafter who would have access to any notes
made. Would her permission be sought before disclosing to any other parties or officials?
As you know there is a real difficulty in relation to her anonymity in the US versus the UK. Are you able to
provide any comfort on this?
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=== Page 4 ===
Many thanks
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
Sent from my iPhone
On 6 Feb 2020, at 21:53,
wrote:
Ms. Greenfield,
Thank you again for speaking with us earlier today regarding our interest in talking with your client in connection with
our investigation into the conduct of Jeffrey Epstein.
As requested, we wanted to briefly memorialize our current views and understandings of your client, and also to
reiterate our interest in approaching any discussion with great care and sensitivity, particularly to avoid adding to her
trauma or causing re-victimization.
As we mentioned on the phone, your client is not a target of our investigation-it sounds like the analogue in the U.K.
may be the "suspect" category-and we currently do not have reason to believe that she has committed any U.S.
federal crime. As we discussed, our knowledge of your client specifically is somewhat limited, having never spoken to
her-and therefore knowing about her only through other witnesses and records-but it certainly has been our
experience that the overwhelming majority of young women and girls who were in the orbit of Jeffrey Epstein during
the relevant periods were subject to his abuse. It does not surprise us, nor do we have any trouble believing, that your
client was similarly a victim. I hope that is helpful in understanding the capacity in which we hope to speak with her.
Separately, and as we also discussed, any discussion with our team would be entirely voluntary-and that extends not
just to whether she would be willing to meet with us at all, but also including her ability to decline to discuss particular
topics or even particular questions, and to talk with her counsel at any time, to take any breaks that would be
beneficial while we're meeting, etc.
In terms of topic areas, we would be hoping to learn about the general narrative of her interactions with Epstein and
his other associates and employees, including Ghislaine Maxwell, whom we understand she may have worked directly
for. That would broadly include how she came to be in contact with them, the nature and scope of her employment,
any instructions she was given relating to other women or girls, and just generally her experiences and observations in
interacting with them. We ordinarily would also be interested in understanding the general nature of the abuse she
was subjected to, but I want to emphasize that we would not need to discuss with her the specifics if she weren't
comfortable with that, and in particular we often don't even broach that subject in a first meeting.
Please let us know if you have any additional questions, and in particular whether any other information from us
would be useful, and we look forward to speaking with you again soon.
Regards,
EFTA00014390

=== Page 5 ===
Assistant U.S. Attorney
Southern District of New York
Fieldfisher, Riverbank House, 2 Swan Lane, London EC4R 3TT.
www.fieldfisher.com
We do not intend to change our bank details. If you receive any communication that any of our bank details have changed, telephone us and speak to your
contact at our office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstances.
This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact the
sender immediately, destroy the email and any attachments and do not use, copy, store or disclose this email and any attachments for
any purpose. Fieldfisher does not accept service of documents by electronic means without express prior agreement.
For details about what personal information we collect and why, please see our Privacy Notice on our website at
www.fieldfisher.com.
Fieldfisher is the trading name of Fieldfisher LLP, a limited liability partnership registered in England and Wales (registered number OC318472) and is authorised and regulated
by the Solicitors' Regulation Authority. A list of its members and their professional qualifications is available at its registered office, Riverbank House, 2 Swan Lane, London
EC4R 3TT. We use the term partner to refer to a member of Fieldfisher LLP or an employee or consultant with equivalent standing or qualifications.
EFTA00014391


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c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014420.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Epstein Sex Offender Report
Date: Thu, 27 Jun 2019 23:00:00 +0000
Attachments: Epstein_Sex_Offender_6.27.19.xps
Good evening,
As requested I've attached Epstein's most recent Sex Offender Report.
Thanks,
EFTA00014420


c1: EFTA00014883
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014883.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject:
Date: Wed, 24 Nov 2021 22:34:00 +0000
Attachments: TTORNEY_NARRATIVE_8_28_20_Epstein_VCP_Claim_Submission_Redactedpdf
Assistant United States Attorney
Southern District of New York
EFTA00014883


c1: EFTA00016403
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016403.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Subject: RE: Follow Up on July 23 Incident Sensitive Disclosure Materials
Date: Tue, 17 Dec 2019 14:16:54 +0000
Ok, sounds good. We have 10:30 sonogram tomorrow so I'll meet you up there after.
Co-Chief, Narcotics Unit
From:
Sent: Tuesday, December 17, 2019 9:15 AM
To: Swergold, Jason (USANYS)
Subject: RE: Follow Up on July 23 Incident Sensitive Disclosure Materials
Thanks again for taking the lead on this stuff. l'll be in a meeting from about 10:30am to 3pm today, but otherwise am
available if there's anything you want to discuss before tomorrow's conference. I have a 10am plea in White Plains
tomorrow, so I'm planning to take the train up.
From:
USANYS)
Sent: Tuesday, December 17, 2019 6:47 AM
To: Aida Leisenring <aleisenring@barketepstein.com>
Cc:
>; Bruce Barket <bbarket@barketepstein.com>
Subject: Re: Follow Up on July 23 Incident Sensitive Disclosure Materials
Aida,
To confirm, we are looking into whether video of the hallway, and videos and/or photos of the cell exist. We likely would
make those available for review in the same manner as the report. We are also looking into whether the orange rope was
preserved and if it was, we will let you know our position on whether it can be made available for inspection. As discussed
briefly, since you have reviewed a photograph of the rope, we are not sure the basis for a physical inspection and would
ask you to articulate one for our consideration.
Co-Chief, Narcotics Unit
On Dec 16, 2019, at 16:52, Aida Leisenring <aleisenring@barketepstein.com> wrote:
Hello
Thank you for taking the time to let us review sensitive disclosure materials in your office on Friday. We appreciate it. I
just wanted to memorialize a few follow-up questions we had.
1. It is our understanding that there is video surveillance in the hallway in or near the tier that was preserved in
reference to the July 23 incident. We would like to see a copy of it.
2. It is our understanding that there may be photographs or a video recording of cell 124 that would have been
taken shortly after the incident. If so, we would like to see them.
3. If the orange rope was preserved, we would like to view it in person.
EFTA00016403

=== Page 2 ===
I understand that you were not aware of the availability of the above and that you would look into this additional
discovery. I just wanted to memorialize our follow up inquiries for your records.
Lastly, if the items above are available, does your office take a position with respect to our request to view them? We
just need to know so we can plan our next course of action.
See you in Court, and thank you again for your time.
Aida Ferrer Leisenring, Esq.
Barket, Epstein, Kearon, Aldea & LoTurco LLP
666 Old Country Road, Ste 700
Garden City, NY 11530
T
F
Please note that my emailed has changed to:
aleisenring@barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments.
EFTA00016404


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=== Page 1 ===
Event: Accepted
proffer (re abuse)
Start Date: 2019-12-04 20:00:00 +0000
End Date: 2019-12-04 23:00:00 +0000
Location: Winston & Strawn offices, 200 Park Ave
Class: X-PERSONAL
Comment:
Date Created: 2019-12-04 21:01:44 +0000
Date Modified: 2019-12-04 21:01:44 +0000
Priority: 5
DTSTAMP: 2019-12-04 17:27:29 +0000
Attendee:
EFTA00016929


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015338.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS) 4"
To: "
(USANYS)"
Cc: "
(USANYS)"
Subject: FW: 2019.02.15 Agenda Meeting with
docx
Date: Thu, 14 Feb 2019 22:48:27 +0000
Importance: Normal
Attachments: 2019.02.15_Agenda_Meeting_with,
docx
attached is a draft agenda for tomorrow's meeting with
We plan to go through the program, our
roles/responsibilities, recent issues, and some case highlights. I will pepper in some lessons learned from the
situation, as discussed earlier today. Let us know if you have any additions/thoughts. Thanks!
From:
(USANYS)
Sent: Thursday, February 14, 2019 5:21 PM
To:
(USANYS) 4
Subject: 2019.02.15 Agenda Meeting with
docx
Updated
EFTA00015338


c1: EFTA00014578
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c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014578.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Fwd: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB)
Date: Thu, 01 Aug 2019 22:20:21 +0000
I do not mind assisting these two woman with travel.
Sent from my iPhone
Begin forwarded message:
From:
Date: August 1, 2019 at 5:55:06 PM EDT
To:
Cc:
Subject: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear
The
represents two women who allege they were fraudulently recruited and enticed by
Epstein and/or his agents to perform a personal massage on him at his private residence, located at
9 East 71st St., New York, NY 10021, in exchange for hundreds of dollars that resulted in Epstein
forcefully sexually assaulting our clients in what we believe is in violation of Title 18, United States
Code, Sections 1591(a) and (b). Our clients believe they were assaulted by Epstein in or around
June 2004. Our clients did not consent or agree to any sexual touching or activity with Mr. Epstein.
Our clients are also concerned, after learning about the pictures recovered from Mr. Epstein's home,
that sexually explicit pictures were unknowingly taken of them during the incidents.
Our clients' names are
Please be
advised, our clients wish to remain anonymous at this juncture and do not consent to their names
being released to the public. Please advise immediately if it appears as if our clients' identities will be
released to the public and/or Mr. Epstein's legal team. If revealing the identities is necessary for the
case to move forward, please advise prior to doing so, so that our clients can make an informed
decision.
We understand your office may be interested in interviewing our clients for additional details. We can
help coordinate a time for you to interview our clients in New York.
Please let us know if you need any additional information at this time; otherwise, we look forward to
hearing from you soon.
EFTA00014578

=== Page 2 ===
Best,
This message is for the designated recipient only and may contain privileged, proprietary, or
otherwise private information. If you have received it in error, please notify the sender immediately
and delete the original. Any other use of the email by you is prohibited.
EFTA00014579


c1: EFTA00016768
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016768.pdf
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c0:
=== Page 1 ===
From: Christian Everdell <CEverdell@CohenGresser.com>
To:
Cc:
"BOBBI
C STERNHEIM"
'Jeff Pagliuca'
i
'Laura Menninger' <lmenninger@hmflaw.com>
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Renewed Bail Motion Reply Memorandum
and Exhibits (to be Filed Under Seal)
Date: Sat, 19 Dec 2020 00:40:06 +0000
Attachments: 2020.12.18_Cover_Letter_to_Judge_Nathan_re_Renewed_Bail_Motion_Replypdf;
Reply_Memorandum_re_Renewed_Bail_Application_Final.pdf;
Reply_Memorandum_re_Renewed_Bail_Application_Final_Redacted.pdf_Exhibit_A.pdf;
Exhibit_B.pdf
Inline-Images: image002.jpg; image004.jpg
Dear Judge Nathan -
Attached please find the following documents submitted to the Court and all counsel under seal pursuant to the Court's
order (Dkt. 89):
1. Cover letter
2. Reply memorandum (unredacted)
3. Reply memorandum (redacted)
4. Accompanying exhibits A-B
Regards,
Christian R Everdell
COHEN & GRESSER LLP
New York NY 10022
view bio
www.cohengresser.com
New York Paris Washington DC London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy
EFTA00016768


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017128.pdf
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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.
EFTA00017128

=== Page 2 ===
0062415200393 - Welcome to New Ticket Viewer
Page 1 of 2
Ticket
Viewer
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home
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Issue Date: 2020-01-18
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Total Tickets:
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1
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N
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259.53 USD
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Ticket Sources
18 Jan 2020 09:20:40 PM
Eqvt Fare Paid:
259.53 USD
Transaction Type:
TKT
Received:
TCN 20 Jan 2020 03:50:15 EN
Taxes/Charges:
AY 11.20 USD
Skeletal Indicator:
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Ofcl Std
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Itinerary Information Coupon State:U Carrier Role:Marketed
Ofcl Std
Ticket Nb
Cpn Nb
Cpn
Orig
Dest
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wth
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EFTA00017129
http://ktvievr.delta.com/tktviewer/action/searchTicket?ticketNumberPrimary=0062415200393etktDocN=00624152003938tic.48/2020

=== Page 3 ===
0062415200393 Welcome to New Ticket Viewer
Page 2 of 2
Fare Calculation
Fare Calc
Fare Calc
Rfmd
Fare Calc Txt
Typ
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FrCn Ind
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
EFTA00017130
http://ktvievwr.delta.com/tktviewer/action/searchTicket?ticketNumberPrimary00624152003938tktDocNb=00624152003938tic48/2020

=== Page 4 ===
0062415200393 - Welcome to New Ticket Viewer
Page 1 of 1
Ticket
Viewer
Ticket Viewer
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prim:
18 Jan 2020 ,1)
Select View: Psngr Profile
(Prod) Version 1.0 Wed, 08 Apr 2020 04:47:55 PM
Ticket Number
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
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 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 Deita Air
Lines
EFTA00017131
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=== Page 5 ===
0062415200393 - Welcome to New Ticket Viewer
Page 1 of 2
Ticket
Viewer
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prim: 0062415200393 (18 Jan 2020 .1)
Select View: Payment
(Prod) Version 1.0 Wed, 08 Apr 2020 04:48:05 PM
Ticket Number
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:
1
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
Pmt Amt
FOP
Nb
Pmt Amt
Sgnd For
Sgnd For
FOP Ref
FOP
FOP
D/CC
Curr Cd
Amt
Stt
Curr Cd
Nb
FOP Trans ID
Vndr
D/CC Acct Nb
D/CC
D/CC
Type
Exp
GTR Acct ID
Cd
Cd
Type
Apvl ID
1
307.80
USD
3
CC
Original Ticket Information
Nbr
Orig Tkt Nb
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No Data Available
Exchanged Ticket Number Summary
New
Tkt
New Tkt
New Tkt
Excgd
Excgd
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
Reprice
Evt Wavr Cd
Name
Evt Wavr Description
Amt
Curr Cd
Pricing Src
Tkt Doc Pricing Src
Amt
Agent
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 Sre
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Reprice
Curr Cd
Chnl Id
Response ID
Process
Response GTs
Cd
DC
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EFTA00017132
Ticket Document Waiver Information
http://tktviewr.delta.com/tktviewer/action/searchPayment
4/8/2020

=== Page 6 ===
PCI Token Manager
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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:
succeeded
CLEAR
SUBMIT
2018 Delta Air Lines, Inc. I Information Technology. All rights reserved.
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4/8/2020
EFTA00017133


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=== Page 1 ===
90A-NY-3151227 Serial 52
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Derivative
Date: 08/22/2019
Evidence NYC023596
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S);
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From: (U) CART-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Derivative Evidence NYC023596: One (1) WD Black 3TB
hard drive, WD3003FZEX-00Z4SA0, S/N WCC13LZR579P, containing the verified
E01 images NYC023578 (1B1), NYC023579 (1B2), NYC023580 (1B3), NYC023581
(1B4), NYC023583 (1B6), NYC023584 (1B7), NYC023585 (1B8), NYC023586
(1B9), NYC023587 (1B10), NYC023588 (1B11), and NYC023592 (1B15). Master
Copy.
Item Type
Description
1B Digital
(U) One (1) WD Black 3TB hard drive, WD3003FZEX-00Z4SA0,
S/N WCC13LZR579P, containing the verified E01 images
NYC023578 (1B1), NYC023579 (1B2), NYC023580 (1B3),
NYC023581 (1B4), NYC023583 (1B6), NYC023584 (1B7),
NYC023585 (1B8), NYC023586 (1B9), NYC023587 (1B10),
NYC023588 (1B11), and NYC023592 (1B15). Master Copy.
Collected On: 08/21/2019 03:00 PM EDT
Seizing Individual:
Collected By:
Device Type: Hard Drive
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.
EFTA00015840

=== Page 2 ===
90A-NY-3151227 Serial 52
UNCLASSIFIED
Title: (U) Submission of CART Derivative Evidence NYC023596
Re: 90A-NY-3151227, 08/22/2019
Designation: Master Copy
Number of Devices Collected: 1
UNCLASSIFIED
2
EFTA00015841


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 360 Filed 10/19/21 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
United States of America,
DATE FILED: 10/19/21
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
As noted in its previous order, the Court will hold a telephone conference to discuss jury
selection matters on October 21, 2021 at 12:00 p.m. Dkt. No. 330. Members of the press and
the public in the United States may access the live audio feed of the proceeding by calling 844-
721-7237 and using access code 9991787. Those outside of the United States may access the
live audio feed by calling 409-207-6951 and using the same access code.
The Court will provide counsel for both sides an additional dial-in number to be used by
counsel, the Defendant, alleged victims, and any family members of the Defendant.
Any photographing, recording, or rebroadcasting of federal court proceedings is
prohibited by law. Violation of these prohibitions may result in fines or sanctions, including
monetary fines, restricted entry to future hearings, denial of entry to future hearings, or any other
sanctions deemed necessary by the Court.
SO ORDERED.
1
EFTA00016955

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 360 Filed 10/19/21 Page 2 of 2
Dated: October 19, 2021
Alim D. New
New York, New York
ALISON J. NATHAN
United States District Judge
2
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=== Page 1 ===
From:
"
)"
To:
"
,
) [Contractor]"
Cc: "Young, Amanda N. (NY) (FBI)"
)"
,
)"
Subject: RE: financial documents (Epstein)
Date: Thu, 18 Jul 2019 00:46:49 +0000
Tomorrow morning could you please burn the following folders to a disc:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNYinvestigation\Subpoena
Returns\American Express
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY investigation\Subpoena
Returns\Deutsche Bank
and put the disc in an envelope addressed to:
Special Agent
Detective
If it's possible to get the disc by 11:30, we'll give the disc to Mandy and Paul at the conference, or if not, if you could put
the envelope with security and reply all that it's ready, they can pick up when convenient.
thanks,
Assistant U.S. Attorney
Southern District of New York
212.637.2415
EFTA00014613


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=== Page 1 ===
From:
To:
Subject: FW: Language to include
Date: Mon, 29 Jun 2020 13:53:09 +0000
I cannot put this language into the letter. I can include the web page.
y she is V/W legal adviser in EOUSA and a really nice person. I would like to see if she has added text that we
can use in the letter. Is it okay that I ask her.
From:
Sent: Monday, June 29, 2020 9:05 AM
To:
>;
Cc:
Subject: Language to include
Good Morning,
I hope each of you had a good weekend. Please find language below that has been approved by FBI NY, VSD
executive management and our OGC rep. I'm more than happy to have a call if you would like to discuss.
The FBI's Victim Services Division (VSD) is committed to providing services and support to victims of crimes
committed by Jeffrey Epstein. Though this particular indictment is focused on specific individuals, you are still
entitled to your rights, resources, and referrals as a federal victim independent of this indictment. An overview
of these services is available at www.fbi.gov/resources/victim-services If you would like to speak with a Victim
Specialist, or if you have any questions regarding your rights to victim services and referrals, please email
victimservices@fbi.gov.
Thank you,
Program Manager
FBI Victim Services Division
EFTA00017706


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
VIRGINIA L. GIUFFRE,
Plaintiff,
No. 15 Civ. 7433 (LAP)
-against-
MEMORANDUM & ORDER
GHISLAINE MAXWELL,
Defendant.
LORETTA A. PRESKA, Senior United States District Judge:
The Court has reviewed Defendant Ghislaine Maxwell's letter
requesting reconsideration of the Court's July 23, 2020, decision
to unseal (1) the transcripts of Ms. Maxwell's and Doe 1's
depositions, and (2) court submissions excerpting from, quoting
from, or summarizing the contents of the transcripts. (See dkt.
no. 1078.)
Ms. Maxwell's eleventh-hour request for reconsideration is
denied. As Ms. Maxwell acknowledges in her letter, reconsideration
is an "extraordinary remedy." In re Beacon Assocs. Litig., 818 F.
Supp. 2d 697, 701 (S.D.N.Y. 2011) (quoting In re Health Mgmt. Sys.
Inc. Sec. Litig., 113 F. Supp. 2d 613, 614 (S.D.N.Y. 2000)). Such
motions "are properly granted only if there is a showing of: (1)
an intervening change in controlling law; (2) the availability of
new evidence; or (3) a need to correct a clear error or prevent
manifest injustice." Drapkin V. Mafco Consol. Grp., Inc., 818 F.
Supp. 2d 678, 696 (S.D.N.Y. 2011). "A motion for reconsideration
1
EFTA00017070

=== Page 2 ===
may not be used to advance new facts, issues or arguments not
previously presented to the Court, nor may it be used as a vehicle
for relitigating issues already decided by the Court." Bennett V.
Watson Wyatt & Co., 156 F. Supp.2d 270, 271 (S.D.N.Y. 2001).
Here, Ms. Maxwell's request for reconsideration hinges on her
assertion that new developments, i.e., her indictment and arrest,
provide compelling reasons for keeping the deposition transcripts
sealed. (See dkt. no. 1078 at 5.) But, despite Ms. Maxwell's
contention that she could not address the effect of those events
in her objections because they occurred after the close of
briefing, (id.), 1 this is plowed ground. Indeed, in her original
objection to unsealing, Ms. Maxwell argued that the specter of
ongoing criminal investigations into unknown individuals
associated with Jeffrey Epstein--a group that, of course, includes
Ms. Maxwell--loomed large over the Court-ordered unsealing
1 The Court notes as a practical matter that Ms. Maxwell was
arrested on July 2, 2020-that is, three weeks prior to the Court's
July 23 decision to unseal the materials at issue. To the extent
that they relate to the to the Court's balancing of interests in
the unsealing process, the issues that Ms. Maxwell raises in her
request were surely plain the day that Ms. Maxwell was apprehended.
Ms. Maxwell, however, did not seek to supplement her objections to
unsealing despite ample time to do SO. In fact, the Court notified
the parties on July 21, 2020, that it would announce the unsealing
decision with respect to Ms. Maxwell's deposition, together with
other documents, on July 23. (See dkt. no. 1076.) Even then, Ms.
Maxwell made no request for delay or to supplement her papers.
Ms. Maxwell did not raise her "vastly different position,"
(Transcript of July 23 Ruling at 16:2-3), until moments after the
Court had made its decision to unseal the relevant documents.
2
EFTA00017071

=== Page 3 ===
process. (See dkt. no. 1057 at 5.) This argument, specifically
Ms. Maxwell's concern that unsealing would "inappropriately
influence potential witnesses or alleged victims," (id.), and her
reference to "publicly reported statements by Plaintiff,
Plaintiff's counsel, the United States Attorney for the Southern
District of New York, and the Attorney General for the U.S. Virgin
Islands" about those investigations, (id.), carried with it the
clear implication that Ms. Maxwell could find herself subject to
investigation and, eventually, indictment. The Court understood
that implication as applying to Ms. Maxwell and thus has already
considered any role that criminal charges against Ms. Maxwell might
play in rebutting the presumption of public access to the sealed
materials. Ms. Maxwell's request for reconsideration of the
Court's July 23 ruling is accordingly denied.
Given the Court's denial of Ms. Maxwell's request for
reconsideration, the Court will stay the unsealing of Ms. Maxwell's
and Doe 1's deposition transcripts and any sealed or redacted order
or paper that quotes from or discloses information from those
deposition transcripts for two business days, i.e., through
Friday, July 31, 2020, so that Ms. Maxwell may seek relief from
the Court of Appeals. Any sealed materials that do not quote from
or disclose information from those deposition transcripts shall be
unsealed on July 30, 2020, in the manner described by the Court's
Order dated July 28, 2020. (See dkt. no. 1077.) Ms. Maxwell's and
3
EFTA00017072

=== Page 4 ===
Doe 1's deposition transcripts and any sealed materials that quote
or disclose information from them shall be unsealed in the manner
prescribed by the July 28 Order on Monday, August 3, 2020, subject
to any further stay ordered by the Court of Appeals.
so ORDERED.
Dated:
New York, New York
July 29, 2020
Loutta a Preska
LORETTA A. PRESKA
Senior United States District Judge
4
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From:
To:
Subject: Here it is
Date: Thu, 26 Jun 2008 15:02:18 +0000
Importance: Normal
Attachments: U2.wpd
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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
(USANYS)"
Subject: RE: Call re Maxwell
Date: Mon, 05 Apr 2021 18:36:28 +0000
Sure. Let's do tomorrow at 1:30. Thanks
From:
Sent: Monday, April 5, 2021 2:25 PM
To:
(USANYS)
>;
(USANYS)
Cc:
>;
(USANYS)
Subject: Call re Maxwell
Hi
We would like to schedule a call to chat about an issue that came up when I was reviewing the physical evidence from the
Epstein file on Friday.
,
and I are all free tonight from 6pm to 7pm, tonight from 7:30pm to 8pm, or tomorrow
from 1pm to 3pm. Is there a time in any of those windows when we could have a call, please?
Thanks,
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From:
)"
To:
(USANYS)"
)"
Cc:
(USANYS)"
Subject: RE: Epstein
Date: Fri, 26 Apr 2019 19:16:44 +0000
Importance: Normal
Attachments: 2019-03-12,_JE,_status_memo_for_ODAG_updated.docx;2019-04-
26,_JE,_status_memo_for_Audrey.docx
Attached is the most recent ODAG memo, along with a short memo for
that summarizes updates since
the last memo. Please let me know if there are any edits you'd like me to make, or additional information you
need.
hasn't reviewed this, because he's in transit, but we spoke briefly this morning to discuss what should
go in the update.
Original Message
From:
(USANYS)
Sent: Friday, April 26, 2019 11:43 AM
To:
)
Cc:
(USANYS)
i
)
Subject: Re: Epstein
would you be able to do this?
Sent from my iPhone
>
On Apr 26, 2019, at 11:36 AM,
)
wrote:
>
>
I'm traveling today, back on Sunday so could do it then or otherwise have to defer to
sorry.
>
>
Sent from my iPhone
>
On Apr 26, 2019, at 10:35,
(USANYS)
wrote:
is going to meet with
on Monday - can you guys put together an update memo this
afternoon on where we are, what we've done since the last update memo, and next steps? This just for
for now, not for sending down to DC.
>>
Sent from my iPhone
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From:
To:
Subject: new atty / victims
Date: Tue, 03 Dec 2019 23:08:18 +0000
I don't think Jordan Merson has been on our radar at all, so just flagging
https://nypost.com/2019/12/03/jeffrey-epstein-accused-of-sexuall-abusing-9-more-women-suit/
Assistant U.S. Attorney
Southern District of New York
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From:
)"
To: Laura Menninger <Imenninger@hmflaw.com>,
(USANYS)"
)"
)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, "ceverdell@cohengresser.com"
<ceverdell@cohengresser.com>, "Bobbi Sternheim (bcsternheim@mac.com)"
<bcsternheim@mac.com>
Subject: RE: Conferral Regarding Possible Violation of Local Criminal Rule 23.1
Date: Wed, 12 May 2021 03:03:03 +0000
Inline-Images: image001.jpg
Counsel,
To our knowledge, Spencer Kuvin does not represent any of the witnesses the Government expects to call at trial in this
case. Because this individual does not represent any witnesses in this case, we do not see a need to raise this issue with
the Court.
We agree that compliance with Local Rule 23.1 is important. To that end, we note that David Markus, an attorney who
has filed a notice of appearance in the Second Circuit on behalf of Ms. Maxwell, and who was present for the arraignment
before Judge Nathan last month, has also made public statements to the press regarding this case, which run the risk of
violating the rule. See, e.g., https://nypost.com/2021/05/05/ghislaine-maxwell-on-enhanced-security-schedule-lockup-
feds/
Our hope is that by alerting you to this concern now, there will not be a need in the future to raise the issue with the
Court.
Best,
From: Laura Menninger <lmenninger@hmflaw.com>
Sent: Friday, May 7, 2021 5:18 PM
To:
)
is
(USANYS)
>;
is
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; 'ceverdell@cohengresser.com <ceverdell@cohengresser.com>; 'Bobbi
Sternheim (bcsternheim@mac.com)' <bcsternheim@mac.com>
Subject: Conferral Regarding Possible Violation of Local Criminal Rule 23.1
Counsel -
The linked article by the Sun dated yesterday contains a number of statements which, if made by a lawyer associated with
a witness in this case, appear to violate Local Criminal Rule 23.1. See also Dkt. No. 28 (expectation of strict compliance
with Rule 23.1 by "counsel for all involved parties"). The rule applies by its terms to any "lawyer participating in or
associated with the investigation (including lawyers for targets, subjects, and witnesses in the investigation...)."
https://www.thesun.co.uk/news/14875477/ghislaine-maxwellplea-deal-same-fate-as-epstein/
I am writing to confer with you prior to bringing this to the Court's attention. Please let me know if you believe Mr.
Spencer Kuvin represents any witness in this case.
Given the urgency of this situation, I would appreciate a response by close of business Monday.
EFTA00014661

=== Page 2 ===
Thanks,
Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: RE: Epstein Sharing Order Part II
Date: Fri, 31 Jan 2020 00:21:36 +0000
Attachments: 2019.12.19_Epstein_6(e)_App_Order.ebd.ajr.docx_(002)_(002).docx
I apologize for the delay on this - I've added the relevant language about revocations to both the application and the
order, and corrected a stray typo, so that stuff is good to go. But two quick things to note, not to belabor this, but - it
doesn't look like there's any reference to the Trust Two documents - that may be because they're not referenced in any
will? At a glance I don't see Trust Two in any of the wills, but I'd want to go back and look more thoroughly unless
somebody already made the decision on that basis. And second, it references a 2019 Trust but I don't see any documents
on that? I have to run out tonight but can certainly circle up with
and/or
tomorrow on any of this, or just ignore
it if I've misread.
thanks,
From:
(USANYS)
Sent: Thursday, January 30, 2020 12:05
To:
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part II
Just wanted to circle back on this -
are you signed off? Is this something we could get over to Part I today or
tomorrow? Thanks
From:
Sent: Wednesday, January 29, 2020 3:56 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
is it the intent to share those? If so, l'll just add it to every mention of each document, but if not then it's
unnecessary. I don't think those are substantive docs but I defer.
From:
(USANYS)
Sent: Wednesday, January 29, 2020 15:55
To:
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part II
Please add it in the right place and send me the order. Remember, I'm not a T&E lawyer. But you are getting to
be
EFTA00015021

=== Page 2 ===
From:
Sent: Wednesday, January 29, 2020 3:22 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part II
Yes, I think this document accurately describes the materials we've received, with just a note that it doesn't appear to
include revocations, so to the extent those are intended to be shared, I think that word may need to be added.
thanks,
From:
(USANYS)
Sent: Wednesday, January 29, 2020 10:40
To:
(USANYS)
is
Subject: Epstein Sharing Order Part II
- I've updated the sharing order application to be one to share the additional trust and will documents we have now
received. Would you take a look when you can?
- I've tried to describe the various materials we have gotten from the estate attorneys over the last two weeks.
Would you mind taking a look (or asking a paralegal to take a look) to make sure I've accurately described/characterized
the new stuff we're looking to share?
Thanks,
EFTA00015022


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From:
)"
To: Laura Menninger <Imenninger@hmflaw.com>,
)"
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP
(ceverdell@cohengresser.com)" <ceverdell@cohengresser.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Fri, 09 Apr 2021 16:00:56 +0000
Inline-Images: image001.jpg
All,
Today the Marshals and the FBI informed me that they are able to arrange for your client and the evidence to be at 500
Pearl in time for the review to start as early as 8am each morning of the review period. The review can still continue until
4:30pm each day. In order to take advantage of the extra time, I would propose planning to begin each review day at
8:30am. You would also be welcome to arrive as early at 8am, and if the Marshals and FBI are ready to begin before 8:30,
then we can do so. I will plan to be at 500 Pearl by 8am each morning.
Also, the CSOs have asked for a list of everyone from the defense team who should be granted access into the proffer area
on the fifth floor of 500 Pearl for the review. Would you please send me a list of the names of everyone who you expect
to attend the review?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Thursday, April 8, 2021 10:05 PM
To: Laura Menninger <lmenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
Below please find responses to the issues you raised:
EFTA00015786

=== Page 2 ===
We are confirmed for the review at the Bronx warehouse on April 12, 2021 from 11am to 4:30pm.
During the April 12th review, your team can see the evidence for yourselves and let me know if you need any of the
items you are not permitted to photograph to be brought to 500 Pearl. Depending on the size of the item(s), we
may need to figure out whether they can be brought later in the week once you have already reviewed several
boxes, which would free up space in the FBI vehicle for the larger items. I'm confident we will be able to reach a
reasonable agreement about those items.
For the bulky photos, you will not be permitted to photograph any that feature nudity. As referenced above, once
your team has seen those photos for yourselves, you can let me know if you will need any to be brought to 500
Pearl.
As I mentioned previously and is indicated in the spreadsheet, we are preparing a letter to defense counsel
explaining why you will not be permitted to review those 16 discs. We expect to send you that letter tomorrow,
after which I will be happy to discuss the matter further.
The blue-ray discs referenced in the spreadsheet are what the FBI burned in order to provide the USAO SDNY with
a copy of electronic data to produce to you in discovery. The discs are not evidence themselves. The data is the
evidence, and it was produced to you already. You are correct, however, that the 4/24/07 file is a data file that was
copied from a VHS tape, which is currently located in the FBI's ELSUR office in Florida. We have asked that the
original tape be shipped to New York, and it should arrive on Tuesday, April 13th. We will make it available for you
to review once we have received it. We also plan to produce the digital file of that same recording to you as part of
our productions of non-testifying witness statements.
The shredded paper is currently being analyzed by the FBI lab. We have asked the case agent to inquire with the
lab regarding its anticipated timeline for analysis and will let you know when we expect it will be possible to have
the shredded paper returned to New York for you to review. It will not, however, be available next week.
The "Missing from Assigned Box" items are items 1B130 and 1B110. Those items were migrated within the FBI
evidence system from the Florida case to the New York case and incorporated into New York evidence item
numbers 1B127, 1B128, & 1B137. So these items will be available for your review under those New York evidence
numbers.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com
Sent: Wednesday, April 7, 2021 4:23 PM
To:
is
V.
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
EFTA00015787

=== Page 3 ===
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
My apologies, I meant to include in my previous email that we could have the Bronx view on Monday, April 12. Thank you
for the logistics.
Regarding the spreadsheets you provided, I have several issues.
First, there are a couple of items that you have noted for the Bronx Warehouse but will in fact need to be brought to 500
Pearl for review because you labeled them as "Highly Confidential" and not "bulky." These appear to include:
NY Evidence List
Items 1B127-130 (4 boxes).
Item 1B13 (1 box)
Florida Evidence List
Item 1, Subitem 26 - one large framed photo from Master Bedroom.
Second, with regard to the "Bulky" photos (Florida Items 1, Subitems 8, 15a, 15b and 15c), are we permitted to
photograph those or not? If not, we will need them transported to 500 Pearl.
Third, Florida Item 8, Subitem 8, says it is Sixteen DVD-R Discs from PBSO but you do not indicate that we can review
those. Why? We need to address with the Court promptly any issues related to our request to view all evidence.
Fourth, Electronic surveillance - Your email yesterday stated that these were all "electronic files" with no corresponding
physical item. However, for several, the chart indicates "Blu-Ray Disks;" is there a reason we cannot inspect these?
Another Florida item is listed as "one original recording of an interview dated 4/24/07"; I am suspicious that "one original
recording of an interview" is not truly only an "electronic" file? I was practicing law in 2007 and do not recall "electronic
files" being the standard then. Can you please confirm? I know that Chris has written separately about the many files for
which the metadata has apparently been stripped, so we will have to address purely electronic information at another
date.
Shredded Paper - Yes, we need to review that as well.
"Missing from Assigned Box" items - can you please provide more of an explanation for all "missing items"?
I will let you know any other issues as I see them. However, now that we have made travel plans in reliance on your
agreement to produce all evidence items, I am hoping that you can promptly answer these questions so that we can
resolve any of them as needed this week.
Thank you,
-Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
)
Sent: Wednesday, April 7, 2021 1:44 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
EFTA00015788

=== Page 4 ===
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Hi Laura,
The Bronx warehouse is located at 2350 Lafayette Ave, Bronx, NY. There is plenty of street parking outside of the
building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the
attorney, investigator, and paralegal at the warehouse to escort them into the building to the evidence review room. The
AUSA will remain present at the warehouse to answer any questions that may arise.
The FBI has informed me that they can make the evidence available for review at the warehouse any day next week or the
week of April 19th. Please just let me know what day you prefer, and we will coordinate with the FBI to arrange for the
review.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Wednesday, April 7, 2021 3:30 PM
To:
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for the updated spreadsheets and the information regarding the timing of the review at 500 Pearl.
I believe we will be able to have an attorney, investigator and paralegal present at the Bronx warehouse to take photos of
the "excluded from transportation" items. Please let us know the particulars for that visit when you have a moment.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
)
Sent: Wednesday, April 7, 2021 10:06 AM
EFTA00015789

=== Page 5 ===
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
Attached please find the revised spreadsheets, which reflect designations under the Protective Order for the three mini-
VHS tapes that I referenced below.
I learned this morning that the Marshals intend to bring Ms. Maxwell back to the MDC each review day at 4:30pm. So we
can plan for the review to take place at 500 Pearl Street from 9:30am to 4:30pm each day beginning on April 13th.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Wednesday, April 7, 2021 12:09 AM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: 'Jeff Pagliuca' <jpagliuca@hmflaw.com>; 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good evening,
Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day
thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street
at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer rooms on the 5th floor of
the 500 Pearl Street courthouse beginning at 9:30am on April 13th. I will plan to be present and to continue assisting with
logistics. If any questions or concerns arise, please feel free to call my cellphone at
To assist in preparing for this review, attached please find annotated versions of the three evidence spreadsheets I
previously emailed to you: (1) a spreadsheet of New York evidence; (2) a spreadsheet of Florida evidence; and (3) a more
detailed spreadsheet of the sub-items contained in the Florida evidence spreadsheet. A couple things to note:
These spreadsheets now indicate the Protective Order designation, if any, for each item to be reviewed. As you will
see, there are three mini-VHS tapes that I need to double check before assigning a final designation. I expect to be
able to access a mini-VHS cassette player later this week, at which point I will be able to provide an updated
spreadsheet with a confirmed designation for those three items. Additionally, please note that there is one item
about which we plan to provide you with a letter later this week.
These spreadsheets also indicate where each item will be made available for the defense to review. As you will see,
we have now learned that one item (consisting of shredded paper) is currently at FBI headquarters and will not be
EFTA00015790

=== Page 6 ===
available for review next week. Please let me know if you believe you need to review that item, and I will inquire as
to whether and how it can be relocated to New York. Additionally, all 1D items consist of electronic data (as
opposed to 1B items, which are physical items). As is noted in the spreadsheets, the electronic data that constitute
the 1D items in this case have either already been produced to you in discovery (e.g., pen register data, GPS data,
and aerial footage), or are digital recordings of interviews that will be produced as non-testifying witness
statements. Because these 1D items are data files stored in the FBI system, there is no corresponding physical item
to produce for you to review.
Please let me know when you would like to schedule a time for a smaller group from the defense team to review evidence
at the Bronx warehouse.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, April 5, 2021 10:48 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
Thank you for your email and for your understanding as we work through the logistics of arranging this review. Your
modifications and clarifications are acceptable to us. Below I address each specifically:
The FBI can arrange for a lawyer, investigator, and paralegal to inspect and photograph the precluded items at the
Bronx warehouse either next week or the week after. Please let us know what day you would like to arrange for
that inspection, and I will coordinate with the FBI accordingly. I would suggest trying to schedule this visit early
next week if possible so that if there are items that you believe need to be produced to 500 Pearl Street, we will
have time to do so during a subsequent day of review at 500 Pearl if the FBI agrees to transport the item(s).
Tomorrow, I will send you evidence spreadsheets with annotations of which items the FBI will not be producing to
500 Pearl Street, and which items we are designating under the Protective Order. Please note that certain items
will be designated "Confidential," in which case they may be photographed, but the photographs should be treated
as Confidential under the Protective Order. Other items will be designated "Highly Confidential," in which case they
may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to
photograph this latter category because some Highly Confidential evidence items include both nude and non-nude
portions, in which case we would permit photography of the non-nude portions.
In light of our decision to produce non-testifying witness statements beginning on April 12, 2021, we are no longer
segregating any electronic media that contain witness statements during this review. This is because all of the
witness statements on the electronic media in the FBI's possession are from witnesses whom the Government does
not expect to call at trial in this case. Please note that we intend to produce digital audio files to you containing the
EFTA00015791

=== Page 7 ===
contents of the electronic media with these non-testifying witness statements, but you are of course welcome to
review the original recordings themselves.
In terms of space, I have been informed that we will not be permitted to conduct this review in a courtroom and
will instead be required to do so in the proffer rooms. I have reserved the two largest proffer rooms available at
500 Pearl. We can use the largest proffer room for evidence review, and the slightly smaller proffer room as a
private meeting space for the defense team.
Confirmed, I will ask the FBI to bring all electronic highly confidential images to 500 Pearl Street, including the
2,100 that were not previously reviewed and the electronic images that were previously provided for review at the
MDC.
Confirmed, I will ask the FBI to bring the 7 hard-copy highly confidential materials to 500 Pearl Street.
As I mentioned earlier today in a separate email, the FBI and AUSAs are prepared to facilitate this review beginning April
13th and continuing every day thereafter until your review is complete. I have also formally requested that the Marshals
produce Ms. Maxwell to 500 Pearl Street on April 13th and every day thereafter until the review is complete. The
Marshals previously confirmed their willingness to produce Ms. Maxwell for such a review in general, but they have not
yet confirmed their ability to do so on any particular dates. I will let you know as soon as the Marshals inform me
whether they can accommodate these specific dates.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Friday, April 2, 2021 5:36 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for your email. Your proposal is largely acceptable to us, with the following modifications and clarifications.
For the items that you propose below to exclude from the evidence transported to 500 Pearl Street (with the
exception of the cash held at 26 Federal Plaza), we will need to have access for a lawyer, investigator and paralegal
to inspect and photograph those items at the Bronx warehouse. This seems to include the bulky items, electronic
devices and "fragile" items.
Once they are photographed and shared with the team and our client, we can decide whether a separate
inspection by our client and/or any expert is necessary at a later time. To be clear, the government's photos
of these same items are insufficient.
If there are any items we are not permitted to photograph (and perhaps you will be able to tell us by April 5
which those are), we likely will need to have those transported because there is no way for our client to
inspect the evidence. We can wait to finalize this issue until you have finished deciding what items you
consider non-photographable, and if we can't agree, then discuss next steps.
EFTA00015792

=== Page 8 ===
Please let us know when these "non-transportable" items can be inspected and photographed at the Bronx
warehouse. It makes sense that it would be done soon so that we can raise any issues as necessary with the
Court.
For playing any of the electronic media, we will obtain the necessary equipment to play at 500 Pearl Street and
seek permission to bring those devices into the Courthouse. You can segregate out the section of recordings that
contain "witness statements" and advise us then which ones cannot be played, but we still need to inspect the
outside of those recordings.
As far as space, can you please advise whether the largest proffer room will be available for review of evidence? It
is my understanding that it can accommodate a large number of the team members at one time. If not, is a locked
courtroom available for us to review the evidence? The agents could bring out a limited number of boxes at a time
for inspection.
We understand that the evidence will not be taken outside of the monitoring of the agents or your staff and
appreciate that you will have a separate room for us to consult with our client privately (without the evidence).
We understand that all of the highly confidential materials, including not only the 2,100 images not previously
disclosed as well as the electronic images that were only shown to NY counsel and the client at the MDC, will be
available for review on a singular laptop at 500 Pearl Street.
We also understand the 7 hard-copy highly confidential materials will also be available for inspection at 500 Pearl
Street.
Please let me know if you have any questions or disagree with my understanding. If you agree, we can then proceed as
scheduled on April 12 and continue day to day until we are finished, with a break if necessary for the arraignment.
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Saturday, March 27, 2021 4:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with
arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will
also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12th.
Physical Evidence
It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are
certainly willing to work with you to ensure that your client can review any physical items that are material to the
preparation of her defense.
We would propose excluding the below items from production to 500 Pearl:
We appreciate your note that the massage tables are not needed, which will certainly help with the logistics
of transport.
We also appreciate your indication that the cash items from 26 Federal Plaza do not need to be produced.
Those are the only items not located in the Bronx warehouse.
EFTA00015793

=== Page 9 ===
The FBI has seized dozens of electronic devices, including desktop computers, servers, and laptops, from
Jeffrey Epstein's residences in 2019. Photographs of those devices were produced in our August 2020
productions as part of the search warrant photographs, and you have received copies of the data that was
seized from those devices pursuant to a warrant. The production of these devices would be very
cumbersome, and we do not see any value in looking at an electronic device that cannot be turned on.
The framed pictures are bulky and cumbersome to transport. These are also very delicate and are difficult
to transport. Photographs of those seized images were already provided to you as part of the photographs
from the searches of Epstein's residences.
Certain items seized from the New York residence are bulky, fragile, and/or difficult to transport. These
include plaster busts of female torsos and a stuffed dog. Photographs of these items were already provided
to you from the search of the New York residence.
The remaining physical items of evidence would fit into approximately 15 to 20 boxes. The FBI has indicated that it
would be feasible to transport those boxes to 500 Pearl Street.
Regarding your request for equipment that can play the recordings, we believe they would require a VCR, a cassette
player, a CD player, an adapter for a micro VHS tape, and a microcassette player. If you wish to play these
recordings at 500 Pearl, you will need to provide that equipment. We have asked the FBI whether any other
equipment would be necessary and will let you know if that is the case prior to the date of your review. It is our
understanding that any recordings that are not witness statements and that are not highly confidential have been
produced to you in discovery. We are not aware of any discoverable, non-highly confidential, recordings that were
not produced to you as part of the Government's discovery productions in the fall. To confirm that understanding,
we are working with the FBI to physically doublecheck each recording. If we identify any discoverable recordings
that have not already been produced, we will promptly provide them to you.
The segregation of highly confidential material will require the FBI and an AUSA to physically review each item to
confirm the item's status. We will endeavor to do so by your requested date of April 5, 2021.
We can confirm that neither the AUSA(s) nor the agent(s) will record or attempt to record any part of the evidence
review or conversations among the defense team or with the defendant during this review. Although the evidence
cannot be left outside of the presence of an agent, we will ensure that a room is available for the defense team and
the defendant to confer privately away from the agent(s) and the AUSA(s) without monitoring.
As for your request for a space large enough to fit 8 members of the defense team, the defendant, an agent, an
AUSA, and the evidence, my office cannot control the space that the Marshals allow us to use at 500 Pearl outside
of the proffer rooms. We will certainly request as large a space as possible, but if we are required to use the
proffer rooms, then members of the defense team may need to rotate in and out of the room. I know members of
the defense team have been in those proffer rooms before, and they can hopefully provide some thoughts on how
we might use the proffer room space effectively for your purposes. If the Court grants authorization for the
defense to bring electronic devices into 500 Pearl, that is certainly fine with the Government, and you may note our
consent in your request to Judge Nathan for such authorization.
Highly Confidential Electronic Images
The 2,100 electronic images were recovered during the responsiveness review of images and videos seized from
Jeffrey Epstein's devices, which review was not complete until early November 2020. We indicated on page 4 the
cover letter to our November 9, 2020 production, which included all other images and videos from those devices,
that "the Federal Bureau of Investigation ('FBI') seized multiple nude and partially nude images from several for the
above-listed electronic devices. All such images have been designated Highly Confidential. The FBI will make these
images available for review by the defense upon request." We did not receive a request from the defense to review
these images until your March 8, 2021 letter, which requested to "view and inspect all materials designated by your
office as 'Highly Confidential' under the terms of the Protective Order".
We did not ask the FBI to bring the 7 hard copy images to the MDC in the fall because we did not understand you to
be requesting a review of physical, non-electronic evidence during those meetings. Our understanding of the
defense request at that time was to review the electronic highly confidential images that were recovered from CDs
from Epstein's residence. We will ensure that the 7 hard copy images are available to you for review at 500 Pearl.
EFTA00015794

=== Page 10 ===
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 22, 2021 5:19 PM
To:
)
is
)
V.
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
We have considered your proposal. Unfortunately, it does not permit us an adequate ability to review the evidence in the
case and does not permit our client to meaningfully participate in her own defense.
First, we are unable to meaningfully review the evidence without the benefit of our laptops and other electronic devices
which are needed to take notes of our review. We also need access to our devices during the review to compare the
physical evidence with the electronic discovery and with our work product.
Second, we need to provide our client the ability to review all discovery, including any recordings, in order to assist in her
own defense. Presuming that she will not be taken to the FBI downtown office, then your proposal offers no means by
which she can both inspect a recording in its physical form and listen to the recording at the same time.
In order to address the deficiencies in your proposal, we believe the following are necessary:
Physical Evidence
All of the physical evidence currently located in the FBI Bronx warehouse will be transported to 500 Pearl Street
and made available during the week of April 12, with our client present, in a room sufficiently large to
accommodate 8 attorneys and investigators.
We do not need the "bulky" massage tables transported; if there are any other extremely large evidence
pieces, let us know what they are and we can consider whether we can have someone review and
photograph those at the Bronx warehouse at an earlier time.
From your email, it appears that only two items are not located at the Bronx warehouse - both envelopes
with cash. Please confirm this. We do not need the two "cash" evidence items transported to 500 Pearl.
If there are other evidence items housed somewhere other than the Bronx, please let us know what they are
and where they are.
We will be permitted to bring our laptops, and a camera, into 500 Pearl Street; we are happy to seek permission
from Judge Nathan to do so.
Either the FBI can provide the equipment necessary to listen to any of the recordings at 500 Pearl Street or we can
bring the necessary equipment. If we are to provide the equipment, we will need to know in advance the formats
of each recording so that we can be prepared. You can note that on your Excel spreadsheet by the item number by
March 29 to give us adequate time to secure the necessary equipment.
EFTA00015795

=== Page 11 ===
The FBI can segregate any physical evidence that you deem "highly confidential." You can identify any "highly
confidential" physical evidence items on your Excel spreadsheets by April 5 (one week before the evidence view). If
we need to photograph or reproduce any such item for expert evaluation, we will seek leave of court. Otherwise,
we will not photograph any such items during the review during the week of April 12. This will ensure the evidence
review proceeds smoothly and there will not be any need to ask permission to photograph on an item by item
basis.
The FBI also can segregate any recordings which we will be able to inspect, but not listen to, during the evidence
view the week of April 12. You can note such designation on your Excel spreadsheet. If we disagree, we can seek
leave of the Court in advance.
We understand that an FBI Agent and/or AUSA may be present during our physical evidence review at 500 Pearl
Street but of course must ensure that no recordings are made of our conversations and also ensure that there is a
separate, secure room in which we can confer with our client during the evidence view without monitoring by the
government.
Please confirm whether all electronic recordings (other than the highly-confidential images and videos described
below) have previously been produced to us, and if not, please explain which ones were not produced by the
discovery deadlines last fall and why.
Highly Confidential Electronic Evidence
Can you please explain why 2,100 + 7 "highly confidential" images have not been shared with us yet? It was our
understanding that you previously provided all "highly confidential" images to our client - and to defense counsel -
for review at the MDC in November. We are confused about where these previously undisclosed items were
located and why they have not yet been made available for inspection and review.
During the week of April 19, Ms. Maxwell should be produced to 500 Pearl Street to review (with counsel and a
defense staff member, on the 1 laptop provided) all of the 5,507 electronic images and video marked "highly
confidential". These should be segregated into the three categories you describe (never-before produced,
previously produced, and the 7 hard-copy images).
Please let us know if you will not agree to any of these steps so that we can address the issues with the Court.
Thank you.
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Tuesday, March 16, 2021 4:40 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
i
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding
discovery cover letter. We are sending a copy of these files to the MDC for your client as well.
In response to your questions, the FBI has informed me of the following:
Regarding the Highly Confidential nude/partially nudge images to be reviewed at 500 Pearl:
There are three categories of these images:
EFTA00015796

=== Page 12 ===
Approximately 2,100 electronic images and videos seized from Epstein's electronic devices (which have not
been previously provided to you)
Approximately 3,400 electronic images from discs seized from Epstein's residences in 2019 (which have
previously been provided to you and your client for review at the MDC)
Approximately 7 hard copy nude images located in the file from the FBI Florida office's investigation of
Epstein (which have not been previously provided to you)
The FBI will make all three of those categories available to you. The electronic files will be provided on hard drives,
and the FBI will provide you with the hard copy images for review as well.
All electronic images should be viewable as thumbnails, except those seized from Apple devices, which must
be viewed using Cellebrite.
The Cellebrite software will be provided on the drive for your review of images and videos seized from Apple
devices.
The electronic files have the same metadata on the hard drive that was available when the FBI seized each
image. For images that were carved or deleted, no metadata was recovered, so none is viewable. For all
other images, the metadata recovered should be viewable on the hard drive.
The approximately 2,100 electronic images and videos seized from Epstein's devices are separated by folder
to indicate which device each image was seized from.
Because these images are considered obscene material, the FBI is not permitted to make duplicates of them, and
there is a limited number of clean laptops on which these images can be reviewed. As a result, the FBI is only able
to provide a single laptop for review of these images.
Regarding the physical evidence:
Attached are two lists of all physical items in the FBI's custody relating to this case. The first list relates to items
associated with the FBI Florida office's investigation of Epstein. The second list relates to items associated with the
FBI New York office's current investigation.
The vast majority of physical evidence in the FBI's custody is located at the FBI's warehouse in the Bronx. Two
items (1B 77 & 1B are located at 26 Federal Plaza, but the case agents can check those items out from 26
Federal Plaza and bring them to the Bronx warehouse on whatever day you choose to conduct your review so that
you will have all evidence in one place.
The FBI is able to arrange for the defense team to review all physical evidence at the Bronx warehouse under the
following conditions:
The warehouse requires at least two weeks' notice in order to pull all of the items for the entire case and
place them in a location where a large group of people can view them.
The warehouse is open during normal business hours between 9am and 5pm on weekdays.
At least two FBI agents and an AUSA will be present at the Bronx warehouse to assist and answer questions.
The evidence will be placed in a loading dock at the warehouse to provide additional space for the review.
To ensure that there is sufficient space, please let me know how many members of the defense team intend
to be physically present for this review.
Electronic devices such as cellphones and laptops are not permitted in the warehouse. The defense team
may bring a digital camera that is not connected to the Internet or a cellular network into the warehouse. If
the defense team wishes to photograph an item of evidence, the defense will need to inform the agents who
are present, so that they may confirm that the photographed item is not Highly Confidential based on the
presence of nudity.
Electronic media such as VHS tapes, cassette tapes, and CDs will not be playable at the warehouse.
To the extent the defense requests that the FBI bring any physical items to 500 Pearl Street for your client to review,
the FBI is prepared to bring items that are reasonably sized to 500 Pearl Street. With respect to bulky or large
items, the defense team should be able to photograph those for your client to review, unless they are deemed
Highly Confidential, in which case the FBI can make arrangements to transport the item to 500 Pearl Street if
necessary.
The FBI is in the process of confirming that it can provide devices to play all of the electronic media in the case in a
single location at the FBI's offices in downtown Manhattan. We are also double-checking to confirm that all media
that does not contain witness statements have already been produced to you and your client in discovery. The FBI
anticipates that we can arrange for you to review all non-witness statement electronic media at the FBI's office in
downtown Manhattan in approximately three weeks.
EFTA00015797

=== Page 13 ===
To the extent you wish to review all of the discs containing photographs, which were seized from Epstein's
residences in 2019, we note that all of those images have already been produced to you in discovery. For
your awareness, the FBI has informed me that it took their team several weeks to review all of the images on
all of those discs.
Please let me know how you wish to proceed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, March 15, 2021 6:00 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
I expect to be able to answer all of your questions about the evidence review by tomorrow.
We have been looking into the discovery request you made last week, and we hope to have a response ready to provide
to you by next week.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 15, 2021 3:01 PM
To:
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
EFTA00015798

=== Page 14 ===
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of
when you would have answers, it could help me answer your question.
At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the
attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their
evidence when they seized it from NY and LSJ, so I don't think we need to wait for them to now prepare an inventory
before we start reviewing evidence.
Also, when do you believe you will have a response regarding the discovery I requested last Monday?
Thanks,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
)
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00015799

=== Page 15 ===
From:
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 3:44 PM
To:
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you. Is that the only index of physical evidence available?
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
EFTA00015800

=== Page 16 ===
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
Code:
Best,
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
EFTA00015801

=== Page 17 ===
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
EFTA00015802

=== Page 18 ===
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00015803


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=== Page 1 ===
From:
To:
Subject: RE: United States V. Ghislaine Maxwell
opens
Date: Mon, 29 Nov 2021 18:47:01 +0000
This is such a worthy case, and you guys are all fighters for even getting to this point. Sending good wishes for a swift and
just result!
From:
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>; USANYS-CRIMINAL PARALEGALS <USANYS-
Cc:
Subject: United States V. Ghislaine Maxwell --
pens
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors will
do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine Maxwell
sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New NY 10007
EFTA00014904


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=== Page 1 ===
MARTIN G. WEINBERG, P.C.
ATTORNEY AT LAW
EMAIL ADDRESSES:
August 1, 2019
By Electronic Mail
Assistant United States Attorneys
U.S. Attorney's Office for the
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Re:
United States V. Jeffrey Epstein, No. 19-cr-00490
Supplement to Defendant's First Request for Discovery
Dear
We write to supplement our first request for discovery that was electronically mailed to you
on July 26, 2019 that sought the preservation and production of documents relating to the NPA
and issues arising from the NPA. We wanted to particularize certain requests that were
applicable to the United States Attorney's Office (hereinafter "USAO") for Southern District of
Florida and the FBI Office that were working with them as follows:
To request that AUSA
who was the lead prosecutor investigating Mr.
Epstein in 2006-8 produce or in the alternative agree to preserve any and all documents,
communications whether emails from any and all email accounts from which she was sending or
receiving relevant emails, texts, letters, papers, voice messages, tapes or any other information
that:
1. Relate to any investigation and any interviews conducted by the USAO for the
Southern District of Florida and/or the USAO for the Southern District of New York
and FBI agents from either or both offices in 2008 in and around New York City,
including, but not limited to an interview of a
and/or communications
with
any other potential witness,
and any other
EFTA00014576

=== Page 2 ===
representative of any USAO for the Southern District of New York between January 1
- June 30, 2008. This request includes any communications prior to or during AUSA
March 2008 trip to New York and any communications that resulted from
the trip.
2. Relate to her communications with her victim witnesses either directly or through
their counsel wherein she discussed their right to confer with a USAO other than the
Southern District of Florida.
3. Relate to any communications with the USAO for the Southern District of New York
or FBI agents working with them at any time from 2007-2019.
4. Relate to the providing of any investigatory information or evidence to the USAO for
the Southern District of New York or FBI agents working with them at any time from
2007-2019.
Very truly yours,
Reid Weingarten
Martin G. Weinberg
Michael Miller
Martin G. Weinberg, P.C.
Steptoe & Johnson LLP
EFTA00014577


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=== Page 1 ===
From:
)"
To: "Weinstein, Marc A."
"Tomback, Andrew"
Cc:
)"
)"
Subject: RE: Estate call
Date: Wed, 15 Jan 2020 17:40:35 +0000
Marc, Andy,
We wanted to again follow up on the status of our request in December for prior wills and for photographs and videos,
and in particular the prior wills, which we had emailed about last week (and Marc mentioned he expected we'd hear back
about by last Thursday). Could you please let us know that status, including the volume of responsive materials possessed
by your respective clients and when we can expect to receive those materials? And if you expect we will not receive them
by this Friday, please let us know why that is.
thank you,
From: Weinstein, Marc A.
Sent: Tuesday, January 07, 2020 20:17
To:
Cc: Tomback, Andrew ;
;
Subject: Re: Estate call
Should be able to let you know by Thursday.
Marc A. Weinstein Partner
Co-Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or
error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in
the contents of this message, which arise as a result of e-mail transmission If verification is required please request a hard-copy version.
On Jan 7, 2020, at 7:57 PM,
wrote:
CAUTION: This email was sent by someone outside of the Firm.
Understood, thank you. Can you please let us know when you expect to have a response on prior wills in particular?
Understanding that's a much more narrow category than photos and videos.
thanks,
Alex.
From: Weinstein, Marc A.
Sent: Tuesday, January 07, 2020 19:45
To:
Cc: Tomback, Andrew
is
Subject: Re: Estate call
We don't think a call is needed tomorrow. We will get back to you on the requests.
Regards,
EFTA00016766

=== Page 2 ===
Marc
Marc A. Weinstein Partner
Co-Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or
error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in
the contents of this message, which arise as a result of e-mail transmission If verification is required please request a hard-copy version.
On Jan 7, 2020, at 6:32 PM,
wrote:
CAUTION: This email was sent by someone outside of the Firm.
Marc, Andy,
Did you want to have a call tomorrow? We don't presently have any substantive update on our end, but as usual would be
happy to talk if there's anything you think would be helpful to convey to us. Separately, we are also wondering about the
status of our request in December for prior wills and for photographs and videos; not sure if that's easier by email or by
phone.
Thanks very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00016767


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
86 Chambers Street
New York, New York 10007
August 3, 2020
By Electronic Mail
Robert Glassman, Esq.
Panish Shea & Boyle LLP
11111 Santa Monica Boulevard, Suite 700
Los Angeles, CA 90025
Re:
Request for Information Relating to Jeffrey Epstein
Dear Mr. Glassman:
I write in response to your letter dated June 8, 2020, seeking documents from the
Department of Justice ("DOJ") related to Jeffrey Epstein and plaintiff Jane Doe in Jane Doe V.
Indyke et al., No. 20-cv-484 (S.D.N.Y.). Because your request seeks information from
Department of Justice (the "Department") employees acquired during and as part of their
performance of their official duties, your request is governed by certain Department
regulations-commonly referred to as Touhy regulations-which, inter alia, prohibit any
Department employee from disclosing such information "without prior approval of the proper
Department official in accordance with §§ 16.24 and 16.25 of this part." 28 C.F.R. § 16.22(a);
see also United States ex rel. Touhy V. Ragen, 340 U.S. 462 (1951); 28 C.F.R. $ 16.21 et seq.
The "proper official" in this case is Audrey Strauss, the Acting United States Attorney for the
Southern District of New York.
The applicable Touhy regulations direct the Department to consider inter alia, "[w]hether
disclosure is appropriate under the rules of procedure governing the case or matter in which
the demand arose." 28 C.F.R. § 16.26(a)(1). The Department understands that there is an initial
pretrial conference scheduled for August 5, 2020, in Doe V. Indyke and that the parties in that
matter have already exchanged discovery demands and responses. See Scheduling Order dated
July 21, 2020, ECF No. 57, Doe V. Indyke et al., No. 20-cv-484 (S.D.N.Y.). In light of the
potential for formal discovery demands to issue in connection with Doe V. Indyke, the
Department has determined that disclosures in response to your pending request are appropriate
at this time and in lieu of any formal discovery request.
The applicable Touhy regulations forbid, inter alia, "[d]isclosure [which] would violate a
statute
or a rule of procedure, such as the grand jury secrecy rule," 28 U.S.C. § 16.26(b)(1).
Accordingly, the Department cannot provide any documents in its possession governed by the
grand jury secrecy rules set forth in Federal Rule of Criminal Procedure 6(e). See 28 U.S.C. §
16.26(b)(1).
Mindful of these considerations, the Acting United States Attorney has authorized the
Department to provide certain documents responsive to your request. Please find electronic
versions of these documents enclosed. The password for these documents will be sent to you by
separate cover.
EFTA00014452

=== Page 2 ===
Page 2
The enclosed documents are as follows:
Pages numbered USDOJ_0001-0040 are invoices from FedEx Corporation that
reference your client. Information therein has been redacted to exclude references
to third parties.
Pages numbered USDOJ_0041-0052 are documents obtained through electronic
search warrants that reference your client. Information therein has been redacted
to exclude references to third parties.
The page number USDOJ_0053 is a photo depicting your client obtained through
a physical search of Jeffrey Epstein's residence.
Please contact me once you have had a chance to review this letter if you would like to
discuss the issues herein further.
Sincerely,
AUDREY STRAUSS
Acting United States Attorney for the
Southern District of New York
By: /s/
Assistant United States Attorney
EFTA00014453


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=== Page 1 ===
From:
To:
Subject:
Date: Mon, 17 Jun 2019 00:27:22 +0000
Importance: Normal
https://www.curbed.com/2015/1/9/10004040/jeffrey-epstein-property-real-estate-holdings
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To: Jenna Dabbs
Roberta Kaplan
Conlon
, Alexandra Elenowitz-Hess
Cc:
)"
)"
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Date: Fri, 12 Jul 2019 02:28:46 +0000
Importance: Normal
Jenna,
Thanks very much on all counts, we appreciate it.
cheers,
From: Jenna Dabbs
Sent: Thursday, July 11, 2019 00:29
To:
>; Roberta Kaplan
>;
Conlon
>; ; Alexandra Elenowitz-Hess
Cc:
is
Subject: Re: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Hey
:
I think your conversation with Robbie earlier this evening covers things from our perspective. Thank you for
always making yourself available. As I know you know, we won't be shy if we need to connect on anything
further. And we will be rooting for you on Monday.
Best,
Jenna
Get Outlook for iOS
From:
Sent: Wednesday, July 10, 2019 10:08:08 PM
To: Roberta Kaplan;
Conlon; Jenna Dabbs; Alexandra Elenowitz-Hess
Cc:
);
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Or can dial into your conference number if that's preferable.
From:
)
Sent: Wednesday, July 10, 2019 22:07
To: 'Roberta Kaplan'
is
Conlon
>; Jenna Dabbs
is
Alexandra Elenowitz-Hess
Cc:
is
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Sure, I'm at my desk -
EFTA00014324

=== Page 2 ===
From: Roberta Kaplan
Sent: Wednesday, July 10, 2019 22:06
To:
>;
Conlon
>; Jenna Dabbs
>; Alexandra Elenowitz-Hess
Cc:
is
Subject: Re: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Can you talk?
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
New York, New York 10118
From:
Sent: Wednesday, July 10, 2019 5:56:39 PM
To:
Conlon; Roberta Kaplan; Jenna Dabbs; Alexandra Elenowitz-Hess
Cc:
);
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Hi all,
As you may already know, pursuant to the Crime Victims' Rights Act, specifically 18 U.S.C. 3771(a)(4), a crime victim has
the right to be reasonably heard at certain public proceedings in the district court, including proceedings involving
release. Accordingly, we wanted to be in touch consistent with our responsibilities and obligations-and your client's
rights-under that statute, to see whether your client would like to be heard in any fashion, whether through a
submission, a representation that we can include in our bail submission due Friday, or some other form. Of course no
requirement or obligation, but we would be happy to discuss it if that would be useful.
To the extent this information is useful in your consideration, I can say that while I don't want to prejudge the
Would it make sense to set up a brief call sometime tomorrow, if any of you want to discuss? I should be able to make
myself available whenever is convenient for you (and likely will be just me, as the remainder of the team will be traveling).
thank you,
Assistant U.S. Attorney
Southern District of New York
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
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.
EFTA00014325


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
)"
Subject: RE: Press Conference at Epstein's
Date: Mon, 27 Jan 2020 21:12:07 +0000
already called me. You can tell
that
and I connected.
From:
Sent: Monday, January 27, 2020 4:11 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: Fwd: Press Conference at Epstein's
Please see the below email from
Could somebody above the line level connect with
to discuss? We
also do not know what the office would like us to convey to the victims. Thanks.
Sent from my iPhone
Begin forwarded message:
From:
(NY) (FBI)"
Date: January 27, 2020 at 3:27:49 PM EST
To:
)"
)"
,
)"
Cc:
(NY) (FBI)"
Subject: Press Conference at Epstein's
All,
I have been getting some questions about the press conference that occurred today at Epstein's mansion, do any
of you know that was about? Our media affairs department has been getting questions. In addition, our Victim
Specialists have been fielding calls from irate victims who weren't notified.
https://twitter.com/AaronKatersky/status/1221833096686903299/photo/1
thanks,
SSA
Squad C-20
Crimes Against Children/Human Trafficking
FBI New York
office
mobile
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=== Page 1 ===
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
DATE FILED: 11/11/21
SOUTHERN DISTRICT OF NEW YORK
United States of America,
20-CR-330 (AJN)
-v-
OPINION & ORDER
Ghislaine Maxwell,
Defendant.
ALISON J. NATHAN, District Judge:
Before the Court is the Defense's motion to exclude the Government's expert witness,
Dr. Lisa Rocchio, pursuant to Federal Rule of Evidence 702 and the standard in Daubert V.
Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993). Dkt. No. 386. The Government filed
a response brief, Dkt. No. 397, and Defendant filed a reply, Dkt. No. 398. The Court conducted
a Daubert hearing on November 10, 2021, at which both parties examined Dr. Rocchio. Dkt.
No. 431. The Court stated its oral opinion at that hearing that it would deny and grant in part
Defendant's motion, to be followed by this opinion.
I.
Legal standard
Federal Rule of Evidence 702 governs the admissibility of expert testimony. That rule
states:
A witness who is qualified as an expert by knowledge, skill, experience, training, or
education may testify in the form of an opinion or otherwise if:
(a) the expert's scientific, technical, or other specialized knowledge will help the trier
of fact to understand the evidence or to determine a fact in issue;
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(b) the testimony is based on sufficient facts or data;
(c) the testimony is the product of reliable principles and methods; and
(d) the expert has reliably applied the principles and methods to the facts of the case.
The Court exercises a "gatekeeper function" in assessing the admissibility of expert
testimony. Restivo V. Hessemann, 846 F.3d 547, 575 (2d Cir. 2017). To determine whether an
expert's method is reliable, the Court considers the non-exhaustive list provided by the Supreme
Court in Daubert, including whether the expert's method has been tested, whether it has been
subjected to peer review, the rate of error, standards controlling the method's operation, and
whether the method is accepted by the expert community. United States V. Kidd, 385 F. Supp. 3d
259, 263 (S.D.N.Y. 2019) (citing Daubert, 509 U.S. at 593-94).
But Rule 702 ultimately sets a "liberal" and "permissive" standard of admissibility.
Nimely V. City of New York, 414 F.3d 381, 395-96 (2d Cir. 2005). In particular, not every expert
admissible under Daubert need rely on a method that conforms with "the exactness of hard
science methodologies." E.E.O.C. V. Bloomberg L.P., No. 07-CV-8383 (LAP), 2010 WL
3466370, at *13-14 (S.D.N.Y. Aug. 31, 2010) (quoting United States V. Simmons, 470 F.3d
1115, 1123 (5th Cir. 2006)).
II.
Discussion
As a preliminary matter, the Defense argues that the additional materials filed by the
Government in support of Dr. Rocchio's expertise should be excluded as failing to comply with
the Court's order that the Government make all expert witness disclosures by April 23, 2021.
Dkt. No. 250. But that Order, made pursuant to Federal Rule of Criminal Procedure 16(a)(1)(G),
required only that the Government provide an adequate summary of the intended topics and
opinions of Dr. Rocchio's testimony, which the Government did here in a timely manner. See
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Kidd, 385 F. Supp. 3d at 262. The Defense cites only one case, United States V. Lewis, which
involved the distinct situation where a district court excluded expert testimony because the notice
itself was untimely. 818 F. App'x 74, 79 (2d Cir. 2020). The Court concludes that the
Government's supplemental materials in further response to the Defense's motion are timely and
may be considered in resolving the Daubert motion.
Turning to the proffered expert opinions, as articulated in the Government's disclosure
and at the Daubert hearing, Dr. Rocchio would offer five expert opinions. First, that perpetrators
of sexual abuse of minors frequently use manipulation or coercion short of physical force as part
of a strategic pattern, often referred to as grooming, to make the minor vulnerable to abuse.
Second, that manipulation and grooming can prevent the minor from understanding their
experience as abuse and so prevent disclosure. Third, that abuse can cause long-term traumatic
and psychological consequences. Fourth, that the presence of another individual can facilitate
sexual abuse of minors. And fifth, that nondisclosure, incremental disclosure, and secrecy are
common among victims of sexual abuse and that memory can be affected by a variety of factors,
including the effects of trauma.
The Defense does not contest that Dr. Rocchio has the qualifications to express opinions
on these subjects. Dr. Rocchio has a PhD in clinical psychology and is a clinical instructor at the
Alpert Medical School of Brown University. She has more than two decades of experience
treating hundreds of victims of trauma, many of which were minor victims of sexual abuse. She
has published peer-reviewed articles on trauma and sexual abuse and has given numerous talks in
addition to her teaching. Given these papers, and her credible and extensive hearing testimony,
the Court therefore finds Dr. Rocchio qualified as an expert.
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The Defense instead argues that Dr. Rocchio's method is unreliable, that it is not relevant
to the jury's determination, and that its prejudicial effect would substantially outweigh its
probative value. These arguments rely heavily on a district court opinion from outside this
circuit, United States V. Raymond, 700 F. Supp. 2d 142 (D. Me. 2010). After careful
consideration of the Defense's arguments and the thorough reasoning in Raymond, the Court
concludes that Dr. Rocchio's anticipated testimony is admissible with one exception. The Court
will address first why Dr. Rocchio's testimony is admissible and then address the one opinion
that it will exclude.
First, Dr. Rocchio's method is reliable and well-accepted in her profession. It is for this
reason that several courts in this circuit have admitted the testimony of similar experts, such as
testimony on so-called trauma bonding to explain why prostitutes may not flee from their pimps
even when not physically restrained. In United States V. Kidd, the court admitted the testimony,
finding it to be "quite common[ ]" and accepted in the academic literature. 385 F. Supp. 3d at
263. Identical testimony was admitted by Judge Furman in United States V. Dupigny, No. 18-
Cr.-528 (JMF) (S.D.N.Y. 2019), Dkt. No. 198 at 27, by Judge Engelmayer in United States V.
Randall, 19 Cr. 131 (PAE) (S.D.N.Y. 2020), Dkt. No. 335 at 24-30, and by Judge Cote in United
States V. Torres, No. 20-CR-608 (DLC), 2021 WL 1947503, at *7 (S.D.N.Y. May 13, 2021).
Their decisions are consistent with the vast majority of courts to consider the admission
of such experts. A number of courts have admitted experts on the particular topic of grooming at
issue here, a sample of which include the Seventh Circuit in United States V. Romero, 189 F.3d
576, 585 (7th Cir. 1999), the Fifth Circuit in United States V. Hitt, 473 F.3d 146, 158 (5th Cir.
2006), the Ninth Circuit in United States V. Halamek, 5 F.4th 1081, 1087-89 (9th Cir. 2021), the
Tenth Circuit in United States V. Batton, 602 F.3d 1191, 1201-02 (10th Cir. 2010), the Eighth
4
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Circuit in United States V. Johnson, 860 F.3d 1133, 1141 (8th Cir. 2017), and the District of
Massachusetts in Doe ex rel. Pike V. Pike, 405 F. Supp. 3d 243, 249 (D. Mass. 2019).
Here, Dr. Rocchio has extensive experience treating minors who have been sexually
abused, and those decades of relevant experience, combined with her formal training, are an
adequate basis for her to testify on methods that perpetrators of sexual abuse often use to build
trust with their victims, whether that be grooming or other forms of manipulation and coercion.
The Government has also provided several articles on the subject of grooming that convince the
Court that it is a well-accepted theory in Dr. Rocchio's field. Though the Second Circuit has not
ruled on the admissibility of a grooming expert, it has previously recognized the academic
literature on grooming to facilitate sexual abuse of minors. See United States V. Brand, 467 F.3d
179, 203 (2d Cir. 2006). The Defense cites to several contrary articles that suggest experts
disagree on the kinds of behaviors that define grooming. But if experts disagree on the proper
interpretation of evidence, "it is not the Court's role to resolve the dispute through exclusion of
one of the expert's opinions." In re Digital Music Antitrust Litig., 321 F.R.D. 64, 80 (S.D.N.Y.
2017).
Moreover, Dr. Rocchio addressed these contrary articles during the Daubert hearing,
identifying points of agreement and disagreement. Based on her testimony, the parties'
submission and accompanying exhibits, the Court concludes that the core concept of grooming is
well-accepted in the relevant literature, even if experts continue to debate the details.
The Defense's primary argument is that Dr. Rocchio's method is unreliable because it is
based on her personal experience with the clients she has treated, that Dr. Rocchio did not verify
whether those clients were truthful, and that Dr. Rocchio has not and cannot identify an error
rate. The Court finds that these objections are misplaced in the field of clinical psychology,
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particularly when studying the causes and effects of sexual abuse of minors. The Court agrees
with Judge Engelmayer's response to this argument:
The absence of large quantity statistical studies is explained by a practical reason
that should be obvious to all. Studying the circumstances and psychological
drivers of trafficked women is not like studying diseases or potential cures in
laboratory animals. In those studies, laboratory conditions literally can be
achieved.
That strictly quantitative mode of inquiry is not realistic or even ethical in the
context of studying sex trafficking. The causes and contributors to sex trafficking
by their nature must be studied retrospectively. They cannot ethically be studied
otherwise. Subjects cannot be tested to see under what circumstances they would
and would not, on a going forward basis, fall prey to the predations of sex
traffickers. Given the necessarily retrospective nature of such a study, given the
small size of the populations under review, and given the inherently
individualized circumstances presented by different perpetrators, victims, and
contexts in this tumultuous and emotionally fraught area of criminal conduct, the
vocabulary of error rates and statistical significance is an unusually poor fit.
Tr. at 29-30, United States V. Randall, 19-Cr.-131 (PAE) (S.D.N.Y. 2020), Dkt. No. 335.
For the reasons Judge Engelmayer gave-which Dr. Rocchio echoed in her testimony-
the Court finds that the error-rate factor listed by Daubert is not determinative as to the reliability
of Dr. Rocchio's method.
For similar reasons, the Court rejects the Defense's argument that Dr. Rocchio's method
is unreliable because she relied on the reports of her clients. Given the realities of studying
sensitive criminal acts like sexual abuse, a researcher can only rarely verify reports with absolute
certainty. Yet that does not mean a clinical or forensic psychologist accepts all statements at
face value. Rather, as the Government notes, part of Dr. Rocchio's profession is to examine and
diagnose her patients consistent with her significant training and specialized knowledge.
Further, on the forensic side of her practice, Dr. Rocchio regularly investigates and verifies
sexual abuse. She reports "remarkable consistency" between the reports of her clinical patients
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and her forensic findings. Nov. 10 Tr. at 40. That said, the Defense is of course free to cross-
examine Dr. Rocchio about how she evaluates her patients.
The Defense also suggests that Dr. Rocchio's experience is based on an unrepresentative
sample of alleged victims because her patients self-selected seeking treatment with her. Yet the
Defense does not explain why Dr. Rocchio's experience with a large number of patients would
not be applicable to the alleged victims in this case. To the extent the Defense wishes to argue
that Dr. Rocchio's experience is under-representative, that is a topic for cross-examination.
Further, the Defense argues that Dr. Rocchio's experience treating victims of sexual
abuse does not make her an expert on grooming, which would require experience with
perpetrators themselves. This argument overlooks the fact that, as she testified, Dr. Rocchio also
relied on literature that includes studies of sexual abusers' reported behaviors. But more
importantly, the Court concludes, as other courts like the Ninth Circuit have, that extensive
experience with victims can be used to study perpetrators' process of victimization. See
Halamek, 5 F.4th at 1088. That is especially so here where the crux of Dr. Rocchio's expected
testimony is the effect that grooming behaviors have on the minor, not the perpetrator's mental
state when performing the behaviors.
Second, the Court finds that Dr. Rocchio's opinions are relevant to the Government's
case against Ms. Maxwell. Two points of law bear mention here. For one, as the Second Circuit
has explained, expert testimony cannot "constitute evaluations of witness credibility"-that is,
expert testimony is inadmissible if it "comment[s] directly, under the guise of expert opinion, on
the credibility of trial testimony from" specific fact witnesses. Nimely, 414 F.3d at 398.
Additionally, if the expert's "opinion is one that the jury could reach with their own "common
knowledge and common sense,' no expert testimony is warranted." Edmondson V. RCI Hosp.
7
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Holdings, Inc., No. 16-CV-2242 (VEC), 2020 WL 1503452, at *6 (S.D.N.Y. Mar. 30, 2020)
(quoting 4 Weinstein's Federal Evidence § 702.03 (2019)); see also United States V. Mulder, 273
F.3d 91, 101 (2d Cir. 2001) (explaining that "the district court should not admit testimony that is
"directed solely to lay matters which a jury is capable of understanding and deciding without the
expert's help" (quoting United States V. Castillo, 924 F.2d 1227, 1232 (2d Cir. 1991))). Dr.
Rocchio's first and second opinions may assist the jury in understanding how a minor may be
enticed, induced, or coerced into illegal sexual activity without physical force. These opinions
may also assist a jury in assessing evidence that some alleged victims repeatedly interacted with
Jeffrey Epstein, seemingly voluntarily, even after they suffered abuse. Dr. Rocchio's fourth
opinion is similarly relevant to the charges that require proving intentional enticement or
inducement.
Dr. Rocchio's third and fifth opinions pertain to issues that will arise in the case based on
anticipated cross-examination by the Defense. Specifically, the third opinion becomes relevant if
the Defense impeaches an alleged victim based on their substance abuse. And the fifth opinion
may become relevant if the Defense impeaches an alleged victim based on an ostensible delay in
fully disclosing sexual abuse. At the Daubert hearing, the Defense stated that they intended to
pursue both lines of impeachment at trial. Nov. 10 Tr. at 156-57. The Court therefore finds
these elements of Dr. Rocchio's testimony relevant to matters the Defense intends to put in issue
during anticipated cross-examination. The Court also concludes that these opinions satisfy the
other relevant Daubert requirements. Namely, they would assist the jury in understanding
concepts that require expert knowledge without directing the jury to reach any conclusion as to a
witness's credibility. Additionally, both Dr. Rocchio's opinion about sexual abuse's connection
to substance abuse and her opinion about delayed disclosure are "are outside the ken of the
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=== Page 9 ===
average person," and so appropriate for expert testimony. United States V. Felder, 993 F.3d 57,
72 (2d Cir. 2021). Nor would admission of these opinions cause unfair Rule 403 prejudice since
they are relevant rebuttal to impeachment points that the Defense will put in issue.
The Defense argues that Dr. Rocchio's testimony is not relevant because the Government
represents that she will testify only to general principles and not offer "testimony regarding any
specific victim." Dkt. No. 386 at 3. The Defense has the law backwards on this point. As
explained above regarding the Second Circuit's Nimely decision, an expert may not testify as to a
specific witness's credibility. 414 F.3d at 398. And as other courts have explained in admitting
similar testimony, Dr. Rocchio's testimony is appropriate because she does not testify as to any
specific witness's credibility. See, e.g., Torres, No. 20-CR-608 (DLC), 2021 WL 1947503, at
*7; Johnson, 860 F.3d at 1140 (8th Cir. 2017) (explaining that an expert may testify "regarding
the general characteristics that sexually abused children exhibit" but may not usurp the jury's
role of assessing the credibility of any specific victim); United States V. Telles, 6 F.4th 1086,
1097-98 (9th Cir. 2021) (same).
This analysis is referred to in the case relied upon by the Defense, United States V.
Raymond, and in portions of the Defense's briefing, as a question of "fit." 700 F. Supp. 2d at
149. But Daubert's "fit" requirement is really just a specialized relevance inquiry that asks
"whether expert testimony proffered in the case is sufficiently tied to the facts of the case that it
will aid the jury in resolving a factual dispute." Alto V. Sun Pharm. Indus., Inc., No. 1:19-CV-
09758 (GHW), 2021 WL 4803582, at *3 (S.D.N.Y. Oct. 13, 2021) (quoting Daubert, 509 U.S. at
591). Fit is satisfied if the expert's opinion would assist the jury's decision on a relevant
question of fact without "usurp[ing] either the role of the trial judge in instructing the jury as to
the applicable law or the role of the jury in applying that law to the facts before it." Id. (quoting
9
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=== Page 10 ===
United States V. Duncan, 42 F.3d 97, 101 (2d Cir. 1994)). For the reasons already provided, the
Court finds that fit is satisfied here.
Third, the probative value of Dr. Rocchio's testimony is not substantially outweighed by
403 prejudice to Ms. Maxwell. The Court finds that Dr. Rocchio's testimony would not unduly
"simplify' an otherwise complex case" or mislead jurors by a supposedly infallible expert. Dkt.
No. 386 at 11. Dr. Rocchio's opinions speak only to concepts and will not (and indeed may not)
suggest that the jury find any alleged victim witness to be credible or to find Ms. Maxwell guilty.
The more general nature of Dr. Rocchio's opinions, which the Court heard in detail at the
Daubert hearing, therefore mitigates its prejudicial effect. Telles, 6 F.4th at 1097. It is the jury's
role to determine whether and how Dr. Rocchio's opinions apply to the facts of this case and the
credibility of the witnesses.
Last, as previously mentioned, the Court will grant in part the Defense's Daubert motion.
The Defense argues that Dr. Rocchio's opinion that grooming can be done to facilitate sexual
abuse by a third party or that the presence of a third party can otherwise facilitate grooming is
unreliable. The Defense calls this "grooming-by-proxy." E.g., Dkt. No. 386 at 9. Terminology
aside, the Court agrees with this narrower objection to Dr. Rocchio's testimony. As discussed at
the hearing, this phenomenon is not identified in the relevant literature regarding child sexual
abuse and has not been subjected to peer review. Instead, the Court understands this opinion to
be an extrapolation of the broader principle of how grooming functions through the development
of trust. That extrapolation may be logical and follow common sense, but it is for the jury to
make on the facts of this case. The Court therefore excludes Dr. Rocchio's opinion that the
presence of a third party can facilitate grooming. Dr. Rocchio's core opinions about grooming,
however, remain admissible under the Rule 702 and Daubert standard and remain relevant
10
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=== Page 11 ===
pursuant to Rule 401 and not unduly prejudicial. As discussed, the jury may extrapolate from the
opinions that the presence of a third party creates the atmosphere of trust that can facilitate
grooming. Moreover, as the Government explains, Dr. Rocchio's testimony is still relevant
because the Government alleges both that Ms. Maxwell "in fact participated in sexual abuse of
minors" and that she "conspired with a predator who groomed and sexually abused minors."
Dkt. No. 397 at 27.
The Court therefore denies the Defense's motion to exclude Dr. Rocchio's testimony
except as to the opinion that the presence of a third party can facilitate grooming.
This resolves docket number 386.
so ORDERED.
Alim D.Netto
Dated: November 11, 2021
New York, New York
ALISON J. NATHAN
United States District Judge
11
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=== Page 1 ===
JANE DOE #13
(
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
O.A. 35
8/21/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 78
1/4/05
Conspiracy to entice a minor to
engage in prostitution
Ct. 16
8/21/04 -
EPSTEIN
Enticement of a minor to engage in
5/27/05
prostitution
Ct. 26
9/16/04
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 27
10/29/04
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 34
1/1/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 35
1/6/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 40
2/24/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 58
8/21/04 -
EPSTEIN
Recruiting, enticing, providing, or
5/27/05
obtaining a person, knowing that she
is a minor and will be caused to
engage in a commercial sex act
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 1 OF 1
JANE DOE #13
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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: RE: draft press release
Date: Sun, 28 Jun 2020 22:58:44 +0000
Attachments: 2020-06-27_GM_press_release_draft_(MC).docx.
Ah perfect, thanks - - and sorry to have not run it by you two before sending, I just figured it would go through so many
rounds that I figured I could incorporate any edits from you guys further down the road (once we're all done with actual
important stuff). And copying
in case she wants to look after the GJ stuff is finished tomorrow! I'll put these in
along with whatever comes from the chiefs - - and thanks in particular for catching that I accidentally swapped the maxes :
)
From:
Sent: Sunday, June 28, 2020 18:55
To:
Subject: RE: draft press release
In case it's helpful, I put a few edits to this in the attached. Thanks so much for taking the lead on it.
From:
Sent: Saturday, June 27, 2020 7:32 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: draft press release
I imagine this will go through many rounds of edits, but just to put something down on paper with plenty of time in
advance - see attached. I'll be out of pocket tonight (unless there's anything time-sensitive), but can turn edits tomorrow
no problem if that's useful.
thanks,
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11/26/21, 7:11 PM
Mail
(NY) (FBI) - Outlook
Accepted: GM Physical Evidence Review
>
Fri 4/9/2021 12:58 PM
To:
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
1/1
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Event: Accepted: DB/Epstein Meet
Start Date: 2019-07-25 14:30:00 +0000
End Date: 2019-07-25 15:00:00 +0000
Location: First Floor Conference Room
Class: X-PERSONAL
Comment:
Date Created: 2019-07-25 00:03:30 +0000
Date Modified: 2019-07-25 00:03:30 +0000
Priority: 5
DTSTAMP: 2019-07-24 21:17:44 +0000
Attendee:
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From:
)"
To:
)"
Cc:
(USANYS)"
Subject: Re: Jeffrey Epstein
Date: Mon, 31 Aug 2020 23:51:53 +0000
Yes! That's her! Thanks so much-I'll call her tomorrow.
On Aug 31, 2020, at 6:48 PM,
)
wrote:
Is it this person?
From:
(USANYS)
Sent: Friday, July 12, 2019 6:48 PM
To:
Cc:
(USANYS)
is
;
is
;
Subject: Re: Jeffrey Epstein
Thanks. Will raise up.
Sent from my iPhone
On Jul 12, 2019, at 6:24 PM,
wrote:
Below is the information that
attorney forwarded me about the State's attorney's office.
Thanks,
Sent from my iPhone
Begin forwarded message:
From:
Date: July 12, 2019 at 6:05:19 PM EDT
To:
:
Subject: Fwd: Jeffrey Epstein
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=== Page 2 ===
*** This email was sent via my iPhone using the dictation app. Please understand there may be some typographical
or grammatical errors.
NOTICE: This E-mail (including attachments) is covered by the Electronic Communications Privacy
Act, 18 U.S.C. 2510-2521, is confidential and may be ATTORNEY PRIVILEGED and CONFIDENTIAL.
It is intended only for the use of the individual or entity named as recipient. If the reader
of this message is not the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication or any of its contents, is strictly prohibited.
If you have received this communication in error, please notify sender immediately by re-sending
This communication to the sender and delete the original message and any copy of it from your
computer system.
Thank you for your cooperation.
Begin forwarded message:
From:
Date: July 12, 2019 at 11:22:04 AM EDT
To:
Cc: Marci Rex <mrex@sa15.org>
Subject: Jeffrey Epstein
Mr.
It was great touching base with you this morning. As I mentioned on the phone, the Office of the State Attorney is
interested in any information that could lead to criminal charges from that crimes occurred in Palm Beach County.
If you aware of any victims who would like to make a statement to local law enforcement please advise. Feel free to
pass my contact information on to anyone who might have information.
Regards-
Assistant State Attorney
Special Victim's Unit
Human Trafficking and ICAC
Office Of The State Attorney
15th Judical Circuit
Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records
available to the public and media upon request. Your e-mail communications may therefore be subject to public disclosure.
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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc: Christian Everdell
, "Mark S. Cohen"
Subject: Ghislaine Maxwell 02879-509
Date: Tue, 29 Dec 2020 01:41:41 +0000
Good evening,
We hope you and your family had a joyful holiday.
In response to your 12/14 email, we are requesting that Ms. Maxwell be permitted to use the laptop,
in lieu of the MDC computer,, during the typical. length of time other inmates are permitted out of
their cells (our understanding is 6 am - 9:30 pm daily, extended to 10:30 pm on weekends.)
The voluminous discovery is easier to access and review on the laptop. The MDC computer turns
off every two hours and is not capable of opening all documents, and volume of discovery may be too
taxing for the operating system.
We also want to bring to your attention some of the ongoing issues concerning Ms. Maxwell's
conditions and restrictions.
The constant rotation of security staff results in inconsistency of rules and restrictions, the current
shift being unnecessarily restrictive, punitive, and threatening.
Ms. Maxwell is ordered to remain in specific locations within her isolation cell
to accommodate capture on the handheld camera, restricting her use of an already small
confinement area.
Her use of the laptop has been restricted.
She is invasively surveilled while showering.
Her cell is cold and precipitation accumulates on the concrete block walls.
Over the holiday weekend, a third blanket, used by Ms. Maxwell to keep herself warm, was removed
leaving her cold; and she now has the onset of a cold.
The blanket was returned the next day, after complaint was made by counsel.
The open-mouth, wanding, pat-down, and in-and-behind ear searches continue,
with more frequently than other inmates are searched.
Her cell and legal papers are searched multiple times a day, a disruption to the organization of her
legal work and an invasion into her privileged work product.
She has not received daily newspapers for almost 3 weeks, and has not received certified mail
(return receipts indicating delivery to MDC on 12/17) and non-certified mail for more than a week.
We will keep you apprised of our concerns.
Your assistance is appreciated.
Best-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
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**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
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=== Page 1 ===
From:
To:
Subject:
Date: Sun, 16 Jun 2019 22:22:27 +0000
Importance: Normal
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#Florida Scans\efrey Epstein\ PBPD
Search Photos\scene 1\DCIM\100NCD70
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: just FYI
Date: Mon, 27 Jan 2020 22:38:52 +0000
Hey just passing this along from FBI, in case
didn't mention it, but apparently a number of victims have contacted
victims services very upset that our office didn't notify them that there was going to be a press conference at Epstein's
house.
Assistant U.S. Attorney
Southern District of New York
EFTA00016804


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=== Page 1 ===
From:
"
(NY) (FBI)"
To:
(USANYS)"
(USANYS)"
(USANYS) [Contractor]"
Subject:
Date: Fri, 24 Jul 2020 15:22:39 +0000
Attachments: Part_9.zip
Special Agent
FBI New York Field Office
Violent Crimes Task Force
Desk:
Cell:
EFTA00015849


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
)"
Cc: Christian Everdell
"Mark S. Cohen"
,
)"
(USANYS)"
Bcc:
Subject: Re: Ghislaine Maxwell 02879-509
Date: Tue, 29 Dec 2020 17:08:45 +0000
Embedded: Re:_Ghislaine_Maxwell_02879-509.msg
Sender:
Subject: Re: Ghislaine Maxwell 02879-509
Message-Id: <3A01B18C-6455-4C7F-807C-E036E3ACF28A@mac.com>
Recipient:
EFTA00015898


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=== Page 1 ===
From:
To:
Cc:
Subject: Draft letter to AJN re GM VTCs at MDC
Date: Sun, 22 Aug 2021 22:24:05 +0000
Attachments: 2021-08-18, GM, defense Letter re VTCs 8-18-18.pdf; 2021-08-
23_GM_Gov't_Letter_re_MDC_VTCs_v2.docx.
Hi
Attached for review please find a draft letter responding to Maxwell's most recent complaints about the MDC. I've
attached the defense letter for reference as well. Our letter is due by EOD tomorrow, so I'm simultaneously sending this
draft to MDC legal counsel for her to review for accuracy.
Thanks,
EFTA00015835


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=== Page 1 ===
From:
@gmail.com>
To:
Subject: NYTimes: Attorney General Sees Too Much Secrecy in Epstein Estate
Date: Tue, 28 Apr 2020 12:45:57 +0000
Attorney General Sees Too Much Secrecy in Epstein Estate
https://www.nytimes.com/2020/04/27/business/jeffrey-epstein-estate-secrecy.html?referringSourcearticleShare.
EFTA00015026


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 277 Filed 05/11/21 Page 1 of 2
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 5/11/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
The Court has considered the parties' proposals regarding the commencement of trial.
Dkt. Nos. 275, 276. For the reasons stated in the Government's letter, the Court will request
November 29, 2021 from the Clerk's Office as the trial start date-that is the date (pending
approval from the Clerk's Office consistent with the SDNY COVID protocols) that opening
statements will be made to the jury. However, the Court will also request from the Clerk's
Office that jury selection occur during the week of November 15. Counsel shall plan
accordingly.
The Court grants the Government's motion to exclude time until November 29, 2021.
The Court finds that the ends of justice served by granting an exclusion from speedy trial
computations for the period from today's date through November 29, 2021, outweigh the
interests of the public and the Defendant in a speedy trial, because this time is necessary to
permit the defense to continue to review discovery and other materials in light of the superseding
indictment; to permit the parties to prepare and file motions in limine; to permit the parties to
make and review additional pretrial disclosures; and to allow adequate time for the parties to
prepare for trial. Time is therefore excluded under the Speedy Trial Act, 18 U.S.C. §
3161(h)(7)(A), until November 29, 2021.
EFTA00014666

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 277 Filed 05/11/21 Page 2 of 2
In order to ensure that there is no delay in the commencement of trial, the Court will
adjust the current pre-trial schedule. So that the Court can resolve motions in limine in advance
of the November 29th trial commencement date, any such motions shall be fully briefed no later
than four weeks in advance of the anticipated trial commencement date of November 29. The
parties shall meet and confer to propose adjustments to other pre-trial disclosures accordingly.
The parties are hereby ORDERED to meet and confer for at least 30 minutes by phone
regarding the overall pretrial disclosure schedule and submit a joint letter by May 14, 2021. The
Court will accept only a joint letter with a joint proposal or with each side's views briefly stated.
The letter must attest to the meet and confer. Any separately filed letters will be struck.
so ORDERED.
Dated: May 11, 2021
Alim D.Netto
New York, New York
ALISON J. NATHAN
United States District Judge
EFTA00014667


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=== Page 1 ===
From: Sigrid McCawley
To:
Cc: Peter Skinner
Subject: FW: New documents:
V. Maxwell (Doc# -, 2d Cir. 20-02413)
Date: Thu, 30 Jul 2020 20:42:21 +0000
Attachments: 2020-07-30_[-].zip
Inline-Images: image001.jpg
Please see the attached Motion to Stay filed with the Second Circuit by Maxwell's counsel today. I will be responding to
this by tomorrow.
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
From: ECFdocuments@pacerpro.com [mailto:ECFdocuments@pacerpro.com]
Sent: Thursday, July 30, 2020 2:47 PM
To: Sigrid McCawley
Subject: New documents:
V. Maxwell (Doc# -, 2d Cir. 20-02413)
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
v. Maxwell
Docket entry number:
MOTION, to stay, on behalf of Appellant Ghislaine Maxwell, FILED. Service date
07/30/2020 by CM/ECF. [2896538] [20-2413]
Date entered: 2020-07-30
VIEW CASE
https://ap.pacerpro.com/cases/13420037
Sent from PacerPro, the fastest and most insightful way to access federal court records.
Questions? sales@pacerpro.com or (415) 890-4958
EFTA00017068

=== Page 2 ===
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
EFTA00017069


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: RE: Epstein
Date: Fri, 26 Apr 2019 16:09:13 +0000
Importance: Normal
Phew! Not losing my mind (at least on this one) just yet. thanks for double checking.
Original Message
From:
)
Sent: Friday, April 26, 2019 12:08 PM
To:
(USANYS)
Subject: RE: Epstein
Just spoke with
he searched his inbox for notes of calls and sorted out that it's the same person you spoke
with, just as you'd thought.
Original Message
From:
(USANYS)
Sent: Friday, April 26, 2019 11:50 AM
To:
(USANYS)
)
Subject: RE: Epstein
Sure, I'm in my office.
Original Message
From:
)
Sent: Friday, April 26, 2019 11:49 AM
To:
(USANYS)
i
)
Cc:
(USANYS)
Subject: RE: Epstein
Definitely can I swing by just to ask a few questions for clarity on format?
Original Message
From:
(USANYS)
Sent: Friday, April 26, 2019 11:43 AM
To:
Cc:
(USANYS)
)
Subject: Re: Epstein
would you be able to do this?
Sent from my iPhone
> On Apr 26, 2019, at 11:36 AM,
)
wrote:
V
> I'm traveling today, back on Sunday so could do it then or otherwise have to defer to
sorry.
V
EFTA00015889

=== Page 2 ===
> Sent from my iPhone
>
On Apr 26, 2019, at 10:35,
(USANYS)
wrote:
is going to meet with Brad Weinshiemer on Monday - can you guys put together an update memo this
afternoon on where we are, what we've done since the last update memo, and next steps? This just for
for now, not for sending down to DC.
Sent from my iPhone
EFTA00015890


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: Maxwell Opinion
Date: Mon, 16 Aug 2021 18:18:53 +0000
Attachments: Rule_17_opinion,_Maxwellpdf: Rule_17_government_brief,_Maxwell.pdf
Yup, attached! It's short and sweet. And also attaching the Government's brief on it.
It also looks like there may be another opinion on this issue that's currently under seal, but which is scheduled to
be made public on the 18th (according to the docket). I should still get the bounce on that when it's posted and
will send it along, too, if it's relevant.
Original Message
From:
(USANYS)
Sent: Monday, August 16, 2021 14:09
To:
)
Subject: Maxwell Opinion
Please can you send me the opinion you mentioned? Thanks!
EFTA00015858


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=== Page 1 ===
From:
To:
Subject: cd from agents
Date: Thu, 06 Dec 2018 22:43:59 +0000
The files from the disc
gave me today are all saved here:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\Case File_12.4.18
Assistant United States Attorney
Southern District of New York
EFTA00016298


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=== Page 1 ===
Event: FW: 227815.002 USA V GHISLAINE MAXWELL 20 CR 330 (AJN)
Start Date: 2021-11-24 19:00:00 +0000
End Date: 2021-11-24 19:30:00 +0000
Organizer: testimony
Location: att prep call
Class: X-PERSONAL
Date Created: 2021-11-24 15:45:49 +0000
Date Modified: 2021-11-24 15:45:49 +0000
Priority: 5
DTSTAMP: 2021-11-23 17:41:37 +0000
Attendee
Alarm: Display the following message 15m before start
Reminder
Original Appointment
From: testimony &lt;
&gt;
Sent: Tuesday, November 23, 2021 12:43 PM
To: testimony;
);
)
Subject: 227815.002 USA V GHISLAINE MAXWELL 20 CR 330 (AJN)
When: Wednesday, November 24, 2021 2:00 PM-2:30 PM (UTC-05:00) Eastern Time (US &amp;
Canada).
Where: att prep call
Microsoft Teams meeting
Join on your computer or mobile app
Click here to join the meeting
Join with a video conferencing device
att@m.webex.com
Video Conference ID:
Alternate VTC instructions
Or call in (audio only)
United States, Houston
Phone Conference ID:
EFTA00016467

=== Page 2 ===
Find a local number
I
Reset PIN
Learn More I Help I Meeting options
EFTA00016468


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
)"
Subject: RE: Contact info for victim
(Epstein vic)
Date: Sat, 13 Jul 2019 19:37:36 +0000
Importance: Normal
Yes can add, thanks, and yes can contact attorneys to ask who wants notification. (They may say all of them, but feel free
to check.) This is a victim we met with for the first time yesterday afternoon.
From:
(USANYS)
Sent: Friday, July 12, 2019 17:09
To:
is
is
(USANYS)
is
Subject: FW: Contact info for victim
(Epstein vic)
Can I add this person. I would like to email them and ask who would like to get notification in the case the system will
only allow me to put one law firm.
From:
Sent: Friday, July 12, 2019 4:45 PM
To:
(USANYS)
Subject: Contact info for victim
(Epstein vic)
Through her 3 attorneys.
1)Daniel Kaiser
Kaiser Saurborn & Mair P.C.
2) William Kaiser
Kaiser Saurborn & Mair P.C.
3) Kimberly Lerner
EFTA00014332

=== Page 2 ===
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=== Page 1 ===
From:
"
)"
To:
Cc:
)"
Subject: draft search warrant
Date: Sun, 07 Jul 2019 03:14:23 +0000
Importance: Normal
Attachments: Second_New_York_Residence_SW.v3.docx
is having some computer issues so I'm sending - please see attached.
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00015572


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=== Page 1 ===
JANE DOE #8 (
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
O.A. 110
3/7/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 124
4/2/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 128
4/11/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 133
5/9/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 136
6/12/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 138
6/20/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 139
6/30/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 141
7/2/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 142
7/22/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 145
8/18/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 146
8/19/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 147
8/21/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 149
9/3/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 150
9/8/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 152
9/18/05
Conspiracy to entice a minor to
engage in prostitution
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 1 OF 2
JANE DOE #8
EFTA00016006

=== Page 2 ===
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
O.A. 154
9/29/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 156
10/3/05
Conspiracy to entice a minor to
engage in prostitution
Ct. 12
2/13/05 -
EPSTEIN
Enticement of a minor to engage in
10/3/05
prostitution
Ct. 47
5/19/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 48
6/30/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 49
9/9/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 50
9/18/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 56
2/13/05 -
EPSTEIN
Recruiting, enticing, providing, or
10/3/05
obtaining a person, knowing that she
is a minor and will be caused to
engage in a commercial sex act
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 2 OF 2
JANE DOE #8
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=== Page 1 ===
10/6/21, 12:43 PM
III/FBI/State Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
III Information
FINGERPRINT CLASS
PATTERN CLASS
IDENTIFICATION DATA UPDATED 2018/01/16
THE RECORD(S) CAN BE OBTAINED THROUGH THE INTERSTATE IDENTIFICATION
INDEX BY USING THE APPROPRIATE NCIC TRANSACTION.
END
1/2
EFTA00015113

=== Page 2 ===
10/6/21, 12:43 PM
III/FBI/State Delayed Response
2/2
EFTA00015114


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=== Page 1 ===
From:
To: "Strauss, Audrey (USANYS)"
Subject: RE: Your outstanding work
Date: Tue, 07 Jul 2020 16:32:59 +0000
Really appreciate the kind words, thank you. And looking forward to the WebEx - hopefully this afternoon!
Original Message
From: Strauss, Audrey (USANYS)
Sent: Monday, July 06, 2020 21:07
To:
Subject: Re: Your outstanding work
,
I think you did a spectacular job, first with Epstein, and now with Maxwell. And from what I could see, the
teamwork was excellent.
You have my thanks and admiration.
Let's be sure to schedule the team Webex when you all have time to do it.
Audrey
Sent from my iPhone
> On Jul 6, 2020, at 5:07 PM,
wrote:
V
> Audrey,
>
> This is now belated -- I confess that even I took a couple days off this past weekend! but I wanted to say
thank you for the kind words, and to express appreciation for your support of this investigation, not only in the
initial Epstein prosecution but through the new angle on Maxwell and follow-up on other individuals as well.
Everyone all the way up the chain has really cared about this the whole way through, and it was a team effort to
work through the byzantine legal issues, the challenges with various witnesses, and all the other ancillary things
that came up along the way. As one of the victim's counsel said to us recently, it has helped to right two wrongs
- the initial wrong of what Epstein and Maxwell did, and the secondary wrong of how it was approached by the
government the first time around. So, thank you again, and we're looking forward to the next stages.
>
V
V
V
V
Original Message
> From: Strauss, Audrey (USANYS)
> Sent: Thursday, July 02, 2020 13:26
> To:
i
> Cc:
> Subject: Your outstanding work
V
> Team,
> While I got to stand up and talk about the indictment, it was your dogged and ingenious work that made it
possible for this office to bring this very worthy indictment.
EFTA00015204

=== Page 2 ===
> We will still look for a time to have a Webex celebration of this milestone.
> Enjoy the holiday weekend.
> Audrey
>
> Sent from my iPhone
EFTA00015205


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=== Page 1 ===
From: Jack Scarola
To:
)"
Cc:
)"
(USANYS)"
Subject: Re: 12/04/09
VS Epstein Deposition Transcript
Date: Mon, 14 Sep 2020 18:35:38 +0000
I am unaware of any protective order relating to the
case.
On Sep 14, 2020, at 12:10 PM,
)
wrote:
Jack,
Are you able to tell us whether there was a protective order entered in the civil suit, or any other type of agreement that
would govern disclosing materials from the civil case with us? When you shared the deposition, we assumed there were
no such restrictions, but I wanted to check.
Thanks,
From: Jack Scarola
Sent: Thursday, September 10, 2020 3:46 PM
To:
Cc:
is
(USANYS)
Subject: Re: 12/04/09
VS Epstein Deposition Transcript
Please let me know if you are able to locate the transcript.
On Sep 10, 2020, at 11:30 AM,
-
wrote:
Jack,
Thanks for your email. We will likely reach out to your adversary in the deposition to ask for a copy, but I wanted to check
to see whether you had already done so.
Thanks,
From: Jack Scarola
Sent: Wednesday, September 9, 2020 9:53 AM
To:
is
V.
(USANYS)
Subject: Fwd: 12/04/09
VS Epstein Deposition Transcript
The email exchange below confirms our inability to locate the first volume of
deposition. However, attached are
fairly detailed notes of Paralegal/Investigator Mike Danchuk, who attended the deposition and recorded these notes
EFTA00016311

=== Page 2 ===
contemporaneously.
appears to have held nothing back, and the notes certainly paint a picture of the kind of
troubled young women who were particularly susceptible to Epstein's pattern of recruitment, grooming and
victimization.
Sent from my iPad
Begin forwarded message:
From: "Chris R. Rodgers"
Date: September 8, 2020 at 3:30:51 PM EDT
To: Jack Scarola
Cc: Mary McCann
"Wendy P. Calvet"
'cmavsepsteinetalz6385257@projects.filevine.com cmavsepsteinetalz6385257@projects.filevine.com
Subject: FW: 12/04/09
vs Epstein Deposition Transcript
Jack, below is the "Unable to locate" response from Prose Court Reporting. Visual Evidence, the videography
service used, also confirmed on Friday that a copy of the video is no longer available. I have attached Mike
Danchuk's notes from that deposition.
From: toni proseflorida.com
Sent: September 7, 2020 7:03 AM
To: Chris R. Rodgers
Subject: RE: 12/04/09
vs Epstein Deposition Transcript
Chris,
I have searched our records and archives and I am unable to locate Volume I of this deposition from
2009.
Sincerely,
Toni
Privileged and Confidential I Electronic communication is not a secure mode of communication and may be
accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola
Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-
2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin.
2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is
not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this
communication is strictly prohibited. Personal messages express views solely of the sender and shall not be
attributed to the law firm. If you received this communication in error, please notify the sender immediately by
e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank you.
EFTA00016312


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=== Page 1 ===
From:
To:
Subject: Re: Ghislaine Maxwell custody
Date: Fri, 03 Jul 2020 18:01:10 +0000
Yes
Sent from my iPhone
On Jul 3, 2020, at 1:01 PM,
wrote:
Thanks! Am I correct that this means Maxwell will be able to call both Chris and Mark today?
(And please tell
hi back!)
On Jul 3, 2020, at 12:47 PM,
wrote:
Done.
P.S.
says hi!
From:
Sent: Friday, July 3, 2020 12:42 PM
To:
Subject: RE: Ghislaine Maxwell custody
Terrific, thanks very much.
Both attorneys are partners at Cohen & Gresser LLP.
Chris Everdell's number is
Mark Cohen's number is
Thanks again,
From:
Sent: Friday, July 3, 2020 11:39 AM
To:
Subject: RE: Ghislaine Maxwell custody
Gene is on it. Can I please have name of law firm and best contact number for each lawyer?
EFTA00014912

=== Page 2 ===
Thanks
From:
Sent: Friday, July 3, 2020 11:32 AM
To:
Subject: RE: Ghislaine Maxwell custody
Appreciate it, thank you.
From:
Sent: Friday, July 3, 2020 11:21 AM
To:
Subject: Re: Ghislaine Maxwell custody
I will cal
and advise - - he can be a little touchy.
Sent from my iPhone
On Jul 3, 2020, at 11:13 AM,
wrote:
Thanks. I think it's fine to speak with
about it, but my sense is that we would also need USMS approval, based
on the email from
If you think it would be ok, I'm happy to reach out
directly to discuss.
From:
Sent: Friday, July 3, 2020 11:05 AM
To:
Subject: Re: Ghislaine Maxwell custody
I will try. Can I start with
he may be in the best position to get it done?
Sent from my iPhone
On Jul 3, 202
Thanks very much for passing this along. The permitted attorney contact on the list below only includes Vogelman
without reference to her New York counsel. Would it be possible to add her two New York attorneys-Chris
Everdell and Mark Cohen-to the list of people Maxwell can speak with on the phone, please?
Ideally, we would like to get them added today so that they can speak with their client over the weekend to
facilitate our discussions with them about next steps in the case.
Thanks,
EFTA00014913

=== Page 3 ===
From
Sent: Thursday, July 2, 2020 3:47 PM
To:
Subject: Fwd: Ghislaine Maxwell custody
FYI
Sent from my iPhone
Begin forwarded message:
From:
Date: July 2, 2020 at 3:43:43 PM EDT
To: "NHD-SUPERVISORS (USMS)"
Cc:
Subject: Ghislaine Maxwell custody
To all:
Below are the restrictions we have put in place regarding Ms. Maxwell during her stay at Merrimack DOC. I. If you
have any questions please feel free to call or email me.
Due to the high profile status of this case Inmate Maxwell will be closely monitored. The following
directives apply and shall not be deviated from without express permission from
, myself or
1.
Inmate Maxwell will be housed in M1
2.
SRT personnel will be posted in medical and will only be relieved only by SRT personnel
3.
Staff will not converse with the inmate outside of the standard communication required related to
the inmate's health and safety
4.
Inmate Maxwell will remain on a 15 minute observation watch
5.
All rounds, and touch probe rounds will be conducted and documented in XJail
6.
Third Shift Supervisors will download the touch probe rounds and camera footage from the
previous day at 0000 hours each day. The video from the medical cell DVR will be downloaded onto a
USB drive and will be tracked via the designated tracking form provided. Supervisors are directed to
deliver this documentation and video to
Monday July 6th
7.
Inmate Maxwell will be authorized to communicate with her legal counsel, Lawrence Vogelman.
This contact is only authorized after Atty Vogelman provides the appropriate PIN
8.
Any and all requests from Inmate Maxwell are to be directed to
only
At no time are staff authorized to make statements to the press regarding this matter or our SOP
regarding
t
ene
EFTA00014914

=== Page 4 ===
Supervisory Deputy United States Marshal
District of New Hampshire
Concord, New Hampshire
office
This e-mail is property of U.S. Marshals Service. It is intended only for the person or entity to which it is addressed
and may contain information that is privileged, confidential, or otherwise protected from disclosure. Distribution
or copying of this e-mail or the information contained herein by anyone other than the intended recipient is
prohibited. If you have received this e-mail in error, please notify me immediately and destroy all electronic and
paper copies of this e-mail.
EFTA00014915


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c0:
=== Page 1 ===
From: Marc Fernich
To:
)"
Cc: Marty Weinberg
Martin Weinberg
)"
Subject: Re: Epstein Arrest Seizure Items
Date: Tue, 16 Jul 2019 00:36:00 +0000
Understood. Thursday's fine. Thanks.
Marc Fernich, Esq.
Sent from my iPhone
On Jul 15, 2019, at 8:34 PM,
wrote:
Marc,
Circling back on this, I'll ask the agents to bring the cash and other personal effects seized from Mr. Epstein to the
hearing on Thursday, unless it is important to receive them before then, in which case please let me know and l'll try to
arrange that. With respect to the electronic devices, we've obtained a warrant to search them and so will be retaining
them as evidence.
thanks,
From: Marc Fernich
Sent: Thursday, July 11, 2019 15:54
To:
Cc: Marty Weinberg
>; Martin Weinberg
is
Subject: Epstein Arrest Seizure Items
Hi
Sorry to bug you while you may be working on a bail reply.
I'm having trouble reaching Agent
to coordinate pickup of the cellphone and other items seized upon Epstein's
arrest. She said she'd be out in the field, but I don't hear from the intermediary agent - identity unknown - who was
supposed to handle it in her absence. Can you step in and try to move this along?
Thanks a lot.
EFTA00014560

=== Page 2 ===
Marc Fernich, Esq.
810 Seventh Ave.
Sent from my iPhone
On Jul 9, 2019, at 3:26 PM,
)
wrote:
Marc,
It is the right number, so feel free to follow up later, but I can also give you her cell number which is
thanks,
From: Marc Fernich
Sent: Tuesday, July 09, 2019 14:56
To:
)
Cc: Marty Weinberg
>; Martin Weinberg
;
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Sorry to trouble again. No answer or VM pickup at that number. I'll try again later so long as it's the right number. Can
you confirm? Many thanks.
Marc Fernich, Esq.
810 Seventh Ave.
Sent from my iPhone
On Jul 9, 2019, at 2:45 PM,
wrote:
Marc,
Apologies for the delay on this, and thanks for following up. The best way to coordinate this is to contact the case
agent directly - I just spoke to her so she'll be expecting your call. They're running around, so if you reach out and
aren't able to connect today please let me know, but hopefully we can get it coordinated. The contact is Special
Agent
and she can be reached at
EFTA00014561

=== Page 3 ===
thanks,
From: Marc Fernich
Sent: Monday, July 08, 2019 15:40
To:
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
One of your agents told Marty the case agent would return Epstein's phone, the cash and other items taken from his
person upon arrest. Marty's returning to Boston shortly. Can you arrange for me to take possession of those items?
Thanks,
Marc
Marc Fernich, Esq.
Sent from my iPhone
On Jul 8, 2019, at 10:53 AM,
wrote:
Marc,
Wanted to send this to you as well in case your co-counsel can't receive it in the Court. Please let me know if it
would be helpful to get a hard copy - I'm copying two of our paralegals who can bring you (or co-counsel) a copy;
l'll be unreachable for the next hour or so.
thank you,
From:
Sent: Monday, July 08, 2019 10:43
To:
Cc:
Martin Weinberg'
>; 'rweingarten@steptoe.com
is
is
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
To the Chambers of Judge Pitman:
EFTA00014562

=== Page 4 ===
In advance of the expected bail argument in the above-captioned case, in connection with the presentment and
arraignment referred by Judge Berman, attached please find a memorandum from the government on the issue of
detention. Defense counsel is copied, as is the chambers of Judge Berman at their request.
Thank you,
Assistant U.S. Attorney
Southern District of New York
<U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum.pdf>
EFTA00014563


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016122.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: I mean
Date: Thu, 07 Nov 2019 19:54:33 +0000
jesus.
https://nypost.com/2019/11/07/paging-epstein-coverup-airport-says-message-was-a-mistake/
Assistant U.S. Attorney
Southern District of New York
EFTA00016122


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015037.pdf
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c7: images
c0:
=== Page 1 ===
UNCLASSIFIED//FOUO
No.
Name
DOB
Source
P
1
NYPD 1999
X
2
NYPD 2019
X
3
NYPD 2010
X
4
NYPD 2010
X
5
PP/2004
X
6
NYPD 2020
X
7
Jeffrey Epstein
1/20/1953
PB 2006
X
8
NYPD 1998
X
9
NYPD 2017
X
10
NYPD 2021
X
11
NYPD 2017
X
12
NYPD 2016
X
13
US PP/2002
X
14
NYPD 2021
X
15
NYPD 2018
X
16
Ghislaine Maxwell
12/25/1961
US PP/2003
X
17
NYPD 2009
X
18
NYPD 2021
X
19
NYPD 2018
X
20
NYPD 2001
X
UNCLASSIFIED//FOUO
EFTA00015037

=== Page 2 ===
UNCLASSIFIED//FOUO
1
UNCLASSIFIED//FOUO
EFTA00015039

=== Page 3 ===
EFTA00015039
N

=== Page 4 ===
EFTA00015040
E

=== Page 5 ===
UNCLASSIFIED//FOUO
4
UNCLASSIFIED//FOUO

=== Page 6 ===
UNCLASSIFIED//FOUO
5
UNCLASSIFIED//FOUO
EFTA00015042

=== Page 7 ===
9

=== Page 8 ===
UNCLASSIFIED//FOUO
7
UNCLASSIFIED//FOUO
EFTA00015044

=== Page 9 ===
8

=== Page 10 ===
6

=== Page 11 ===
110

=== Page 12 ===
11

=== Page 13 ===
EFTA00015049
12

=== Page 14 ===
UNCLASSIFIED//FOUO
13
UNCLASSIFIED//FOUO
EFTA00015050

=== Page 15 ===
UNCLASSIFIED//FOUO
14
UNCLASSIFIED//FOUO
EFTA00015051

=== Page 16 ===
UNCLASSIFIED//FOUO
15
UNCLASSIFIED//FOUO
EETA00015052

=== Page 17 ===
UNCLASSIFIED//FOUO
16
UNCLASSIFIED//FOUO
EFTA0001505:

=== Page 18 ===
EFTA00015054
17

=== Page 19 ===
UNCLASSIFIED//FOUO
18
UNCLASSIFIED//FOUO
EFTA00015055

=== Page 20 ===
UNCLASSIFIED//FOUO
19
UNCLASSIFIED//FOUO
EFTA00015056

=== Page 21 ===
EFTA00015057
20


c1: EFTA00014438
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014438.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
eJusticeNY Integrated Justice Portal
Page 1 of 10
eJusticeNY
INTEGRATED JUSTICE PORTAL
People
Sex Offenders
Full Registry Search
+1
Feedback
SOMS Full Registry Search
Full Registry Search
BACK
DONE
Offender Details
Domiciled
Informational Data is available.
Access to New York State Sex Offender Registry information is governed by Correction Law Article 6-C. Pursuant
to Correction Law Section 168-b (2)(e), no information in the Registry shall be made available except in
furtherance of the provisions of the Sex Offender Registration Act (SORA). Access to Registry information through
eJusticeNY is allowed solely for Registry purposes. The information contained in the Sex Offender Registry
through eJusticeNY should not be shared with the public Unauthorized release of Registry information is a crime.
Anyone who uses this information to injure, harass, or commit a criminal act against any person may be subject to
criminal prosecution.
A law enforcement agency having jurisdiction and which is authorized under SORA to perform community
notification on sex offenders living within the agency's jurisdiction should refer to the offender specific
notifications sent by the DCJS Sex Offender Registry to the jurisdiction regarding what community
notification, if any, is permitted. If a jurisdiction has questions regarding community notification, please
refer to the Community Notification Document available on eJustice or call the Registry at (518) 417-3385.
Offender ID: 33216
Sex: Male
NYSID: 4614879Q
Race: White
FBI Number: 787075K6
Ethnicity: Unknown
SSN:
Height: 6'00'
NCIC Number: X152300377
Weight: 180
Last Name: EPSTEIN
Hair: Gray
First Name: JEFFREY
Eyes: Blue
Middle Name: E
Corr. Lens:
DOB: Jan 20, 1953
Photo Date: Apr 27, 2018
View Additional Photos
Additional Names / Aliases:
Last Name
First Name
Middle Name
EPSTEIN
JEFFREY
EDWARD
Scars, Marks Tattoos:
Description
Telephone Numbers:
Type
Number
Home
Risk Level Information:
Level
Designation
Date Assigned
Date Entered
Injunction Settled
3
No Designation Applies
Jan 18, 2011
Jan 24, 2011
P
May 4, 2010
Current Addresses:
Time Category Location Name and Street Address
City
County/Country State
Zip
P
RES
ST
Virgin
00802
THOMAS
Islands
S
RES
France
S
RES
ST
Virgin
00802
THOMAS
Islands
S
RES
PALM
Florida
33480
BEACH
S
RES
France
S
RES
STANLEY
New
87056
Mexico
S
RES
NEW
New York
New
10021-4102
YORK
York
P
EMP
ST
Virgin
00802
THOMAS
Islands
Show Previous Addresses
https://www.ejustice.ny.gov/wps/myportal/!ut/p/a1/jZBbb4JAEIV_Sx94arlziFx8BC8UY.
6/28/2019
EFTA00014438

=== Page 2 ===
eJusticeNY Integrated Justice Portal
Page 2 of 10
+
Show Future Addresses
Jurisdiction Agency:
Agency Name
Street
City
County State
Zip
Virgin Islands Dept of Justice Sex GERS Building Second Floor, 48B-50C
St
Virgin
00802
Offender Registry
Kronprindsens Gade
Thomas
Islands
Other Address Info or Status:
Current Internet Details:
Email Address
Screen Name
Service Providers
VIRGIN ISLANDS TELEPHONE CORPORATION DBA VIYA
QWEST COMMUNICATIONS COMPANY LLC DBA CENTURY LINK
SIGNAL SERVICE
CONFIDE MESSAGING SERVICE
WHATSAPP MESSAGING SERVICE
LEVEL 3 COMMUNICATION
CENTURY LINK
VERIZON
FREE TELECOM
AT&T
ORANGE TELECOM
COMCAST
TIME WARNER/SPECTRUM
Show Previous Internet Details
Current Driver Licenses:
License Number
License State
Virgin Islands
Virgin Islands
Show Previous Driver Licenses
Current Vehicles:
Lic. Plate No.
State
Vehicle Year
Make/Model
Color
2008
2015
General Motor Corp. Yukon
Black
2018
2015
https://www.ejustice.ny.gov/wps/myportal/!ut/p/a1/jZBbb4JAEIV_Sx94arlziFx8BC8UY0.
6/28/2019
EFTA00014439

=== Page 3 ===
eJusticeNY Integrated Justice Portal
Page 3 of 10
2019
Chevrolet Suburban
Black
2019
Chevrolet Suburban
Black
2016
Chevrolet Suburban
Black
2018
Chevrolet Suburban
Black
2007
Gulf Stream Unknown
2011
2017
Chevrolet Express
Black
2017
Bentley Mulsanne
1989
2016
Chevrolet Suburban
Black
2012
Cadillac Escalade
Black
1989
2012
Cadillac Escalade
Black
2015
General Motor Corp. Denali
Black
2010
Chevrolet Suburban
Black
2013
2015
Chevrolet Suburban
Black
2015
General Motor Corp. Yukon
Black
2015
Chevrolet Suburban
Black
2012
1988
2001
2013
Ford Expedition
Black
2008
Land Rover Range Rover
Black
2007
Hummer Hummer II
Black
2002
Mercedes-Benz 500 Series
Black
2010
Chevrolet Suburban
Black
1968
2008
2006
2011
2011
1999
+
Show Previous Vehicles
Current Registration:
Date
Signature
Ending Date
90 Day Verification
Apr 15, 2010
Yes
Life
Yes
Address At Time of Arrest:
Time Category Location Name and Street Address
City
County/Country State
Zip
P
RES
UNKNOWN
UNKNOWN
Arrest Agency:
Florida Dept of Law Enforcement Sex Offender Registry
Conviction:
Crime Date
Arrest Date
Conviction Date
Victim Sex/Age
Jul 23, 2006
Jul 23, 2006
Jun 30, 2008
Female 14 Years
Female 16 Years
Female Unknown
Conviction Charges:
(Please note: a conviction for an attempt is generally punishable at one grade below the classification of
the crime attempted, i.e., a rape 3rd degree is punishable as a class E felony while an attempted rape 3rd
degree is punishable as a class A misdemeanor.)
Title
Section
Subsection
Class
Category
Counts
Description
OUT
000000000
000000
U
F
1
Non-NYS Felony Sex Offense
Offense Description Modus Operandi:
Offense Description:
Actual,MoreThanOnce Sexual Intercourse
Actual,MoreThanOnce Deviate Sexual Intercourse
Actual,MoreThanOnce Sexual Contact
Relationship to victim:
None Reported
Weapon used:
None Reported
Force used:
Detail unknown
Computer used:
None Reported
Pornography involved:
None Reported
Sentencing:
https://www.ejustice.ny.gov/wps/myportal/!ut/p/al/jZBbb4JAEIV_Sx94arlziFx8BC8UY.
6/28/2019
EFTA00014440

=== Page 4 ===
eJusticeNY Integrated Justice Portal
Page 4 of 10
Court
Docket
OS1909
Sentence:
Probation: 6 Month(s) Term: Time Served Unspecified
Supervising Agency Information:
Agency
Officer
Telephone Number
Special Conditions of Supervision:
Maximum Expiration Date/Post Release Supervision Date of Sentence:
Jul 21, 2010
Notifying Agency Information:
Agency
Officer
Telephone Number
NYS Board of Examiners of Sex Offenders
UNKNOWN
+
Show Previous Registration(s)
Note:
OTHER SSN: 090-41-3348
Communications:
Display Criteria:
Show All
Date
Description
Sent To/ Received From
Jun 17, 2019
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jun 17, 2019
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Jun 17, 2019
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Jun 17, 2019
SOR Change
Sent to Florida Dept of Law Enforcement Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Apr 24, 2019
Annual Verification
Received from Offender
Received
Apr 9, 2019
Annual Verification
Sent to EPSTEIN,JEFFREY at 6100 RED HOOK QUARTER, B3,
to Offender
ST THOMAS, VI, 00802
Mar 20, 2019
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Mar 20, 2019
SOR Change
Sent to Florida Dept of Law Enforcement Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Mar 20, 2019
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 48B-50C Kronprindsens Gade,
St Thomas, VI, 00802
Mar 20, 2019
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Mar 5, 2019
Offender Photo Due
Sent to JEFFREY E EPSTEIN at 6100 RED HOOK QUARTER, B3,
Letter
ST THOMAS, VI, 00802
Mar 5, 2019
Agency Photo Due
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jan 7, 2019
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Jan 7, 2019
SOR Change
Sent to Florida Dept of Law Enforcement Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Jan 7, 2019
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Jan 7, 2019
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 48B-50C Kronprindsens Gade,
St Thomas, VI, 00802
Dec 24, 2018
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Dec 24, 2018
SOR Change
Sent to New Mexico Dept of Public Safety Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Dec 24, 2018
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Dec 24, 2018
SOR Change
Sent to Florida Dept of Law Enforcement Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Nov 7, 2018
SOR Change
Sent to Florida Dept of Law Enforcement Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Nov 7, 2018
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Nov 7, 2018
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
https://www.ejustice.ny.gov/wps/myportal/!ut/p/a1/jZBbb4JAEIV_Sx94arlziFx8BC8UY..
6/28/2019
EFTA00014441

=== Page 5 ===
eJusticeNY Integrated Justice Portal
Page 5 of 10
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Nov 7, 2018
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Oct 9, 2018
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Oct 9, 2018
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Oct 9, 2018
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Oct 9, 2018
SOR Change
Sent to Florida Dept of Law Enforcement - Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Jul 10, 2018
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jul 10, 2018
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Jul 10, 2018
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Jul 10, 2018
SOR Change
Sent to Florida Dept of Law Enforcement - Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Apr 19, 2018
Annual Verification
Received from Offender
Received
Apr 19, 2018
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Apr 19, 2018
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Apr 19, 2018
SOR Change
Sent to Florida Dept of Law Enforcement - Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Apr 19, 2018
SOR Change
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 9, 2018
Annual Verification
Sent to JEFFREY E EPSTEIN at 6100 RED HOOK QUARTER, B3,
to Offender
ST THOMAS, VI, 00802
Mar 5, 2018
Offender Photo Due
Sent to JEFFREY E EPSTEIN at 6100 RED HOOK QUARTER, B3,
Letter
ST THOMAS, VI, 00802
Mar 5, 2018
Agency Photo Due
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Feb 6, 2018
SOR Change
Sent to Florida Dept of Law Enforcement Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Feb 6, 2018
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Feb 6, 2018
SOR Change
Sent to New Mexico Dept of Public Safety Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Feb 6, 2018
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Feb 1, 2018
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Feb 1, 2018
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Feb 1, 2018
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Feb 1, 2018
SOR Change
Sent to Florida Dept of Law Enforcement - Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Jan 23, 2018
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jan 23, 2018
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Jan 23, 2018
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Jan 23, 2018
SOR Change
Sent to Florida Dept of Law Enforcement Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Aug 9, 2017
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Aug 9, 2017
SOR Change
Sent to Florida Dept of Law Enforcement Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Aug 9, 2017
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Aug 9, 2017
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jul 20, 2017
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Jul 20, 2017
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
https://www.ejustice.ny.gov/wps/myportal/!ut/p/a1/jZBbb4JAEIV_Sx94arlziFx8BC8UY0.
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EFTA00014442

=== Page 6 ===
eJusticeNY Integrated Justice Portal
Page 6 of 10
Jul 20, 2017
SOR Change
Sent to Florida Dept of Law Enforcement Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Jul 20, 2017
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Jun 20, 2017
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jun 20, 2017
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Jun 20, 2017
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Jun 20, 2017
SOR Change
Sent to Florida Dept of Law Enforcement Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Jun 6, 2017
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Jun 6, 2017
SOR Change
Sent to Florida Dept of Law Enforcement - Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Jun 6, 2017
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jun 6, 2017
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Jun 5, 2017
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jun 5, 2017
SOR Change
Sent to Florida Dept of Law Enforcement - Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Jun 5, 2017
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Jun 5, 2017
SOR Change
Sent to New Mexico Dept of Public Safety Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Apr 27, 2017
Annual Verification
Received from Offender
Received
Apr 27, 2017
SOR Change
Sent to Florida Dept of Law Enforcement Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Apr 27, 2017
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 27, 2017
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Apr 27, 2017
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Apr 10, 2017
Annual Verification
Sent to EPSTEIN,JEFFREY at 6100 RED HOOK QUARTER, B3,
to Offender
ST THOMAS, VI, 00802
Apr 3, 2017
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 3, 2017
SOR Change
Sent to New Mexico Dept of Public Safety - Sex Offender
Notification
Registry at PO Box 1628, Santa Fe, NM, 87504
Apr 3, 2017
e-SOR Change
Sent to NYCPD Sex Offender Unit
Notification
Apr 3, 2017
SOR Change
Sent to Florida Dept of Law Enforcement Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Mar 7, 2017
Offender Photo Due
Sent to JEFFREY E EPSTEIN at 6100 RED HOOK QUARTER, B3,
Letter
ST THOMAS, VI, 00802
Mar 7, 2017
Agency Photo Due
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Nov 8, 2016
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Sep 30, 2016
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 48B-50C Kronprindsens Gade,
St Thomas, VI, 00802
Sep 15, 2016
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jul 26, 2016
SOR Change
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jun 3, 2016
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
May 9, 2016
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
May 6, 2016
SOR Change
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 26, 2016
Annual Verification
Received from Offender
Received
Apr 26, 2016
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
https://www.ejustice.ny.gov/wps/myportal/!ut/p/a1/jZBbb4JAEIV_Sx94arlziFx8BC8UY.
6/28/2019
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=== Page 7 ===
eJusticeNY Integrated Justice Portal
Page 7 of 10
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 11, 2016
Annual Verification
Sent to EPSTEIN,JEFFREY at 6100 RED HOOK QUARTER, B3,
to Offender
ST THOMAS, VI, 00802
Apr 6, 2016
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Mar 7, 2016
Offender Photo Due
Sent to JEFFREY E EPSTEIN at 6100 RED HOOK QUARTER, B3,
Letter
ST THOMAS, VI, 00802
Mar 7, 2016
Agency Photo Due
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jan 28, 2016
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jan 20, 2016
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jan 7, 2016
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jan 4, 2016
SOR Change
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Dec 29, 2015
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Dec 4, 2015
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Nov 23, 2015
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jun 16, 2015
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jun 11, 2015
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
May 7, 2015
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 48B-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 28, 2015
Annual Verification
Received from Offender
Received
Apr 28, 2015
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 21, 2015
SOR Change
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 13, 2015
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 9, 2015
Annual Verification
Sent to EPSTEIN,JEFFREY at 6100 RED HOOK QUARTERS,
to Offender
SUITE B3, ST THOMAS, VI, 00802
Mar 17, 2015
SOR Change
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Mar 6, 2015
Agency Photo Due
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Mar 6, 2015
Offender Photo Due
Sent to JEFFREY E EPSTEIN at 6100 RED HOOK QUARTERS,
Letter
SUITE B3, ST THOMAS, VI, 00802
Mar 4, 2015
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Feb 27, 2015
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Dec 30, 2014
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Oct 30, 2014
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Oct 9, 2014
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Aug 24, 2014
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Aug 12, 2014
SOR Change
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 21, 2014
Annual Verification
Received from Offender
Received
Apr 21, 2014
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 48B-50C Kronprindsens Gade,
St Thomas, VI, 00802
https://www.ejustice.ny.gov/wps/myportal/!ut/p/a1/jZBbb4JAEIV_Sx94arlziFx8BC8UY0..
6/28/2019
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=== Page 8 ===
eJusticeNY Integrated Justice Portal
Page 8 of 10
Apr 9, 2014
Annual Verification
Sent to EPSTEIN,JEFFREY at 6100 RED HOOK QUARTERS,
to Offender
SUITE B3, ST THOMAS, VI, 00802
Mar 18, 2014
Offender Photo Due
Sent to JEFFREY E EPSTEIN at 6100 RED HOOK QUARTERS,
Letter
SUITE B3, ST THOMAS, VI, 00802
Mar 5, 2014
Agency Photo Due
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Mar 5, 2014
Offender Photo Due
Sent to JEFFREY E EPSTEIN at 6100 RED HOOK QUARTERS,
Letter
SUITE B3, ST THOMAS, VI, 00802
Jan 22, 2014
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jan 7, 2014
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jan 6, 2014
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jul 5, 2013
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jun 12, 2013
SOR Change
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
May 14, 2013
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
May 6, 2013
SOR Change
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 24, 2013
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 23, 2013
Annual Verification
Received from Offender
Received
Apr 9, 2013
Annual Verification
Sent to EPSTEIN,JEFFREY at 6100 RED HOOK QUARTERS,
to Offender
SUITE B3, ST THOMAS, VI, 00802
Apr 5, 2013
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Mar 20, 2013
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Mar 12, 2013
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Mar 5, 2013
Agency Photo Due
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Mar 5, 2013
Offender Photo Due
Sent to JEFFREY E EPSTEIN at 6100 RED HOOK QUARTERS,
Letter
SUITE B3, ST THOMAS, VI, 00802
Feb 27, 2013
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Feb 11, 2013
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jan 30, 2013
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jan 11, 2013
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Dec 28, 2012
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Dec 4, 2012
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Nov 19, 2012
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 48B-50C Kronprindsens Gade,
St Thomas, VI, 00802
Nov 14, 2012
SOR Change
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Sep 14, 2012
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jul 23, 2012
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jul 9, 2012
SOR Change
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 24, 2012
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 23, 2012
Annual Verification
Received from Offender
Received
https://www.ejustice.ny.gov/wps/myportal/!ut/p/a1/jZBbb4JAEIV_Sx94arlziFx8BC8UY0.
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=== Page 9 ===
eJusticeNY Integrated Justice Portal
Page 9 of 10
Apr 19, 2012
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 9, 2012
Annual Verification
Sent to EPSTEIN,JEFFREY at 6100 RED HOOK QUARTERS,
to Offender
SUITE B3, ST THOMAS, VI, 00802
Mar 9, 2012
SOR Change
Sent to Virgin Islands Dept of Justice - Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Mar 5, 2012
Agency Photo Due
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Mar 5, 2012
Offender Photo Due
Sent to JEFFREY E EPSTEIN at 6100 RED HOOK QUARTERS,
Letter
SUITE B3, ST THOMAS, VI, 00802
Feb 17, 2012
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Jan 6, 2012
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
May 4, 2011
Annual Verification
Received from Offender
Received
May 4, 2011
Annual Verification
Received from Offender
Received
May 2, 2011
Annual Verification
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Failure Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Apr 11, 2011
Annual Verification
Sent to EPSTEIN,JEFFREY at 6100 RED HOOK QUARTERS,
to Offender
SUITE B3, ST THOMAS, VI, 00802
Mar 7, 2011
Offender Photo Due
Sent to JEFFREY E EPSTEIN at 6100 RED HOOK QUARTERS,
Letter
SUITE B3, ST THOMAS, VI, 00802
Mar 7, 2011
Agency Photo Due
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Mar 2, 2011
SOR Change
Sent to Virgin Islands Dept of Justice Sex Offender Registry
Notification
at GERS Building Second Floor, 488-50C Kronprindsens Gade,
St Thomas, VI, 00802
Mar 2, 2011
SOR Change
Sent to Florida Dept of Law Enforcement - Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
Jan 24, 2011
Final Risk
Sent to Florida Dept of Law Enforcement = Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
May 4, 2010
Jurisdiction
Sent to Florida Dept of Law Enforcement - Sex Offender
Notification
Registry at Sex Offender/Predator Unit, PO Box 1489,
Tallahassee, FL, 32302
- Show Informational Data
Note: The following information is for Registry and investigative purposes
only and may not be shared with the public. Please refer to the beginning
of this detail sheet which discusses unauthorized release of Registry
information.
Current Informational Addresses:
Time Category Location Name and Street Address
City
County/Country State
Zip
Previous Informational Addresses:
Time Category Location Name and Street Address
City
County/Country State
Zip
Future Informational Addresses:
Time Category Location Name and Street Address
City
County/Country State
Zip
Current Informational Internet Details:
Email Address
Screen Name
TWITTER JEFFREYEPSTEIN1
Service Providers
Previous Informational Internet Details:
Email Address
Screen Name
Service Providers
Current Informational Driver Licenses:
License Number
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=== Page 10 ===
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EFTA00014447


c1: EFTA00016595
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016595.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: RE: draft response to Epstein defense preservation requests
Date: Tue, 06 Aug 2019 19:01:17 +0000
Attachments:2019-08-05,_JE_letter_to_defense_re_preservation_requests.docx;2019-07-
26,_JE,_defense_letter_requesting_preservation_and_production.pdf,2019-08-
01,JE,_defense_supplemental_letter_requesting_preservation_and_production.pdf
This has been in the works for a little while, due to various other things that have come up in the interim, but we didn't
want it to get lost given the discovery motion schedule. The attached is based on our conversations with
including
his email with suggested language for the prefatory language, and responds to the two attached defense letters. Happy to
discuss anytime and to incorporate comments and suggestions.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00016595


c1: EFTA00015823
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015823.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
April 9, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
The Government writes regarding your request to review sixteen (16) discs in the
possession of the Federal Bureau of Investigation ("FBI") as part of the file previously maintained
by the FBI's Palm Beach Resident Agency (the "FBI Florida Office") during its investigation of
Jeffrey Epstein under evidence number 1B8, Subitem 8 (the "Discs"). As noted in the evidence
log previously provided to you, the Discs are described in the FBI's evidence system as follows:
(16) DVD-R discs with printed labels reading, "Palm Beach County
Sheriff's Office Case # 05-250067 Epstein Encase Files Palm Beach
PD DVD-R for General VERBATIM DVD Computer Crimes
Unit." Each disc is also respectively labeled, "Disk 1 of 16," "Disk
2 of 16," etc.
When the FBI's New York Office first received the FBI Florida Office's file regarding its
investigation of Jeffrey Epstein, the agents working on this case attempted to review all electronic
media contained in that file, including the Discs. During that review, the case agents were unable
to open any files contained on the Discs and believed that the files were inoperable.
EFTA00015823

=== Page 2 ===
Page 2
In preparing for defense counsel in this case to review all physical evidence in the FBI
Florida Office's file, the Government tried to access the content of these Discs and was similarly
unable to open those files. However, the Government recognized that the file extensions and sizes
of those files appeared to be consistent with those of a forensic image of an electronic device.
With the help of an FBI computer specialist, the Government has learned that the Discs appear to
contain a forensic image of a computer seized from Jeffrey Epstein's residence in Palm Beach,
Florida by the Palm Beach Police Department during the execution of a search warrant in or about
2005 (the "Epstein Computer").
The Government has reviewed the 2005 search warrant obtained by the Palm Beach Police
Department, which was previously produced to you in a discovery production dated October 20,
2020. While that warrant appears to have authorized the seizure of electronic devices, it does not
appear to have authorized a search of the content of such devices. Moreover, the Government is
not aware of any further warrant obtained by local or federal authorities as part of the prior Florida
Investigation that would authorize a review of the contents of the Epstein Computer. Nor has this
Office obtained a warrant for the Epstein Computer. Accordingly, the Government does not
believe it has a lawful basis to review the forensic image of the Epstein Computer contained on
the Discs. Moreover, and given, among other things, the passage of time since the Epstein
Computer was seized in 2005, the Government does not intend to obtain a warrant to search the
Epstein Computer or otherwise review or make use of its contents. As such, because the
Government lacks authority to review their contents, the Discs are not discoverable in this case,
and the Government cannot permit you to review the contents of the Discs.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by
Assistant United States Attorneys
1
In this respect, the Government is also mindful of the fact that Epstein's estate has repeatedly
informed the Government that it is unwilling to waive any attorney-client privileges in connection
devices seized from Epstein during this investigation. As a result, even assuming the Government
had the authority to review the contents of the Discs, the Government would have to first conduct
a privilege review before producing any non-privileged material to you. However, because the
Government has no lawful authority to search the contents, it cannot conduct such a review.
EFTA00015824


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein 2018R01618
Date: Wed, 14 Aug 2019 16:47:52 +0000
OK. Crazy
From:
Sent: Wednesday, August 14, 2019 12:19 PM
To:
Subject: FW: Epstein 2018R01618
Importance: High
Is this good enough?
From:
Sent: Wednesday, August 14, 2019 11:29 AM
To:
Subject: RE: Epstein 2018R01618
Importance: High
What we can do is have the Help Desk manually remove the standard VNS closing paragraphs from the letter for
each of the registrants. We cannot remove the closing from the email notices (about five registrants have email
addresses). If that is acceptable, let me know and I will follow up with the instructions on how to proceed.
From:
Sent: Wednesday, August 14, 2019 9:57 AM
To:
Subject: RE: Epstein 2018R01618
is there a way to remove the closing paragraph of the VNS notification?
|
VNS Project Manager
I
EOUSA
I
Office of Legal Programs
I
From:
Sent: Wednesday, August 14, 2019 7:55 AM
To:
Subject: Epstein 2018R01618
The SDNY USA Geoffrey Berman wants a notice to go out with two paragraphs only. The introduction and the added
text. He was very specific on what he wants.
I called
at VNS help desk and he could not tell me how to manipulate the notification so that it only has two
paragraphs the introduction and other.
EFTA00017765

=== Page 2 ===
Can you
and I figure out how to do this. The notice is timely.
Victim Witness Coordinator
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel.
EFTA00017766


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
(USANYS)"
Subject: RE: Epstein Account Documents
Date: Wed, 06 Oct 2021 20:12:16 +0000
Hi
Thanks very much. Could you please send us the account statements for a few months after these documents were
executed? It would be helpful to see the balances.
Thanks!
From:
Sent: Monday, October 4, 2021 8:27 AM
To:
Subject: Epstein Account Documents
As a follow up to our conversation regarding Epstein accounts where Ghislaine Maxwell was a signer on the account, I
have compiled the attached documents for your review.
If you have any question, please contact me.
Best
Forensic Accountant
FBI New York Field Office
26 Federal Plaza
NYC, NY 10278
Office:
EFTA00015030


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=== Page 1 ===
From:
To:
(USANYS)"
Cc:
Subject: Re: Epstein
Date: Mon, 29 Jun 2020 22:46:36 +0000
Thank you!
On Jun 29, 2020, at 6:45 PM,
(USANYS)
wrote:
Sorry, I think I found it. Attached.
From: A
Sent: Monday, June 29, 2020 5:44 PM
To:
Cc:
(USANYS)
Subject: Re: Epstein
Do you have a copy of the second 6(e) order from February that allowed Civil to review the additional trust agreements
beyond those referenced in the order attached to Ted's email? I don't have a copy.
Thanks,
On Jun 29, 2020, at 2:13 PM, McEnany, John (USANYS)
wrote:
Yes. We need to apply for a new order with an application that would discuss why we need to disclose;
privacy concerns; potential protective orders; should we give notice to the people we got the trust agreements
from (and if not why not), etc.
From:
(USANYS)
Sent: Monday, June 29, 2020 2:05 PM
To: M
S)
Cc: F
SANYS) <LFogelman@usa.doj.gov>
Subject: FW: Epstein
This is the original order, which does seem to suggest we need "further order of the court" to further disclose.
From:
(USANYS)
Sent: Wednesday, January 29, 2020 9:33 AM
To:
USANYS)
Subject: Epstein
EFTA00016159

=== Page 2 ===
Will come by in a second.
E
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel. (2
<2020-02-03, JE, 6e disclosure, signed order.pdf>
EFTA00016160


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c0:
=== Page 1 ===
From:
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:55:04 +0000
Inline-Images: image001.png
So happy to see this. Congrats guys!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO ENITED VILLINGS
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
EFTA00017719

=== Page 2 ===
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment [1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
EFTA00017720

=== Page 3 ===
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00017721


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To: "Berman, Geoffrey (USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
Subject: RE: Epstein Trust Analysis
Date: Thu, 30 Jan 2020 00:07:00 +0000
Please ignore this version, I will be circulating a revised version with some additional content tomorrow morning.
From:
Sent: Wednesday, January 29, 2020 5:51 PM
To: Berman, Geoffrey (USANYS)
is
(USANYS)
(USANYS)
is
(USANYS)
(USANYS)
Subject: Epstein Trust Analysis
Hi everyone,
I've attached a summary/analysis of the Epstein trust documents we received. This document incorporates the analysis of
the trusts from 2019 I did previously.
On the bottom, you'll see each trust has a tab and then further amendments to the trust (if any) go chronologically to the
right. There's also key and summary tabs at the beginning of the document.
Please let me know if you have any questions, or if you'd like me to walk you through how to use the document, in case it
isn't clear.
Thanks,
p.s. I wouldn't recommend printing the document, just due to the size of the excel tables.
EFTA00016812


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=== Page 1 ===
From:
To:
Bcc:
Subject: FW: FW: Ghislaine Maxwell 02879-509
Date: Tue, 29 Dec 2020 16:38:05 +0000
Embedded: FW:FW:_Ghislaine_Maxwell_02879-509.msg
Sender
Subject: FW: FW: Ghislaine Maxwell 02879-509
Message-Id:
<DM3P110MB04580F454F8C59C87BF9234584D80@DM3P110MB0458.NAMP110.PROD.OUTLOOK.CO
M>
EFTA00015907


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=== Page 1 ===
From:
(USANYS)"
To: Karas NYSD Chambers
, Bruce Barket
Cc: Aida Leisenring
>, , Michael Bachrach
John Diaz
(USANYS)"
(USANYS)"
>, "Kenneth J. Montgomery Esq"
Subject: RE: Letter regarding jail conditions and court appearance
Date: Wed, 26 Aug 2020 20:25:52 +0000
Attachments: 2020.08.26_letter_to_KMK_re_MCC_conditions.pdf
Dear Judge Karas,
Attached please find a follow-up letter from the Government in response to the Court's August 21 Order.
Respectfully submitted,
Co-Chief, Narcotics Unit
O:
From:
(USANYS)
Sent: Monday, August 24, 2020 8:05 PM
To: Karas NYSD Chambers
>; Bruce Barket
Cc: Aida Leisenring
>; Michael Bachrach
>; John Diaz
is
is
(USANYS)
is
(USANYS)
V.
>; Kenneth J. Montgomery Esq
is
Subject: RE: Letter regarding jail conditions and court appearance
Dear Judge Karas,
Pursuant to the Court's August 21 order, attached please find the Government's letter.
Respectfully submitted,
Co-Chief, Narcotics Unit
O:
From: Karas NYSD Chambers
Sent: Friday, August 21, 2020 1:22 PM
To: Bruce Barket
EFTA00016001

=== Page 2 ===
Cc: Aida Leisenring
is
is
>; Michael Bachrach
is
>; ; John Diaz
is
is
is
(USANYS)
is
(USANYS)
is
is
(USANYS)
Subject: Re: Letter regarding jail conditions and court appearance
All,
Attached please find a memo endorsement from Judge Karas.
-Chambers of Judge Karas
From: Bruce Barket
Sent: Thursday, August 20, 2020 6:24 PM
To: Karas NYSD Chambers
Subject: FW: Letter regarding jail conditions and court appearance
Good afternoon,
I sent this to
but wanted to forward here as well. Can you confirm that the judge will see it?
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments
From: Bruce Barket
Sent: Thursday, August 20, 2020 12:50 PM
To:
Cc: Aida Leisenring
>; ; tonyricco
is
>; Michael Bachrach
>; Kenneth J. Montgomery Esq
>; 'john diaz
(
)'
is
i
is
is
(USANYS)
is
is
(USANYS)
(
)'
Subject: Letter regarding jail conditions and court appearance
I hope all is well. Can you please bring this letter to the attention of the judge? Note that I copied the lawyer for the MCC
and the prosecution team as well as firewall counsel. Thank you.
Bruce A. Barket, Esq.
EFTA00016002

=== Page 3 ===
Barket Epstein Kearon Aldea & LoTurco, LLP
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments
EFTA00016003


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=== Page 1 ===
From: "Strauss, Audrey (USANYS)"
To:
Subject: FW: Q and A
Date: Tue, 30 Jun 2020 19:24:38 +0000
Attachments: Maxwell_possible_QA_v2.docx
For our 3:30 Q and A prep
From:
Sent: Tuesday, June 30, 2020 2:47 PM
To: Strauss, Audrey (USANYS)
Subject: RE: Q and A
From: Strauss, Audrey (USANYS)
Sent: Tuesday, June 30, 2020 2:41 PM
To:
Subject: Q and A
Would you please resend?
Audrey Strauss
Deputy United States Attorney
United States Attorney's Office
Southern District of New York
Tel.:
EFTA00015203


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=== Page 1 ===
From:
To:
Cc:
)"
(NY) (FBI)"
)"
Subject: Re: Epstein - Subpoena Tracker
Date: Wed, 10 Jun 2020 15:03:11 +0000
As a follow up to our conversation, after you review the productions on hand, I will provide you any productions
that are need.
Please make the necessary arrangements for me to gain access to USAfx.
Best
Forensic Accountant
FBI New York Field Office
26 Federal Plaza
NYC, NY 10278
Office:
From:
Sent: Wednesday, June 10, 2020 9:59 AM
To:
Cc:
is
is
is
Subject: Re: Epstein - Subpoena Tracker
Hi
I've been working to get all of the subpoena returns organized for this case. In going through the tracker of bank
subpoenas and returns that you sent over on June 2nd, I was unable to find any corresponding returns on our shared
drive. I understand that in the past you have been sending them over on discs but given the circumstances would you be
able to also have them uploaded to USAfx?
Thanks,
Paralegal Specialist
U.S. Attorney's Office I
SDNY
1 St. Andrew's Plaza
EFTA00016316

=== Page 2 ===
New York, NY 10007
Offic
Cell:
EFTA00016317


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: CBS News Inquiry
Date: Wed, 21 Aug 2019 23:02:30 +0000
I'll handle. Thanks.
Sent from my iPhone
On Aug 21, 2019, at 7:01 PM,
wrote:
From: Brown, Bridget
Sent: Wednesday, August 21, 2019 18:56
To:
Cc: @CND National Desk Staff
Subject: CBS News Inquiry
Good evening -
Reaching out from the CBS News National Desk. We are following reports that at least 8 jail officials knew that Jeffrey
Epstein was not to be left alone in his cell leading up to his death. Can you confirm this? Do you have any comment?
Please reply all.
-
Thank you,
Bridget Brown
News Associate National Desk
EFTA00016938


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=== Page 1 ===
From: Laura Menninger
To:
)"
)"
(USANYS)"
i
,
)"
Cc: Jeff Pagliuca
"
>, , Ann
Lundberg
, Nicole Simmons
Subject: [EXTERNAL] Supplemental letter regarding
testimony
Date: Sun, 28 Nov 2021 02:42:17 +0000
Attachments:
Counsel -
Please see attached letter regarding Mr.
anticipated testimony.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
(Office)
EFTA00014892


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=== Page 1 ===
From
To:
Subject: Epstein
Date: Sat, 10 Aug 2019 14:29:31 +0000
Can you give me a ring when you get a second?
Sent from my iPhone
EFTA00014347


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=== Page 1 ===
From: Christian Everdell
To: "NathanNYSDChambers@nysd.uscourts.gov"
Cc:
(USANYS)"
"Mark S. Cohen"
"BOBBI
C STERNHEIM"
>, 'Jeff Pagliuca'
i
'Laura Menninger'
Subject: RE: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Renewed Bail Motion Reply
Memorandum and Exhibits (to be Filed Under Seal)
Date: Wed, 23 Dec 2020 18:08:04 +0000
Attachments: Reply_Memorandum_re_Renewed_Bail_Application_Final.pdf;
Reply_Memorandum_re_Renewed_Bail_Application_Final_Redacted.pdf
Inline-Images: image001.jpg; image002.jpg; image004.jpg; image006.jpg
Dear Judge Nathan -
In preparing to file the reply brief pursuant to the Court's order (Dkt. 101), we noticed a typographical error in the reply
memorandum.
We have spoken to the government and they have no objection to the defense making this revision (on pages i
and 8) before filing the memorandum on the public docket. Accordingly, attached to this email are revised versions of the
unredacted and redacted memorandum reflecting this change. We will file the revised redacted version on the docket
today. We apologize for the error.
Regards,
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
view bio
www.cohengresser.com
New York Paris Washington DC London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
From: Christian Everdell
Sent: Friday, December 18, 2020 7:40 PM
To: "NathanNYSDChambers@nysd.uscourts.gov'
EFTA00015975

=== Page 2 ===
Cc:
)';
)';
(USANYS)'; Mark S. Cohen; 'BOBBI C
STERNHEIM'; 'Jeff Pagliuca'; 'Laura Menninger'
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Renewed Bail Motion Reply Memorandum and Exhibits (to be Filed
Under Seal)
Dear Judge Nathan -
Attached please find the following documents submitted to the Court and all counsel under seal pursuant to the Court's
order (Dkt. 89):
1. Cover letter
2. Reply memorandum (unredacted)
3. Reply memorandum (redacted)
4. Accompanying exhibits A-B
Regards,
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
GG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00015976


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
)"
Subject: FW: travel approval request
Date: Mon, 17 Feb 2020 18:02:58 +0000
Attachments: QVEOYT.pdf
Re: the below, I just got a bounce-back from
that she's out tomorrow. Is this something one of you might be able
to check and/or assist with? Or should I just do it myself tomorrow?
thanks,
From:
Sent: Monday, February 17, 2020 13:02
To:
Cc:
is
is
Subject: RE: travel approval request
Wanted to see if you had reserved a conference room for us, per the below from Thursday? I got a confirmation for the
hotel (attached) but it doesn't seem to say anything about a conference room. Could you please let us know either way?
And if not yet, could you please reserve that for us tomorrow (Tuesday) and let us know when it's finalized?
thank you!
From:
Sent: Thursday, February 13, 2020 13:26
To:
is
)
Cc:
)
is
Subject: RE: travel approval request
Apologies for the slight delay yesterday on this travel, we had a witness scheduling issue so the travel will be a day later
than originally anticipated. The city is Pensacola, Florida, and it will be me and
(rather than
and
if you could please book me on the following flights:
Feb. 19: Delta, LGA to PNS, 9:00 a.m. (arriving 12:49 p.m.)
Feb. 20: Delta, PNS to LGA, 4:06 p.m. (arriving 9:41 p.m.)
And the following hotel, for the night of Feb. 19:
-
Hilton Garden Inn (listed in E2 as "HGI PENSACOLA AIRPORT MEDICAL")
EFTA00014396

=== Page 2 ===
We will also need a conference room at the Hilton Garden Inn for February 19, starting at 5:00 p.m. for three hours (or for
the entire day, if that's the only way they'll do it).
Please let us know if any questions or issues, and thanks as always.
From:
Sent: Wednesday, February 12, 2020 09:02
To:
is
i
i
Cc:
Subject: Re: travel approval request
Hi,
Which specific city will the hotel be in?
If
could push the travel authorizations thru to
& I today, that would be great As well as sending the
conference room payment request to
Remember to take the FL tax exempt form along with you.
Thanks
Sent from my iPhone
On Feb 12, 2020, at 6:43 AM,
wrote:
Approved
Sent from my iPad
On Feb 11, 2020, at 7:53 PM,
)
wrote:
Similar to prior requests in connection with the Epstein investigation (2018R01618),
and I would like to please
request permission for the two of us to travel next week for an interview of a witness in Pensacola, Florida on 2/19.
We'd plan to fly down on 2/18 and fly back on 2/19. Also, similar to prior requests, we'd like to request approval to get
a conference room on 2/19.
Thank you,
From:
Sent: Tuesday, January 21, 2020 2:56 PM
To:
Cc:
is
is
is
is
Subject: RE: travel approval request
EFTA00014397

=== Page 3 ===
Approved
From:
Sent: Tuesday, January 21, 2020 2:49 PM
To:
Cc:
is
)
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), but with an added international
element, we'd like to please request permission for the team to travel next week for an interview near Stockholm,
Sweden, next week on January 29th and/or 30th. We expect to be traveling, respectively, some combination of the
27th (overnight) to the 31st, depending on when the interview ends up being scheduled, and we'll put final dates on
our formal applications. Also similar to prior trips, we'd like to request approval to get a conference room for one of
those days at a hotel for the interview itself.
Also based on our discussion earlier we'll be mindful of looking for domestic (or domestic-flagged) carrier flights, as
well as the costs of any alternatives, in looking at possible specific bookings. Thanks as always for your help and input
on that.
thank you,
From:
Sent: Wednesday, December 11, 2019 09:58
To:
Cc:
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16
and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior
trips, we'd like to request approval to get a conference room for one of those days.
thank you,
From:
Sent: Tuesday, November 05, 2019 16:53
To:
Cc:
is
is
Subject: RE: travel approval request
EFTA00014398

=== Page 4 ===
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:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no
later than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference
room at the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
is
)
Subject: RE: travel approval request
EFTA00014399

=== Page 5 ===
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.
From:
)
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
EFTA00014400

=== Page 6 ===
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
EFTA00014401


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=== Page 1 ===
From:
To: Nathan NYSD Chambers
Cc:
Subject: US V. Maxwell, 20 CR 330 (AJN) - Proposed Redactions
Date: Wed, 24 Nov 2021 00:13:20 +0000
Attachments: Ex._1_[proposed_redactions].pdf
Chambers,
Attached please find the Government's proposed redactions as reference in Dkt. No. 498.
Respectfully submitted,
EFTA00016621


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c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
(NY) (FBI)"
)"
"
)"
(NY) (FBI)"
) [Contractor]"
Subject: RE: Epstein search warrant materials
Date: Tue, 12 Nov 2019 19:43:32 +0000
The FBI has a large amount of search warrant return files (primarily though not exclusively emails) that they need to
transmit to us for loading to Relativity.
Could we please borrow a 1TB hard drive just for the purpose of transferring the data from them to us? We can get it
back to you as quickly as the data is loaded through our folks.
thanks very much,
From:
(NY) (FBI)
Sent: Tuesday, November 12, 2019 14:41
To:
Cc:
in
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant materials
A 1TB should do it. There are a ton of emails, but they don't take up much space.
Senior Forensic Examiner
cell
desk
On Nov 12, 2019 2:39 PM,
)"
wrote:
Okay thanks. We can circle back in a week or so on exactly what's being processed (in terms of number of devices and
what they are), because we have no idea what it is.
More immediately, please let us know how big of a hard drive you need for later this week.
From:
(NY) (FBI)
Sent: Tuesday, November 12, 2019 14:37
To:
Cc:
is
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant materials
I've got everything here with me. Once I've cleared these load files, that stuff will all be processed. Already have
our HQ working on the Island DVR system.
EFTA00017061

=== Page 2 ===
Senior Forensic Examiner
cell
desk
On Nov 12, 2019 2:34 PM,
)"
wrote:
Thanks, and we do understand it's a heavy lift so we appreciate the help. Could you let us know the size of the materials
so we can get an appropriate hard drive for you?
And separately, I'm not sure what the status is of the island materials - are those with you, or still being preliminarily
checked for any CP images? Or somewhere else??
thanks again,
From:
(NY) (FBI)
Sent: Tuesday, November 12, 2019 14:15
To:
)
Cc:
is
V.
>;
(NY) (FBI)
Subject: RE: Epstein search warrant materials
I am generating the load files for such stuff as we speak. Apologies for the delays, this is a long and complex
process that I had to come up with a procedure for. I anticipate the files being ready by the Thursday COB. If you
could forward a drive to me to copy the files onto, I would appreciate it.
Senior Forensic Examiner
cell
desk
On Nov 12, 2019 2:11 PM,
)"
wrote:
Wanted to follow up on our phone conversation from about six weeks ago - I think we had anticipated that the electronic
evidence that was being processed by CART from the New York residence search (which I believe was whittled down to
approximately 5-6 iMacs and 5 laptop computers) would be completed for upload with load files for Relativity sometime
in late October. We're concerned about timing particularly because I think that's just the tip of the iceberg - I don't think
FBI has even started on the island materials, for example - so wanted to check on timing. Could you please let us know
what the status is of those materials, and also what the materials are from the island that need to be processed, and
whether there's an estimated time of completion for those as well?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00017062


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c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(NY)
(FBI)"
(NYPD)"
i
USANYS)"
(USANYS)"
Subject: RE: [EXTERNAL EMAIL] - RE: Ghislaine Maxwell Triggerfish
Date: Mon, 28 Dec 2020 19:05:19 +0000
Thanks very much to you both.
From
(NY) (FBI)
Sent: Monday, December 28, 2020 1:57 PM
To:
(NYPD)
;
(USANYS)
is
(USANYS)
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Ghislaine Maxwell Triggerfish
I agree
Special Agent
FBI New York Field Office
On Dec 28, 2020 12:04 PM,
(USANYS)"
wrote:
I agree, thanks
From:
(USANYS)
Sent: Monday, December 28, 2020 10:58 AM
To:
(NY) (FBI)
is
(NYPD)
(USANYS)
is
(USANYS)
Subject: FW: Ghislaine Maxwell Triggerfish
See below. I do not think we can justify seeking extended sealing at this point, but let me know if you all disagree. The
warrant materials are attached for reference.
From:
(USANH)
Sent: Wednesday, December 23, 2020 2:42 PM
To:
(USANYS)
Cc:
(USANH)
Subject: FW: Ghislaine Maxwell Triggerfish
do you need the seal on the DNH triggerfish warrant extended?
Merry Christmas to you and yours!
Mr.
From
(USANH)
Sent: Wednesday, December 23, 2020 10:20 AM
To
(USANH)
Subject: Ghislaine Maxwell Triggerfish
1
EFTA00015880

=== Page 2 ===
The seal on this triggerfish is set to expire soon.
Am I correct in assuming we can go ahead and let this lapse?
EFTA00015881


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c0:
=== Page 1 ===
United States Attorney
PRO JUSTITIA
Southern District of New York
There will be a press conference today at XX:00 a.m. to announce charges against Ghislaine
Maxwell for her role in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein.
The press conference will be livestreamed on Facebook @USAOSDNY. Relevant documents
are attached.
WHO:
Audrey Strauss, Acting United States Attorney for the Southern District of New
York
, Assistant Director-in-Charge of the New York Office of
the Federal Bureau of Investigation
WHAT:
Press Conference
WHEN:
Wednesday, July, 1, 2020
xx:00 p.m.
WHERE:
U.S. Attorney's Office, Southern District of New York
CONTACT:
NOTE:
Please silence all cell phones, PDAs, and pagers before start of press conference.
MANDATORY COVID-19 PROTOCOLS WILL BE IN PLACE.
CLICK HERE FOR GUIDANCE.
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE
PRESS OFFICE AT (212) 637-2600
EFTA00015355


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c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
)"
Subject: RE: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Motions in Limine]
Date: Tue, 19 Oct 2021 13:50:26 +0000
Attachments: Maxwell's_Motions_in_Limine.zip
Inline-Images: image001.jpg
Oh sure! I've attached the zip file, but also happy to add you to the share drive if you like.
From:
(USANYS)
Sent: Tuesday, October 19, 2021 9:19 AM
To:
is
(USANYS)
Cc:
is
(USANYS)
is
Subject: RE: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Motions in Limine]
Thanks,
I don't seem to have access to the shared. Would you mind asking IT to add me and
? And/or
emailing the PDF?
From:
Sent: Tuesday, October 19, 2021 12:15 AM
To:
(USANYS)
is
(USANYS)
Cc:
is
(USANYS)
is
Subject: FW: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Motions in Limine]
The defense filed 13 motions in limine. I've attached their two cover letters, and the various motions are saved here:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\!Trial\MIL\DefenseMs
From: Nicole Simmons
Sent: Monday, October 18, 2021 11:41 PM
To: 'Nathan NYSD Chambers'
Cc: Jeff Pagliuca
; Laura Menninger
is
is
is
is
(USANYS)
Subject: [EXTERNAL] U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Motions in Limine]
Dear Judge Nathan:
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Motions in Limine and supporting documents.
Regards,
Nicole Simmons
EFTA00016944

=== Page 2 ===
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
TIST
Denver, Colorado
80203
www.hmflaw.com


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=== Page 1 ===
SDNY News Clips, Monday, March 9, 2020
SDNY News Clips
Monday, March 9, 2020
Contents
Public Corruption
2
Epstein
2
MCC
3
Money Laundering and Transnational Criminal Enterprises
5
Navarro
5
Terrorism and International Narcotics
10
Schulte
10
Violent and Organized Crime
13
Ray
13
Matters of Interest
16
Berman
16
Barr
18
Weinstein
19
Coronavirus
20
1
EFTA00014263

=== Page 2 ===
SDNY News Clips, Monday, March 9, 2020
Public Corruption
Epstein
Prince Andrew 'shut the door' on Epstein probe cooperation: U.S. prosecutor
Reuters
By Brendan Pierson and Mark Hosenball
3/9/2020
NEW YORK (Reuters) - Britain's Prince Andrew has declined to cooperate with a U.S. investigation into possible co-
conspirators of deceased financier and accused sex trafficker Jeffrey Epstein, a U.S. prosecutor said on Monday.
"Contrary to Prince Andrew's very public offer to cooperate with our investigation into Epstein's co-conspirators, an
offer that was conveyed via press release, Prince Andrew has now completely shut the door on voluntary cooperation
and our office is considering its options," U.S. Attorney Geoffrey Berman said when asked about Epstein at a news
conference about an unrelated case.
Berman's spokesman James Margolin declined comment on the options being considered. He said the prince's lawyers
had said Andrew would not submit voluntarily to an interview. He said this was after Jan. 27, when Berman told a news
conference Andrew had not offered any cooperation.
Andrew, 60, had said in a public statement in November that he was stepping down from public duties and would be
willing to help "any appropriate law enforcement agency with their investigations, if required."
A friend of Epstein's, the prince has not been accused of criminal wrongdoing. He has described his association with the
financier as "ill-judged." A spokeswoman for the royal family declined comment.
Clare Montgomery, a senior London barrister who British news reports say represents Andrew on matters related to
Epstein, also declined to comment, citing professional rules limiting her ability to speak publicly about legal issues.
Andrew, Queen Elizabeth's second son, has denied an accusation by a woman who said she was trafficked by Epstein
and forced to have sex with his friends, including the prince, when she was 17.
A U.S. Federal Bureau of Investigation probe is focusing on British socialite Ghislaine Maxwell, a longtime associate of
Epstein's, and others who facilitated the wealthy financier's alleged trafficking of underage girls, law enforcement
sources told Reuters in December.
Epstein had socialized with the prince and other high-profile figures including U.S. President Donald Trump and former
president Bill Clinton.
Epstein's suicide in Manhattan's Metropolitan Correctional Center in August, at age 66, occurred little over a month
after he was arrested and charged with trafficking dozens of underage girls as young as 14 from at least 2002 to 2005.
Prosecutors said he recruited girls to give him massages, which became sexual in nature. Epstein had pleaded not guilty.
2
EFTA00014264

=== Page 3 ===
SDNY News Clips, Monday, March 9, 2020
MCC
Jail captain in charge when Jeffrey Epstein hanged himself to be transferred: sources
NY Daily News
By Stephen Rex Brown
3/9/2020
He's certainly no stranger to emergencies.
The Metropolitan Correctional Center captain in charge when Jeffrey Epstein hanged himself is expected to be
transferred to a new lockup where he will serve as "emergency preparedness officer," sources tell the Daily News.
Jermaine Darden's move to FCI Fort Dix, a low-security prison in Burlington County, N.J., was delayed due to the ongoing
lockdown at the dysfunctional jail in lower Manhattan, according to a source.
As captain, Darden oversees lieutenants and correctional officers at MCC. Among those under his command were
Officers Tova Noel and Michael Thomas, who are accused of sleeping on the job and falsifying records the night of
Epstein's death.
A source doubted that Darden was at the jail when Epstein was found hanging in his cell at 6:30 a.m. on Aug. 10 but was
confident he was one of the first people called about it.
Thomas' attorney Montell Figgins said Darden's transfer and new title was yet another example of the upper ranks of
the Metropolitan Correctional Center facing no consequences for systemic Bureau of Prisons failures that allowed the
accused sex trafficker to avoid facing justice.
"It shows you the hubris of the system," Figgins said. "They couldn't care less about the reality of what they're dong.
They would take this person, who was involved in this incident, and give him another title?"
Darden, 48, declined to comment.
The transfer follows a pattern similar to that of Lamine N'Diaye, the correctional center warden during the Epstein
debacle. N'Diaye was moved to a desk job at a regional office in Pennsylvania days after the suicide. He was expected to
assume a leadership role at Fort Dix in February until U.S. Attorney General William Barr intervened and ordered the
transfer be put on hold while investigations into Epstein's death continue, The Associated Press reported.
Darden's new title at Fort Dix could come with a pay raise, a source said.
Working at the low-security lockup in New Jersey should be less stressful than at the Metropolitan Correctional Center.
The 12-story jail next door to Manhattan Federal Court has been reeling since Epstein's suicide. The building's
infrastructure is crumbling. Morale is at rock bottom following the arrests of Thomas and Noel. A gun smuggled into the
jail prompted an ongoing lockdown and forced overworked staff to put in even longer hours. The FBI is investigating the
flow of contraband into the facility.
3
EFTA00014265

=== Page 4 ===
SDNY News Clips, Monday, March 9, 2020
A gun smuggled into the jail prompted an ongoing lockdown and forced overworked staff to put in even longer hours.
The FBI is investigating the flow of contraband into the facility.
Figgins made the case that Darden's leadership was one of many problems at the Metropolitan Correctional Center at
the time of Epstein's suicide.
"They don't have any pictures of what happened that night because they didn't follow proper protocol," Figgins said.
"And yet he gets another position."
The Bureau of Prisons declined to comment on personnel decisions.
Thomas and Noel have pleaded not guilty to charges including filing false records, which carries a maximum sentence of
five years.
4
EFTA00014266

=== Page 5 ===
SDNY News Clips, Monday, March 9, 2020
Money Laundering and Transnational Criminal Enterprises
Navarro
Horse racing trainers and veterinarians charged in international doping scandal
NBC
By Tom Winter and David K. Li
3/9/2020
More than two dozen trainers, veterinarians and others in horse racing were charged in a widespread doping scheme
that "amounted to nothing less than abuse," federal officials and court papers revealed Monday.
The defendants ran horses at tracks in New York, New Jersey, Florida, Ohio, Kentucky and the United Arab Emirates,
federal prosecutors in New York City said.
"Over the course of the scheme, participants manufactured, purchased, sold, shipped, delivered, received and
administered thousands of units" of performance-enhancing drugs, or PEDs, for use on racehorses, U.S. Attorney
Geoffrey Berman wrote in charging documents against 19 of 27 defendants.
The indicted included 11 trainers, seven veterinarians and nine drug suppliers and distributors, according to Berman.
"All involved in the cruel and systematic doping of racehorses across the United States and indeed around the world
using misbranded, adulated and dangerous performance-enhancing drugs," Berman told reporters in New York.
"This is the most far-reaching prosecution of racehorse doping in the history of the Department of Justice."
William F. Sweeney Jr., the FBI's assistant director in charge of the New York office, said this practice forced horses to
run faster than they really could, putting them in grave danger.
"These substances stimulated endurance, deadened nerves, increased oxygen intake and reduced inflammation,"
Sweeney told reporters. "What actually happened to these horses amounted to nothing less than abuse."
He added: "They experienced cardiac issues, overexertion leading to leg fractures, increased risk of injury and in some
cases death."
As of now, investigators said they have not found any evidence that defendants told anyone about their doping scheme
so to make bets on juiced horses. But they allegedly profited on hefty prize money.
"Conversely, the human beings in the scheme continued to line their purses as they manipulated this multiple-billion-
dollar horse racing industry across the globe," Sweeney said. "People are rightfully disturbed by the mistreatment of
animals who have absolutely no means of defense."
Prosecutors said trainer Jorge Navarro "orchestrated" this scheme by "using PEDs designed to evade drug tests,
physically concealing containers of PEDs and drug paraphernalia from state regulators and racing officials."
5
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=== Page 6 ===
SDNY News Clips, Monday, March 9, 2020
One of Navarro's most prized thoroughbreds, XY Jet, died of an apparent heart attack this year after receiving a
significant amount of PEDs, in one instance 50 injections, according to the indictment.
X Y Jet won the prestigious Dubai Golden Shaheen at Meydan Racecourse in Dubai in March 2019, which paid $1.5
million to the winner, highlighting a career of 12 victories and more than $3 million in earnings. The horse won that race
and another contest in February of last year in Florida after receiving adulterated and misbranded PEDs before both
races, according to the indictment.
While in the UAE for the Dubai race, Navarro "personally administered various adulterated and misbranded PEDs to X Y
Jet, including a substance Navarro referred to as 'monkey,'' according to the indictment.
"Monkey" is a commonly used code word for a drug that can "boost a racehorse's red blood cell count in order to
stimulate endurance during a race and improve race recover," according to the indictment.
But those drugs, "when combined with intense physical exertion, thicken the horse's blood, thereby causing increased
cardiac exertion and pressure, which can lead to cardiac issues or death," the indictment said.
Navarro and another high profile trainer, Jason Servis, were both indicted on a count of conspiracy of drug adulteration
and misbranding.
Navarro allegedly told Servis in an intercepted phone call on March 5 last year that he particularly liked a PED called SGF-
1000.
"I've been using it on everything almost," Navarro told Servis. Navarro ended the phone call a short time later, saying, "I
don't want to talk about this S--- on the phone, OK," according to prosecutors.
Servis is the trainer of Maximum Security, who crossed the finish line first at last year's Kentucky Derby but was
disqualified minutes later after stewards ruled that the horse had impeded the paths of others; Country House was
declared the winner. Maximum Security won the Eclipse Award as horse racing's top 3-year-old colt in 2019.
Before a race later that year at Monmouth Park in Oceanport, New Jersey, Servis was caught on an intercepted
telephone call with veterinarian and co-defendant Kristian Rhein, according to the indictment. The veterinarian assured
Servis that a PED given to Maximum Security wouldn't show up on a test.
"They don't even have a test for it," Rhein told Servis, the indictment alleged. "There's no test for it in America."
Federal agents specializing in organize crime probes were investigating a "different case, on a different topic all
together" before they tripped on to the doping scheme and "one thing led to another," according to Sweeney.
"We had one agent in particular (who) was actually an expert in this industry from (a) prior life," Sweeney said. "He was
part of the team and they did great work."
The indictments show how widespread illegal drugs are in horse racing, according to People for the Ethical Treatment of
Animals.
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SDNY News Clips, Monday, March 9, 2020
"This sweeping federal investigation has exposed that illegal doping is still ubiquitous in horse racing, including at the
highest levels," PETA Senior Vice President Kathy Guillermo said in a statement.
"These crimes cheat bettors of billions of dollars and are egregiously cruel to horses, resulting in rampant injuries, pain,
and deaths, such as those cited in the indictment."
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SDNY News Clips, Monday, March 9, 2020
Maximum Security trainer among 27 indicted in racehorse doping scheme
NY Post
By Gabrielle Fonrouge
3/9/2020
The trainer behind the world's best racehorse, Maximum Security, along with 26 others have been indicted in the largest
crackdown on racehorse doping the Department of Justice has ever seen, Manhattan federal prosecutors announced
Monday.
Jason Servis, who just led Maximum Security to a $10 million victory in last month's Saudi Cup, allegedly used everything
from customized painkillers to blood thickeners on "virtually all of the racehorses under his control" to make them
"unnaturally fast," prosecutors alleged.
"These defendants engaged in this conduct not for the love of the sport, and certainly not out of concern for the horses,
but for money," US Attorney for the Southern District of New York Geoffrey Berman said Monday. "And it was the
racehorses that paid the price for the defendants' unbridled greed."
Prosecutors alleged the international scheme spanned racetracks in New York, New Jersey, Florida, Ohio, Kentucky and
the United Arab Emirates and could have killed a number of horses.
"You know how many [expletive] horses he [Navarro] [expletive] killed and broke down that I made disappear? You
know how much trouble he could get in if they found out the six horses we killed?" Nicholas Surick, one of the
indicted trainers, wrote in a text message about co-conspirator Jorge Navarro, another high-profile horse trainer.
One of Navarro's award-winning steeds, XY Jet, died of an apparent heart attack in January after receiving over 50
injections of performance-enhancing drugs, an indictment against Navarro alleges.
Berman said X Y Jet's death is still under investigation.
The probe, started two years ago by the Federal Bureau of Investigation, turned up a total of nine trainers, nine
suppliers and seven crooked veterinarians who used blood thickeners, painkillers and bronchodilators to dope the
horses.
"These substances stimulated endurance, deadened nerves, increased oxygen intake and reduced inflammation,"
William Sweeney, assistant director in charge of the FBI's New York office, said at a press conference.
"What actually happened to these horses amounted to nothing less than abuse."
Sweeney said the PEDs caused the horses to have "cardiac issues" and led to "overexertion," which can cause leg
fractures and death.
One of the indicted veterinarians, Dr. Louis Grasso, who'd previously been investigated for a racehorse doping scheme,
allegedly distributed "cobra venom" to trainers as a painkiller and filled out prescriptions under the names of canine
patients to keep investigators off his tail, according to court records and Paulick Report.
"I don't give a f-k what it is," Grasso allegedly told co-conspirator and fellow racehorse trainer Thomas Guido III when
saying he charges "$100 per script," according to an indictment against him.
Grasso then allegedly boasted to an undercover officer that he could get "a script for anything," records show.
Investigators alleged Grasso submitted false prescriptions to over 10 pharmacies in at least seven states in 2019 alone
and was caught counseling Guido after one of his horses died, the indictment states.
8
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=== Page 9 ===
SDNY News Clips, Monday, March 9, 2020
"It happens [the trainer] probably over juiced him," Grasso allegedly said. "I've seen that happen 20 times."
A total of 26 out of the 27 defendants were arrested Monday while another defendant, Seth Fishman, was previously
arrested in October. Servis got hit with a charge of misbranding conspiracy, which relates to mislabeling drugs.
They collectively face a total of 105 years in prison, prosecutors said.
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=== Page 10 ===
SDNY News Clips, Monday, March 9, 2020
Terrorism and International Narcotics
Schulte
Trial of Programmer Accused in C.I.A. Leak Ends in Hung Jury
NYT
By Nicole Hong
3/9/2020
An office of the Central Intelligence Agency outside Washington turned into a crime scene on March 7, 2017.
WikiLeaks had just published a trove of confidential C.I.A. documents that revealed secret methods the spy agency used
to penetrate the computer networks of foreign governments and terrorists.
Investigators scrambled to find the culprit, seizing more than 1,000 devices from the C.I.A. as top-secret operations and
computer networks shut down. Eventually, they arrested Joshua Schulte, 31, who worked as a computer engineer for
the agency.
But on Monday, in a muddled outcome for the government, a federal jury in Manhattan could not agree on whether to
convict Mr. Schulte of the biggest theft of classified documents in C.I.A. history.
After hearing four weeks of testimony, the jurors deadlocked on eight counts, including illegal gathering and
transmission of national defense information. They did convict Mr. Schulte on two other counts - contempt of court
and making false statements to the F.B.I.
The motivation for the alleged theft, prosecutors said, was Mr. Schulte's belief that C.I.A. management did not take his
workplace complaints seriously. His feuding with co-workers led to his resignation in November 2016 to join Bloomberg
L.P. as a software engineer.
The partial verdict came after six days of chaotic deliberations. One juror was dismissed in the middle of the discussions
because she violated the judge's orders by researching the case, and then shared that information with the jury. The
judge declined to replace her with an alternate, leaving a panel of 11 people.
The jury also complained in a note about a separate juror who was not participating in the group discussion, raising
concerns about "her attitude."
After the verdict, one juror said the deliberations were a "horrible experience," her eyes welling with tears as she
walked away from reporters.
Mr. Schulte's legal troubles are not over. The government could retry the case. In addition, during the investigation,
federal agents found more than 10,000 images and videos of child pornography on electronic devices in Mr. Schulte's
home. He faces a separate federal trial on those charges.
The verdict showed that the jury had doubts about the government's most important evidence, which came from a
C.I.A. server. Trial witnesses guided jurors through a complicated maze of forensic analysis that, according to
prosecutors, showed Mr. Schulte's work machine accessing an old backup file one evening in April 2016.
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=== Page 11 ===
SDNY News Clips, Monday, March 9, 2020
He did so, prosecutors said, by reinstating his administrator-level access that the C.I.A. had removed after his workplace
disputes. The file matched the documents posted by WikiLeaks, the anti-secrecy organization, nearly a year later,
according to the government.
The defense argued that the C.I.A. computer network had weak passwords and widely known security vulnerabilities,
and that it was possible other C.I.A. employees or foreign adversaries had breached the system.
Mr. Schulte's lawyers pointed to an internal C.I.A. report commissioned after the WikiLeaks debacle that found the
agency did not know the files had been stolen until a year later.
In particular, the defense zeroed in on a C.I.A. employee identified only as Michael. On the night of the alleged theft,
Michael and Mr. Schulte, who were close friends, left the office together, according to a government court filing.
The C.I.A. placed Michael on administrative leave in August because he was not cooperating with the criminal
investigation into the data theft and had declined to take a polygraph test.
But the government did not notify the defense about Michael's employment status until six months later, the night
before he took the stand at trial as a government witness.
Mr. Schulte's lawyer, Sabrina Shroff, asked in her closing argument why prosecutors had "kept this information about
Michael to themselves."
"It shows their doubt about the case against Mr. Schulte," she told jurors.
During deliberations, some of the notes sent by the jury signaled it was exploring alternate culprits who might have
committed the theft.
The government had no direct proof that Mr. Schulte sent the files to WikiLeaks. Instead, prosecutors relied on
circumstantial evidence. For instance, Mr. Schulte downloaded the same program onto his home computer that
WikiLeaks recommends as a safe way to submit documents to the organization.
Prosecutors said that after stealing the documents and sending them to WikiLeaks, Mr. Schulte "nuked" his hard drive at
home to erase any trace of his submission.
The trial provided a rare glimpse inside the top-secret cyberoperations of the C.I.A. Mr. Schulte was a coder in the
agency's Engineering Development Group, which builds tools that allow C.I.A. officers to extract files from foreign
computers without detection.
On the witness stand, C.I.A. employees - who testified under pseudonyms or only first names - publicly
acknowledged for the first time some of the hacking tools that had been developed by the agency.
"Foreign governments do not want us on their networks and would complain, to put it lightly, if they caught us doing
this," testified a C.I.A. employee, who used the pseudonym Jeremy Weber.
11
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=== Page 12 ===
SDNY News Clips, Monday, March 9, 2020
Prosecutors were careful to avoid details about specific operations. During cross-examination, Ms. Shroff asked one
C.I.A. witness: "Do you recall a time when the C.I.A. covertly tried to read Angela Merkel's emails?" referring to the
German chancellor.
The government objected, and the judge stopped the witness from answering.
The testimony revealed the scramble inside C.I.A. headquarters when the files leaked. Sean Roche, a top C.I.A. official at
the time, said he got a call from another C.I.A. director who was out of breath. "It was the equivalent of a digital Pearl
Harbor," he testified.
Mr. Schulte immediately became a suspect. His personnel file indicated a willingness to violate C.I.A. policy, and his
resignation letter accused the agency of "deep injustices and illegal behavior," witnesses testified.
Much of the trial felt like a rehash of a workplace complaint gone horribly wrong. Mr. Schulte's primary grievance was
with another co-worker, identified only as Amol. Their group at the C.I.A., predominantly male coders, was known for
shooting Nerf guns and playing pranks.
Days after the first WikiLeaks disclosure, Mr. Schulte was scheduled to fly to Mexico.
Federal agents approached Mr. Schulte as he was leaving work at Bloomberg and took him to a cafe near Grand Central
Terminal in New York. Mr. Schulte gave them advice about finding the leaker. His hands trembled during the
conversation, an F.BI. agent testified.
That night, Mr. Schulte stayed in a hotel room as F.B.I. agents, who had a search warrant, seized large volumes of data
from his apartment.
The defense argued that investigators were quick to scapegoat Mr. Schulte because he was an easy target; after all, he
had antagonized virtually all of his co-workers at the C.I.A.
Prosecutors showed jurors detailed notebooks that Mr. Schulte kept in jail while awaiting trial. His bail was revoked after
he used the internet without the judge's permission, in violation of court orders.
While in jail, Mr. Schulte obtained a contraband cellphone from another inmate and set up a Twitter account called
@freejasonbourne, referring to the fictional C.I.A. operative played by the actor Matt Damon. He emailed reporters
sensitive information about his case from an encrypted account, resulting in his conviction for contempt of court.
In one notebook, prosecutors showed Mr. Schulte wrote a to-do list for himself, including "delete suspicious emails."
12
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=== Page 13 ===
SDNY News Clips, Monday, March 9, 2020
Violent and Organized Crime
Ray
Lawrence Ray Is the Latest Defendant To Be Convicted Before He Goes to Trial
Frank Report
By K.R. Claviger
3/8/2020
To some extent, it's always been this way: prosecutors like to get as much media coverage as possible when they
announce arrests and indictments - especially if the defendant is well known or the alleged crime is especially
abhorrent.
But with the advent of 24/7 news and the spread of social media, the reality is that many cases are now being
adjudicated in the court of public opinion long before they show up in the court of law.
Lawrence Ray - the man who allegedly forced at least one of his daughter's friends from Sarah Lawrence College into
prostitution - is the latest example of this rapidly increasing phenomenon.
According to Geoffrey Berman, the U.S. Attorney for the Southern District of New York (SDNY), Ray was arrested on
February 10th at his home in Piscataway, NJ - and charged with sex trafficking, forced labor, and extortion.
At the time of his arrest, Ray was in bed with one of his daughter's former college roommates - a woman for whom he
had been named guardian (I plan to do more research on that situation).
According to Berman, Ray had groomed the woman to be a prostitute - and had kept most of the money she earned
from her trysts.
Alleged Prostitute's Earnings Are Extraordinary
At Ray's arraignment on February 11th, Assistant U.S. Attorney Danielle Sassoon described ledgers that were confiscated
from Ray's home at the time of his arrest.
According to Sassoon, those ledgers indicated that Ray's alleged victim generated $700,000 in earnings in 2017 - and
$1,000,000 in 2018.
Let's just take a look at those numbers to see if they make any sense.
If the alleged victim was charging an average of $500 per hookup, that would mean that she had 1,400 hookups in 2017
- and 2,000 hookups in 2018.
That's somewhere between 27 and 39 per week - or between 4 and 5 per day - with no days off.
And even if the alleged victim was somehow able to charge an average of $1,000 per hookup - which seems somewhat
unlikely - that would mean she had more than 900 hookups in 2017 and at least 1,000 in 2018.
13
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=== Page 14 ===
SDNY News Clips, Monday, March 9, 2020
While all of the cited figures are mathematically and physically possible, they nevertheless seem extraordinary and
almost unimaginable.
And should they prove to be true, they will likely cause a lot of coeds at Sarah Lawrence College and elsewhere to
reconsider their career options.
The Whole Story Is Somewhat Unimaginable
According to prosecutors, the exploitation began in 2010 when Ray moved into an on-campus dorm with his daughter
and several of her sophomore classmates at the college.
As outlined in his indictment, "Ray began 'therapy' sessions with some roommates purportedly to help them with their
psychological problems, and presented himself as a father figure to the roommates".
The indictment further alleges that Ray spent almost a decade physically, psychologically and sexually abusing his
victims.
Some of his alleged victims were required to perform unpaid labor at Ray's behest - while others were forced to drain
money from their personal bank accounts and those of their parents.
Prosecutors indicated that the alleged crimes involved as many as five victims - and that they took place in Westchester
County, Manhattan, and North Carolina.
Ray has been charged with a total of nine felony counts - and could be facing more than 100 years in federal prison if he
were to be found guilty of all of them.
Allegations First Emerged in 2019
Adding to the story's unbelievability is the fact that in April 2019, New York magazine published a story that included
many of the same accusations that are set forth in the indictment.
According to a statement that was released by Sarah Lawrence College at the time of Ray's arrest, it undertook an
"internal investigation" of the specific activities that were described in the New York magazine article but did not
substantiate any of those claims.
In that same statement, the college indicated that "We have not been contacted by the Southern District of New York,
but will, of course, cooperate in their investigation to the full extent of the law if invited to do so".
Why the SDNY investigators would not have discussed the matter with college officials is just one of the many mysteries
surrounding this case.
This May Be Another Case Where the Results Are OK but Not the Process
Maybe Lawrence Ray is a total scumbag who deserves to spend the rest of his life in prison.
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=== Page 15 ===
SDNY News Clips, Monday, March 9, 2020
But the way in which this case has been handled thus far - with the salacious claims made by the U.D. Attorney for the
SDNY at the press conference it held to announce Ray's arrest and the subsequent leaks to the media concerning the
materials that were seized at Ray's home - it's starting to look a lot like the script that's been followed in other recent
high-profile prosecutions.
What the hell has happened to due process - and the presumption of innocence before someone is found guilty?
Why do prosecutors feel it's necessary to try their cases in the court of public opinion before they go to trial?
How is it possible to select objective jurors who have not formed an opinion about cases like this when everyone who
watches TV and/or who has an internet connection is bombarded for months with news about the case before it goes to
trial?
Have we reached a point where trials are no longer necessary - and we're ready to just let prosecutors decide who's
guilty of committing a crime?
Is this really what the founders of America had in mind when they were drafting the U.S. Constitution?
15
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=== Page 16 ===
SDNY News Clips, Monday, March 9, 2020
Matters of Interest
Berman
US Attorney Geoffrey Berman asserts independence from Justice Department
CNN
By Kara Scannell
3/9/2020
(CNN) - Geoffrey Berman, the US attorney in Manhattan, asserted his office's independence from politics on Monday in
his first public comments since career prosecutors have clashed with Justice Department leadership over the handling of
politically sensitive cases.
Berman's rare remarks follow actions taken by Attorney General William Barr, from his characterization of former
special counsel Robert Mueller's investigative conclusions to the sentencing of Trump ally Roger Stone, that have raised
concerns among current and former prosecutors that Barr is doing the bidding of the President and politicizing the
Justice Department.
Berman, who was appointed by President Donald Trump, was asked by a reporter at a press conference whether the
Justice Department had interfered in his office's investigation of Lev Parnas and Igor Fruman, two associates of Rudy
Giuliani, Trump's personal attorney.
Parnas and Fruman, who were charged with campaign finance violations, worked with Giuliani in his effort to dig up dirt
on former Vice President Joe Biden and his son Hunter's activities in Ukraine. Prosecutors are also investigating Giuliani's
efforts in Ukraine, including his attempt to remove then-US ambassador Marie Yovanovitch.
"The Southern District of New York has a long history of integrity and pursuing cases and declining to pursue cases based
only on the facts and the law and the equities, without regard to partisan political concerns. My primary commitment is
and has been to maintain those core values and that's how our office is operating," Berman said.
Berman's statement is the first time he has spoken out about the independence of the US Attorney's Office for the
Southern District of New York, which has had a long history of operating apart from the Justice Department and often
handles high-profile cases.
Since Barr became attorney general last year, there has been tension between him and Berman. Barr has attempted to a
micromanage certain cases by asking more questions than his predecessors, according to people familiar with the
relationship. Berman has pushed back, these people say, and recently moved to indict a Turkish bank over Barr's efforts
to reach a settlement that would have avoided an indictment.
Barr clashed with federal prosecutors in recent weeks over the handling of two high-profile cases that touch the
President, the sentencing of Stone and the oversight of the prosecution of Michael Flynn, Trump's former national
security adviser. Barr assigned the US attorney from St. Louis with re-examining the Flynn investigation, among others.
He also created a new framework for investigations relating to Ukraine with the appointment of the US attorney in
Brooklyn to coordinate any existing investigations and approve the "widening and expansion of existing matters,"
according to an internal Justice Department memorandum.
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=== Page 17 ===
SDNY News Clips, Monday, March 9, 2020
That move was perceived by some former prosecutors as an attempt to assert more control over investigations tied to
Ukraine, especially those carried out by the US Attorney's Office for the Southern District of New York. In addition to the
Giuliani investigation, prosecutors are also looking into whether foreign money flowed into Trump's inaugural
committee. The office also prosecuted Michael Cohen, Trump's former personal attorney, for violating campaign finance
laws in connection to payments made to two women who alleged affairs with Trump.
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=== Page 18 ===
SDNY News Clips, Monday, March 9, 2020
Barr
Judge's blistering opinion reveals William Barr's unfitness
CNN
By Elie Honig
3/9/2020
(CNN) - As a Justice Department prosecutor, I was taught that all you have is your credibility and your independence.
Without those two attributes, you're lost. But in a scalding opinion, federal District Court Judge Reggie Walton called
into serious doubt whether Attorney General William Barr possesses either of these golden prosecutorial virtues (and
before anyone cries politics, Judge Walton was nominated to the bench by President George W. Bush, a Republican, in
2001).
Judge Walton's opinion pulls no punches. He finds that "the Court cannot reconcile certain public representations made
by Attorney General Barr with the findings in the Mueller Report." (Judge Walton is hardly alone in this assessment;
Mueller himself castigated Barr for "not fully captur[ing] the context, nature, and substance of this Office's work and
conclusions.") The judge notes Barr's "lack of candor" which "call[s] into question Attorney General Barr's credibility and
in turn, the Department's representation" that it had properly redacted the Mueller report in the Freedom of
Information Act (FOIA) lawsuit before the Court.
The Justice Department released a statement taking issue with the judge's ruling, noting that its attorneys worked with
Mueller's team to redact the report. But it completely misses the point. Judge Walton criticizes Barr not for the
redactions made to the Mueller report, but rather for Barr's misleading public comments about it. The Justice
Department is silent on this issue.
Having already trashed Barr's credibility, Judge Walton then turned his fire on Barr's lack of political independence,
noting that Barr's public "inconsistencies" with the Mueller report -- at a time when the public did not have access to the
report itself -- "cause the Court to seriously question whether Attorney General Barr made a calculated attempt to
influence public discourse about the Mueller Report in favor of President Trump..."
For a former Justice Department prosecutor like myself, this is a jaw-dropper. Not only does a Republican-nominated
federal judge call out Barr for fudging the truth, but he further questions whether Barr did it to protect the President --
precisely the opposite of what the Justice Department is, and should be, about.
Judge Walton's scathing decision has led to a humiliating result not just for Barr but for the entire Justice Department. In
a FOIA lawsuit, a judge typically defers heavily to the Department to make necessary and appropriate redactions to any
materials before they are released to the public. Here, however, Judge Walton has essentially said: I don't trust you to
do this honestly, so I'll have to babysit you and review your work first. (Fool me once...)
A ruling like Judge Walton's would derail the career of any line-level prosecutor. In my 14 years as a federal and state
prosecutor, neither I nor any of my hundreds of colleagues were ever called out anywhere near so bluntly and forcefully
by a judge. Judge Walton's powerful words confirm what thousands of former Justice Department prosecutors and
officials (including me) already firmly believe: Barr is unfit to serve as Attorney General.
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=== Page 19 ===
SDNY News Clips, Monday, March 9, 2020
Weinstein
Harvey Weinstein injured in Rikers Island jail, his publicist says
CNN
By Chloe Melas and Ralph Ellis
3/9/2020
(CNN) - Convicted rapist Harvey Weinstein fell sometime Sunday morning while at Rikers Island jail, his spokesperson
Juda Englemayer told CNN.
Englemayer said Weinstein was dizzy before he fell.
"Harvey says his head throbs all the time and thinks he has a concussion. He has not been officially diagnosed,"
Englemayer said.
Englemayer, who spoke to Weinstein by phone Sunday evening, says Weinstein has "had a lot of time to think about his
life and what he's done," adding, "He said he wasn't a nice guy and that's how he got here."
Movie mogul Weinstein doesn't walk steadily and doesn't have a walker in jail, Englemayer said. During his recent trial,
Weinstein used a walker to get in and out of court.
After Weinstein was convicted of sex crimes February 24, paramedics determined he had a heart issue and transported
him to Bellevue Hospital in Manhattan.
Weinstein, 67, had a heart procedure last Wednesday during which doctors inserted a stent, Engelmayer told CNN
recently. He was moved Thursday to the infirmary unit at Rikers Island, New York's main jail complex, Engelmayer said.
He's expected to be sentenced March 11 in New York State Supreme Court. He faces a minimum of five years and a
maximum of more than two decades in prison.
A New York jury convicted Weinstein of committing a criminal sex act in the first degree involving one woman and
another count of rape in the third degree.
19
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=== Page 20 ===
SDNY News Clips, Monday, March 9, 2020
Coronavirus
SDNY Courthouses Ban Entry To Any Exposed To Coronavirus
Law360
By Frank G. Runyeon
3/9/2020
Law360, New York (March 9, 2020, 11:10 AM EDT) -- The Southern District of New York on Monday enacted new
restrictions on who may enter the courts due to the coronavirus outbreak, barring entry to anyone who recently
traveled to countries that are hardest hit by the virus or those who have come into contact with it.
In an order, Chief Judge Colleen McMahon said the ban applies to anyone who has traveled to China, South Korea,
Japan, Italy or Iran in the past 14 days. Also banned are people who live with or have come into close contact with
anyone who has been in one of those countries during that period; people who have been asked to self-quarantine; and
those who have either been diagnosed with the virus - called COVID-19 - or come into contact with someone who has
been diagnosed.
The order cited guidance by the U.S. Centers for Disease Control that the best way to avoid illness is by avoiding the
virus altogether.
"Anyone attempting to enter in violation of these protocols will be denied entry by a court security officer," Judge
McMahon wrote. She added that the restrictions would "remain in place temporarily until it is determined to be safe to
remove them."
20
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c1: EFTA00015851
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=== Page 1 ===
From: "Bourtin, Nicolas"
To:
)"
Cc: "Levin, Sharon Cohen"
Subject:
/ Epstein
Date: Tue, 01 Oct 2019 23:19:15 +0000
Attachments: TD_Filed_SAR_2019-43693.do.pdf.
-
As I mentioned last night, attached is a SAR that
filed today in connection with persons associated with Jeffrey
Epstein. The bank would like to close all of the accounts of the entities named in the SAR as soon as possible. (The
current balance on those accounts is approximately $30 million.) Before doing so, the bank wanted to make your office
aware of these accounts in case the government intends to take any action.
Please advise once you've had a chance to consider.
Many thanks.
Nic
Nicolas Bourtin I Sullivan & Cromwell LLP
I
New York, NY 10004-2498
This e-mail is sent by a law firm and contains information that may be privileged and confidential. If you are not
the intended recipient, please delete the e-mail and notify us immediately.
EFTA00015851


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=== Page 1 ===
U.S. V. Ghislaine Maxwell
Maxwell has been charged with facilitating
the sexual abuse of underaged girls by Jeffrey
Epstein.
The charged conduct occurred in New York city,
Palm Beach, Florida, Santa Fe, New Mexico, and
London, England.
If you recognize either of these persons and feel
you may be a victim, please call the following
number:
1-800-CALL FBI
EFTA00016157

=== Page 2 ===
U.S. v. Ghislaine Maxwell
Properties Owned by Epstein Where Alleged
Grooming and/or Abuse of Minor Victims Occurred:
New York, New York
Palm Beach, Florida
Santa Fe, New Mexico
MASSACHUSETTS JUSTICE
WITH
EFTA00016158


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=== Page 1 ===
2996479
AT&T
06/17/2020
WIRELESS
SUBSCRIBER INFORMATION
Financial Liable Party
Name:
SCOTT BORGERSON
Credit Address:
Customer Since:
03/13/2004
Photo ID Type:
Photo ID State:
Photo ID Number:
DOB:
SSN/TaxID/FEIN:
Contact Name:
Contact Home Phone:
Contact Work Phone:
Contact Home Email:
Contact Work Email:
Billing Party
Account Number:
Name:
SCOTT BORGERSON
Billing Address:
Account Status:
Active
Billing Cycle:
43
User Information
MSISDN:
IMSI:
MSISDN Active:
09/17/2016 - Current
Name:
G MAX
User Address:
Service Start Date:
09/17/2016
Dealer Info:
Q3LJG Q3LJG Q3LJG
Payment Type:
Postpaid
Contact Name:
G MAX
Contact Home Phone:
Contact Work Phone:
Contact Home Email:
Contact Work Email:
Status Change History
Status Change Reason
Status Change Date
AT&T PROPRIETARY
The information contained here is for use by authorized person only and
is not for general distribution.
Page 1 of 1
EFTA00017139

=== Page 2 ===
2996479
AT&T
06/17/2020
WIRELESS
SUBSCRIBER INFORMATION
Financial Liable Party
Name:
SCOTT BORGERSON
Credit Address:
Customer Since:
03/13/2004
Photo ID Type:
Photo ID State:
Photo ID Number:
DOB:
SSN/TaxID/FEIN:
Contact Name:
Contact Home Phone:
Contact Work Phone:
Contact Home Email:
Contact Work Email:
Billing Party
Account Number:
Name:
SCOTT BORGERSON
Billing Address:
Account Status:
Active
Billing Cycle:
43
User Information
MSISDN:
IMSI:
MSISDN Active:
09/20/2019 - Current
Name:
NOAH BORGERSON
User Address:
Service Start Date:
09/20/2019
Dealer Info:
B8GPB B8GPB B8GPB
Payment Type:
Postpaid
Contact Name:
NOAH BORGERSON
Contact Home Phone:
Contact Work Phone:
Contact Home Email:
Contact Work Email:
Status Change History
Status Change Reason
Status Change Date
AT&T PROPRIETARY
The information contained here is for use by authorized person only and
is not for general distribution.
Page 1 of 1
EFTA00017140

=== Page 3 ===
2996479
AT&T
06/17/2020
WIRELESS
SUBSCRIBER INFORMATION
Financial Liable Party
Name:
SCOTT BORGERSON
Credit Address:
Customer Since:
03/13/2004
Photo ID Type:
Photo ID State:
Photo ID Number:
DOB:
SSN/TaxID/FEIN:
Contact Name:
Contact Home Phone:
Contact Work Phone:
Contact Home Email:
Contact Work Email:
Billing Party
Account Number:
Name:
SCOTT BORGERSON
Billing Address:
Account Status:
Active
Billing Cycle:
43
User Information
MSISDN:
IMSI:
MSISDN Active:
01/22/2018 - Current
Name:
G WIFI
User Address:
Service Start Date:
01/22/2018
Dealer Info:
DOHOW DOHOW DOHOW
Payment Type:
Postpaid
Contact Name:
G WIFI
Contact Home Phone:
Contact Work Phone:
Contact Home Email:
Contact Work Email:
Status Change History
Status Change Reason
Status Change Date
AT&T PROPRIETARY
The information contained here is for use by authorized person only and
is not for general distribution.
Page 1 of 1
EFTA00017141

=== Page 4 ===
2996479
AT&T
06/17/2020
WIRELESS
SUBSCRIBER INFORMATION
Financial Liable Party
Name:
SCOTT BORGERSON
Credit Address:
Customer Since:
03/13/2004
Photo ID Type:
Photo ID State:
Photo ID Number:
DOB:
SSN/TaxID/FEIN:
Contact Name:
Contact Home Phone:
Contact Work Phone:
Contact Home Email:
Contact Work Email:
Billing Party
Account Number:
Name:
SCOTT BORGERSON
Billing Address:
Account Status:
Active
Billing Cycle:
43
User Information
MSISDN:
IMSI:
MSISDN Active:
07/27/2007 - Current
Name:
SCOTT G BORGERSON
User Address:
Service Start Date:
07/22/2007
Dealer Info:
AMZ00 AMZ00 AMZ00
Payment Type:
Postpaid
Contact Name:
SCOTT G BORGERSON
Contact Home Phone:
Contact Work Phone:
Contact Home Email:
Contact Work Email:
Status Change History
Status Change Reason
Status Change Date
AT&T PROPRIETARY
The information contained here is for use by authorized person only and
is not for general distribution.
Page 1 of 1
EFTA00017142


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=== Page 1 ===
From:
To:
Subject: RE: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
Date: Mon, 14 Sep 2020 20:07:29 +0000
Yep I got it. It's downloading now but will take a little while. It's about 11 GB.
From:
Sent: Monday, September 14, 2020 4:06 PM
To:
Subject: RE: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
Forwarded it. All good?
From:
Sent: Monday, September 14, 2020 3:51 PM
To:
Subject: RE: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
Will you forward the confirmation link once it comes in?
From:
Sent: Monday, September 14, 2020 3:33 PM
To:
Subject: FW: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
PBSA is giving us their entire Epstein file.
Will, when I get the email with the info about how to download the file, I'll forward it to you. Would you please download
everything and save it on the share? You can put it here:
USvEpstein-
2018R01618\Investigation\PBSA Epstein File
Original Message
From:
Sent: Monday, September 14, 2020 3:23 PM
To:
Subject: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
The attached document is in regard to the above referenced case, to which you are a party of or have an interest in. If
you have any questions, please contact our office at
EFTA00016318


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=== Page 1 ===
10/6/21, 12:58 PM
III/FBI/State Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
III Information
The following information is provided in response to your request for a search of the III based on:
IDENTIFICATION DATA UPDATED 2016/10/24
THE RECORD(S) CAN BE OBTAINED THROUGH THE INTERSTATE IDENTIFICATION
INDEX BY USING THE APPROPRIATE NCIC TRANSACTION.
END
1/1
EFTA00015094


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=== Page 1 ===
From:
(USAFLS)"
To:
Cc:
Subject: RE: Epstein -- Upcoming Court Dates and Motion filed by Palm Beach Post
Date: Wed, 03 Jun 2009 19:22:46 +0000
Importance: Normal
I will be here on Thursday and Friday.
From:
(USAFLS)
Sent: Tuesday, June 02, 2009 4:08 PM
To:
(USAELS)
Cc:
(FBI);
(FBI)
Subject: Epstein Upcoming Court Dates and Motion filed by Palm Beach Post
Hi all — It is the summer, so Epstein must be back in full swing. There are two court hearings next week that we
have been given notice of (one of which we have been "invited" to attend), and we need to discuss our position
before I attend. Here are the most recent items:
1. Judge Marra has asked us to appear on Friday, June 12th to address whether "Epstein's defense of the
civil suits breaches the Non-Prosecution Agreement."
2. The Palm Beach Post has filed a motion to intervene in one of the state court civil suits in order to ask the
judge to unseal the Non-Prosecution Agreement.
3. A hearing on the motion to unseal in state court is set for Wednesday, June 10th. We have been given
notice of that hearing, along with Michael McAuliffe from the State Attorney's Office.
4. On May 26, 2009, Epstein's counsel filed a pleading in federal court that essentially argues that the civil
claims filed under 18 USC 2255 must all be dismissed (i.e., that he can never be held liable under that
statute) because he was not convicted of any federal offense. This directly contradicts the Non-
Prosecution Agreement, wherein Epstein agreed that if any identified victim elects to file suit pursuant to
18 USC 2255, "Epstein will not contest the jurisdiction of the United States District Court for the
Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to
contest liability At this point, I believe that Epstein is probably in breach of the Agreement. I will
gather the documentation related to this for your review. We are required to provide him with "timely
notice" of his breach and file an indictment within 60 days of learning of the breach. That means that we
need to indict by July 24th — my
birthday!
5. Several litigants have asked Judge Marra to unseal the Non-Prosecution Agreement. No hearing has been
set on those motions.
Can we do a conference call on Thursday afternoon or Friday morning to discuss? There are a number of things
that we have to do before we provide notice of breach, so time is of the essence. I can drive down to Miami on
EFTA00014173

=== Page 2 ===
Friday if that works better.
Thank you.
Assistant U.S. Attorney
Southern District of Florida
500 East Broward Boulevard, 7th Floor
Ft. Lauderdale, FL 33394
EFTA00014174


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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: Unsealing
Date: Sat, 01 Aug 2020 17:48:17 +0000
Yeah, that's what all this week's fighting with Boies has been about. The Circuit has now given them until the
20th to brief it, I think, so we can ask Boies about this in advance, but the documents have victim names
redacted, for example --
https://apps.npr.org/documents/document.html?id=7011492
Deposition-May-2016
That redacts
name, for example.
Though it wouldn't be new information that
was approached by Epstein and Maxwell and interacted with
them, given
comments to the press previously.
Original Message
From:
)
Sent: Friday, July 31, 2020 22:51
To:
)
)
Subject: Unsealing
I didn't realize Maxwell's deposition is being unsealed in the litigation before Judge Preska. Is that right? I saw
an article suggesting that will be released in the batch of documents, but wasn't sure.
is named in it,
obviously, so that raises concerns about victim confidentiality.
Sent from my iPhone
EFTA00017066


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=== Page 1 ===
11/26/21, 7:21 PM
Mail
R. (NY) (FBI) - Outlook
Re: Photos for Maxwell Trial
Thu 11/4/2021 4:47 PM
To:
>
Thank you!
From:
Sent: Thursday, November 4, 2021 4:44:42 PM
To:
Subject: Photos for Maxwell Trial
Hey
This is the spreadsheet you mentioned the other day.
Let me know if you need anything else!
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
1/1
EFTA00014960


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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From:
Date: November 8, 2021
Re:
United States V. Ghislaine Maxwell
Court Docket No: 20 Cr. 330 (AJN)
USAO No: 2018R01618
Witness Name:
Witness DOB:
(Name/DOB as printed here will be forwarded to travel agency and then to TSA and must exactly
match the witness's driver's license or other travel ID or TSA will not permit the witness to fly.)
Witness Address:
Witness TelNos (mobile):
Witness e-mail:
Witness Needed to Appear in SDNY on
Date: December 1, 2021
Time: 4 PM
Witness Needed to Appear for:
Trial ( X)
Date:
Grand Jury ( )
Date:
Trial Prep () Date: August 16, 2021 at 1 PM, and August 17, 2021 at 10 AM
Estimated Dates Witness will Arrive:
December 1, 2021 (morning)
Depart:
December 3, 2021 (evening)
Is the person a Fact Witness and not an Expert Witness?
(Yes/No):
Yes
Current Federal Civilian or Military Employee?
(Yes/No):
No
Is the Witness Facing Criminal Charges?
(Yes/No):
No
Does the Witness Reside Outside the Continental United States?
(Yes/No):
No
Is this Witness a Victim-Witness?
(Yes/No):
No
Hotel Required?
(Yes/No):
Yes
Has the Witness advised you of any unusual travel expenses?
(Yes/No):
No
Unusual expenses of fact witnesses can include
special travel arrangements
care for dependent child or incapacitated family member left at home
kennel fees for pets
rev. 2019.11.19
EFTA00015887

=== Page 2 ===
necessary travel companion
extra baggage (more than one bag)
Please describe the unusual expense:
For Victim-Witness Coordinator:
1. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW
is apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should
be used.
For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to
court/GJ testimony.
Witnesses may only be brought in under the FEWS appropriation for grand jury testimony that
has been scheduled and where the witness is expected to testify before the grand jury; court
testimony; or preparation for same. Any other witness travel, e.g., for investigative interviews,
must be covered by the investigating component from litigative funds. See
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
EFTA00015888


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 Page 1 of 12
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 7/30/2020
SOUTHERN DISTRICT OF NEW YORK
X
:
:
UNITED STATES OF AMERICA
:
PROTECTIVE ORDER
- V. -
:
:
20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
:
:
Defendant.
:
:
X
ALISON J. NATHAN, United States District Judge:
WHEREAS the Government intends to produce to GHISLAINE
MAXWELL, the defendant, certain documents and materials that
(i) affect the privacy and confidentiality of individuals,
(ii) would impede, if prematurely disclosed, the Government's
ongoing investigation; (iii) would risk prejudicial pretrial
publicity if publicly disseminated, and (iv) is not authorized
to be disclosed to the public or disclosed beyond that which is
necessary for the defense of this action, and other materials
pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16")
and pursuant to any other disclosure obligations (collectively,
the "Discovery"), which contain sensitive, confidential, or
personal identifying information;
WHEREAS, the Government seeks to protect sensitive,
confidential, or personal identifying information contained in
the materials it produces consistent with Rule 16 or other
disclosure obligations;
1
EFTA00016247

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 Page 2 of 12
WHEREAS the Government has applied for the entry of
this Order;
IT HEREBY IS ORDERED:
1.
The Discovery disclosed to the defendant
("Defendant") and/or to the defendant's criminal defense
attorneys ("Defense Counsel") during the course of proceedings
in this action:
a)
Shall be used by the Defendant or her
Defense Counsel solely for purposes of the defense of this
criminal action, and not for any civil proceeding or any purpose
other than the defense of this action;
b)
Shall not be copied or otherwise recorded or
transmitted by the Defendant, except to Defense Counsel, or
except as necessary for the Defendant to take notes, which are
not to be further transmitted to anyone other than Defense
Counsel;
c)
Shall not be disclosed or distributed in any
form by the Defendant or her counsel except as set forth in
paragraph 1 (d) below;
d)
May be disclosed only by Defense Counsel and
only to the following persons ("Designated Persons") :
i. investigative, secretarial, clerical,
or paralegal personnel employed full-time, part-time, or as
2
EFTA00016248

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 Page 3 of 12
independent contractors by the defendant's counsel ("Defense
Staff") ;
ii. any expert or potential expert, legal
advisor, consultant, or any other individual retained or
employed by the Defendant and Defense Counsel for the purpose of
assisting in the defense of this case ("Defense
Experts/Advisors");
iii. such other persons as hereafter may be
authorized by Order of the Court ("Other Authorized Persons") ;
e) May be provided to prospective witnesses and
their counsel (collectively, "Potential Defense Witnesses"), to
the extent deemed necessary by defense counsel, for trial
preparation. To the extent Discovery materials are disclosed to
Potential Defense Witnesses, they agree that any such materials
will not be further copied, distributed, or otherwise
transmitted to individuals other than the recipient Potential
Defense Witnesses.
2. The Defendant and Defense Counsel shall provide a
copy of this Order to any Designated Persons to whom they
disclose Discovery materials. Prior to disclosure of Discovery
materials to Designated Persons, any such Designated Person
shall agree to be subject to the terms of this Order by signing
a copy hereof and stating that they "Agree to be bound by the
terms herein," and providing such copy to Defense Counsel. All
3
EFTA00016249

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 Page 4 of 12
such acknowledgments shall be retained by Defense Counsel and
shall be subject to in camera review by the Court if good cause
for review is demonstrated. The Defendant and her counsel need
not obtain signatures from any member of the defense team (i.e.,
attorneys, experts, consultants, paralegals, investigators,
support personnel, and secretarial staff involved in the
representation of the defendants in this case), all of whom are
nonetheless bound by this Protective Order.
3.
To the extent that Discovery is disseminated to
Defense Experts/Advisors, Other Authorized Persons, or Potential
Defense Witnesses, via means other than electronic mail, Defense
Counsel shall encrypt and/or password protect the Discovery.
4. The Government, the Defendant, Defense Counsel,
Defense Staff, Defense Experts/Advisors, Potential Defense
Witnesses and their counsel, and Other Authorized Persons are
prohibited from posting or causing to be posted any of the
Discovery or information contained in the Discovery on the
Internet, including any social media website or other publicly
available medium.
5.
The Government (other than in the discharge of
their professional obligations in this matter), the Defendant,
Defense Counsel, Defense Staff, Defense Experts/Advisors,
Potential Defense Witnesses and their counsel, and Other
Authorized Persons are strictly prohibited from publicly
4
EFTA00016250

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 Page 5 of 12
disclosing or disseminating the identity of any victims or
witnesses referenced in the Discovery. This Order does not
prohibit Defense Counsel or Defense Staff from referencing the
identities of individuals they believe may be relevant to the
defense to Potential Defense Witnesses and their counsel during
the course of the investigation and preparation of the defense
case at trial. Any Potential Defense Witnesses and their
counsel who are provided identifying information by Defense
Counsel or Defense Staff are prohibited from further disclosing
or disseminating such identifying information. This Order does
not prohibit Defense Counsel from publicly referencing
individuals who have spoken by name on the public record in this
case.
6.
The Defendant, Defense Counsel, Defense Staff,
Defense Experts/Advisors, Potential Defense Witnesses, and Other
Authorized Persons are prohibited from filing publicly as an
attachment to a filing or excerpted within a filing the identity
of any victims or witnesses referenced in the Discovery, who
have not spoken by name on the public record in this case,
unless authorized by the Government in writing or by Order of
the Court. Any such filings must be filed under seal, unless
authorized by the Government in writing or by Order of the
Court.
5
EFTA00016251

=== Page 6 ===
Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 Page 6 of 12
7.
Copies of Discovery or other materials produced
by the Government in this action bearing "confidential" stamps,
or designated as "confidential" as described below, and/or
electronic Discovery materials designated as "confidential" by
the Government, including such materials marked as
"confidential" either on the documents or materials themselves,
or designated as "confidential" in a folder or document title,
are deemed "Confidential Information." The Government shall
clearly mark all pages or electronic materials containing
Confidential Information, or folder or document titles as
necessary, with "confidential" designations.
8.
Confidential Information may contain personal
identification information of victims, witnesses, or other
specific individuals who are not parties to this action, and
other confidential information; as well as information that
identifies, or could lead to the identification of, witnesses in
this matter. The identity of an alleged victim or witness who
has identified herself or himself publicly as such on the record
in this case shall not be treated as Confidential Information.
9.
Defense Counsel may, at any time, notify the
Government that Defense Counsel does not concur in the
designation of documents or other materials as Confidential
Information. If the Government does not agree to de-designate
such documents or materials, Defense Counsel may thereafter move
6
EFTA00016252

=== Page 7 ===
Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 Page 7 of 12
the Court for an Order de-designating such documents or
materials. The Government's designation of such documents and
materials as Confidential Information will be controlling absent
contrary order of the Court.
10. Confidential Information disclosed to the
defendant, or Defense Counsel, respectively, during the course
of proceedings in this action:
a)
Shall be used by the Defendant or her
Defense Counsel solely for purposes of the defense of this
criminal action, and not for any civil proceeding or any purpose
other than the defense of this action;
b)
Shall be maintained in a safe and secure
manner;
c)
Shall be reviewed and possessed by the
Defendant in hard copy solely in the presence of Defense
Counsel;
d)
Shall be possessed in electronic format only
by Defense Counsel and by appropriate officials of the Bureau of
Prisons ("BOP"), who shall provide the defendant with electronic
access to the Discovery, including Confidential Information,
consistent with the rules and regulations of the BOP, for the
Defendant's review;
7
EFTA00016253

=== Page 8 ===
Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 Page 8 of 12
e)
Shall be reviewed by the Defendant solely in
the presence of Defense Counsel or when provided access to
Discovery materials in electronic format by BOP officials;
f)
May be disclosed only by Defense Counsel and
only to Designated Persons;
g)
May be shown to, either in person, by
videoconference, or via a read-only document review platform,
but not disseminated to or provided copies of to, Potential
Defense Witnesses, to the extent deemed necessary by Defense
Counsel, for trial preparation, and after such individual (s)
have read and signed this Order acknowledging that such
individual (s) are bound by this Order.
11. Copies of Discovery or other materials produced
by the Government in this action bearing "highly confidential"
stamps or otherwise specifically designated as "highly
confidential," and/or electronic Discovery materials designated
as "highly confidential" by the Government, including such
materials marked as "highly confidential" either on the
documents or materials themselves, or designated as "highly
confidential" in an index, folder title, or document title, are
deemed "Highly Confidential Information." To the extent any
Highly Confidential Information is physically produced to the
Defendant and Defense Counsel, rather than being made available
to the Defendant and Defense Counsel for on-site review, the
8
EFTA00016254

=== Page 9 ===
Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 Page 9 of 12
Government shall clearly mark all such pages or electronic
materials containing Highly Confidential Information with
"highly confidential" stamps on the documents or materials
themselves.
12. Highly Confidential Information contains nude,
partially-nude, or otherwise sexualized images, videos, or other
depictions of individuals.
13. Defense Counsel may, at any time, notify the
Government that Defense Counsel does not concur in the
designation of documents or other materials as Highly
Confidential Information. If the Government does not agree to
de-designate such documents or materials, Defense Counsel may
thereafter move the Court for an Order de-designating such
documents or materials. The Government's designation of such
documents and materials as Highly Confidential Information will
be controlling absent contrary order of the Court.
14. Highly Confidential Information disclosed to
Defense Counsel during the course of proceedings in this action:
a)
Shall be used by the Defendant or her
Defense Counsel solely for purposes of the defense of this
criminal action, and not for any civil proceeding or any purpose
other than the defense of this action;
9
EFTA00016255

=== Page 10 ===
Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 Page 10 of 12
b)
Shall not be disseminated, transmitted, or
otherwise copied and provided to Defense Counsel or the
Defendant;
c)
Shall be reviewed by the Defendant solely in
the presence of Defense Counsel;
d)
Shall not be possessed outside the presence
of Defense Counsel, or maintained, by the Defendant;
e)
Shall be made available for inspection by
Defense Counsel and the Defendant, under the protection of law
enforcement officers or employees; and
f)
Shall not be copied or otherwise duplicated
by Defense Counsel or the Defendant during such inspections.
15. The Defendant, Defense Counsel, Defense Staff,
Defense Experts/Advisors, Potential Defense Witnesses, and Other
Authorized Persons are prohibited from filing publicly as an
attachment to a filing or excerpted within a filing any
Confidential Information or Highly Confidential Information
referenced in the Discovery, unless authorized by the Government
in writing or by Order of the Court. Any such filings must be
filed under seal, unless authorized by the Government in writing
or by Order of the Court.
16. The provisions of this Order shall not be
construed as preventing disclosure of any information, with the
exception of victim or witness identifying information, that is
10
EFTA00016256

=== Page 11 ===
Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 Page 11 of 12
publicly available or obtained by the Defendant or her Defense
Counsel from a source other than the Government.
17. Except for Discovery that has been made part of
the record of this case, Defense Counsel shall return to the
Government or securely destroy or delete all Discovery,
including but not limited to Confidential Information, within 30
days of the expiration of the period for direct appeal from any
verdict in the above-captioned case; the period of direct appeal
from any order dismissing any of the charges in the above-
captioned case; the expiration of the period for a petition
pursuant to 28 U.S.C. $ 2255; any period of time required by the
federal or state ethics rules applicable to any attorney of
record in this case; or the granting of any motion made on
behalf of the Government dismissing any charges in the above-
captioned case, whichever date is later.
18. The foregoing provisions shall remain in effect
unless and until either (a) the Government and Defense Counsel
mutually agree in writing otherwise, or (b) this Order is
modified by further order of the Court.
19. The Government and Defense Counsel agree to meet
and confer in advance of any hearings or trial to discuss and
agree to any modifications necessary for the presentation of
evidence at those proceedings. In the absence of agreement,
11
EFTA00016257

=== Page 12 ===
Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 Page 12 of 12
Defense Counsel may make an appropriate application to the Court
for any such modifications.
SO ORDERED:
Dated:
New York, New York
July 30, 2020
Alim D.Nitto
HONORABLE ALISON J. NATHAN
United States District Judge
12
EFTA00016258


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=== Page 1 ===
From:
To: BOBBI C STERNHEIM <bcsternheim@mac.com>
Cc:
Subject: Re: Ghislaine Maxwell 02879-509
Date: Fri, 13 Aug 2021 11:54:22 +0000
Good morning Bobbi-
There was a miscommunication on our end internally. There was no
breach. The address provided was a very secure line, however, it was
already one being used. We are creating a line as secure as possible.
We are hoping for this to be complete by the 9:30 scheduled call, but I
cannot confirm it will be ready by then.
I sincerely apologize for the confusion and inconvenience.
Best,
BOBBI C STERNHEIM <bcsternheim@mac.com> 8/12/2021 11:29 AM
Good morning-
In my email of 8/9 (see below), I raised concerns regarding use of the
MDC Zoom
platform because it does not preclude third parties with access
information to the Zoom "Courtrooms"
from interfering (inadvertently or intentionally) with Ms. Maxwell's
privileged communication.
That concern manifested itself today when third parties accessed the
Zoom room used by Ms. Maxwell and counsel.
This breach was reported to, and I believe witnessed by, MDC staff,
including technician
This severely impacts confidential privileged attorney-client
communication and is especially concerning in this
high-profile case.
I am requesting that we immediately revert back to the WebEx platform
controlled by Cohen & Gresser.
Please contact me to discuss.
Thank you-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
EFTA00015856

=== Page 2 ===
Main: 212-243-1100
Cell: 917-912-9698
Fax: 888-587-4737
bcsternheim@mac.com
This message and any attached documents contain information from the
Law Offices of Bobbi C. Sternheim that may be confidential and/or
privileged.
If you are not the intended recipient, you may not read, copy,
distribute, or use this information.
If you have received this transmission in error, please notify the
sender immediately by reply e-mail and then delete this message. Thank
you.
> On Aug 9, 2021, at 10:16 PM, BOBBI C STERNHEIM <bcsternheim@mac.com>
wrote:
>
> It is my understanding that the new MDC Zoom platform does not
preclude third parties who have the access information
> to the Zoom "Courtroom" from interfering (inadvertently or
intentionally) with Ms. Maxwell's privileged communication.
EFTA00015857


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=== Page 1 ===
From:
To:
Subject: FW: photo project
Date: Wed, 24 Nov 2021 19:03:18 +0000
Attachments: Photos_for_Trial_Prep_with_Location_Info.xlsx
From:
Sent: Thursday, September 30, 2021 4:31 PM
To:
Cc:
Subject: RE: photo project
Hi
The photo sourcing project is completed and attached.
I added 3 columns: Evidence Item #, Name of CD and Location of Item.
Thanks,
From:
Sent: Monday, September 27, 2021 6:26 PM
To:
Cc:
Subject: [EXTERNAL EMAIL] - photo project
Hi
Just checking in on the photo sourcing project. Do you think you'll be able to send us that spreadsheet in the next few
days?
Thanks so much for helping with this.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00016469


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=== Page 1 ===
JANE DOE #7
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
O.A. 23
7/16/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 27
7/22/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 32
8/17/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 39
8/25/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 41
9/16/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 44
10/3/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 45
10/26/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 57
12/4/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 66
12/16/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 75
1/1/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 85
1/14/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 89
1/27/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 90
1/28/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 92
2/1/05
Conspiracy to entice a minor to
engage in prostitution
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 1 OF 2
JANE DOE #7
EFTA00016008

=== Page 2 ===
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
Ct. 11
7/22/04 -
EPSTEIN
Enticement of a minor to engage in
1/31/05
prostitution
Ct. 21
7/16/04
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 22
7/22/04
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 24
8/19/04
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 26
9/16/04
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 27
10/29/04
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 33
12/17/04
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 34
1/1/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 55
7/22/04 -
EPSTEIN
Recruiting, enticing, providing, or
1/31/05
obtaining a person, knowing that she
is a minor and will be caused to
engage in a commercial sex act
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 2 OF 2
JANE DOE #7
EFTA00016009


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=== Page 1 ===
EXHIBIT A
EFTA00014679

=== Page 2 ===
La I'm 80 excited.
Boss bought
me atcket to come out + See
her thas been almost ayear- scady.
He is very wealthy + might help
me yet into or pay for wilege
up because I hate di Ssapoi ntment
don't mant to yet my hopes
but it would be really 100 l it
it happened + even it / doesn H
hiv, it is 80 great / get to go see
- Not For Media Use
0010
Property of
FFTA0001


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
)"
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
i
(USANYS) 1"
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Date: Mon, 21 Dec 2020 21:55:26 +0000
Yes, I highlighted the huge volume of discovery for Maxwell when I spoke with
this morning. That volume was a
significant driver in our team's decision to request that she receive so much time to review her discovery. Based on my
read of the transcript from this morning's Rivera conference, it sounds like Rivera is not even using all the time he has
now. By contrast, my understanding is that Maxwell is using up the full time she has been given.
From:
(USANYS)
Sent: Monday, December 21, 2020 4:47 PM
To:
(USANYS)
i
(USANYS)
i
(USANYS)
>;
(USANYS)
is
is
in
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
I'd also look into potential differences in the volume of discovery. No idea what your case entails,
but in Maxwell
we have produced truly enormous volumes of material (we seized 60 some devices during the investigation, for example,
in addition to an entire FBI file from the prior Florida investigation...) that may explain some of this.
From:
(USANYS)
Sent: Monday, December 21, 2020 4:42 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
i
)
in
>;
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Thanks,
Can you keep me posted on what we think will be the substance of the draft declaration when you know
(that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences between MCC
and MDC, as well as specific differences in their housing situations?
From:
(USANYS)
Sent: Monday, December 21, 2020 4:35 PM
EFTA00015972

=== Page 2 ===
To:
(USANYS)
i
(USANYS)
V.
(USANYS)
is
(USANYS)
is
)
is
)
i
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
All:
I wanted to bring to your attention a recent issue that's surfaced in United States v. Rivera et al., a sex
trafficking case pending before Judge Engelmayer. As I'll describe in more detail below, Judge
Engelmayer has asked us to submit a declaration from the BOP explaining why the discovery and
counsel access accommodations provided to Ghislaine Maxwell (detained at the MDC outside the
general population) cannot be extended to Justin Rivera (detained at the MCC in the general
population).
Justin Rivera was charged in February 2019 with sex trafficking conspiracy. He's been detained at the
MCC since April 2019 on consent (he's also serving a state sentence). His trial, which was originally
scheduled for April 2019, is expected to start on February 16, 2020. In July 2020, he had new counsel
appointed, citing an irreconcilable breakdown with his former counsel.
Since this fall, Judge Engelmayer has become increasingly frustrated with the MCC's treatment of
Rivera. In particular, he's cited their failure to provide Rivera with adequate accommodations to
review discovery and meet with his lawyers, who refuse to visit Rivera at the MCC for personal health
concerns. We have two court orders in place to address these issues: (1) a laptop order, which requires
the MCC to provide Rivera access to a laptop for three hours per day; and (2) a videoconference order,
which requires the MCC to make available four hours of videoconferencing each week, in addition to
any telephone or videoconference calls obtained through the Federal Defenders.
At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time Rivera
has for videoconferences and electronic discovery review is insufficient for trial preparation, although
defense counsel has stated that they may request more time in the future. However, in a letter last
night and during a court conference this morning (transcript attached), defense counsel cited the
accommodations that the MDC has provided to Maxwell, describing them as "strikingly different and
far superior" to those afforded to Rivera. Defense counsel further suggested that Rivera was being
treated differently on account of his race, gender and class. Judge Engelmayer stated that the
disparity in access "jumped off the page" and that the optics were "terrible," and asked us to explain
the rationale for the differing treatment. After conferring with
and
before
our conference, we explained our understanding that the disparity comes down to the fact that
Maxwell and Rivera have very different housing situations, with Maxwell's situation being more
amenable to greater access to electronic discovery review and legal visits.
Judge Engelmayer asked us to submit a declaration, from an appropriate person at the BOP,
explaining in more detail why the accommodations provided to Maxwell cannot be extended to Rivera.
Based on the recent bail opposition in the Maxwell case, I believe the differences in counsel/discovery
access are as follows:
Accommodation
Maxwell
Rivera
EFTA00015973

=== Page 3 ===
Review of electronic
13 hours per day/7 days per
3 hours per day/7 days per
discovery (NB: each
week (91 hours total)
week (21 hours total)
defendant has laptop access)
Counsel visits (by video)
3 hours per day/5 days per
Four hours per week (plus an
week (15 hours total)
additional two hours
scheduled through the
Federal Defenders) (6 hours
total)
Weekend legal calls
As needed
Not available
The declaration is due by December 31. Because Judge Engelmayer's request implicates at least two
criminal cases, and potentially the ongoing civil litigation with the MCC, we wanted to make sure that
you were all aware of this issue. We are also happy to set up a call to discuss this further. In the
meantime, we are working with
to identify the appropriate declarant and draft an
explanation for the Court.
Best,
Assistant United States Attorney
United States Attorney's Office for the Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Tel:
EFTA00015974


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=== Page 1 ===
From:
To:
Subject: Fwd: EPSTEIN SEX OFFENDER info from EJUSTICE Portal and NYPD DAS
Date: Fri, 28 Jun 2019 20:15:50 +0000
Attachments:J_EPSTEIN_SEX_OFFENDER_FROM_NYS_via_EJUSTICE_Portal.xps,ATT00001.htm;
J_EPSTEIN_SOMU_from_DAS.xps; ATT00002.htm
Begin forwarded message:
From:
To:
Subject: EPSTEIN SEX OFFENDER info from EJUSTICE Portal and NYPD DAS
Detective
Office
Desk
Fax
Cell
1510171437462_FBI__1510171974096_DB3b.jpg
EFTA00014436

=== Page 2 ===
EFTA00014437


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=== Page 1 ===
From: Craig Hunter
To:
Subject: Thanks! Re: Ghislaine Maxwell's arrest
Date: Thu, 02 Jul 2020 19:21:47 +0000
Dear Ms. Strauss,
I applaud your arrest of Ghislaine Maxwell.
She no doubt has powerful friends, but if certain people don't have
to obey the law or face its consequences because of money,
power or connections, I fear we are lost.
Allowing certain people to not face the law's consequences is but a
short step from targeting certain people or groups for legal
harassment or trumped up imprisonment.
Without uniform enforcement of the law, laws are meaningless, our
constitution is meaningless, and the freedoms we value so highly
in this country would evaporate.
I wanted to thank you for your fight and sacrifice to maintain the
integrity of the Southern District of New York and for your work to
uphold the rule of law in the US.
Thank you for fighting for us,
Craig Hunter
EFTA00016165


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: FW: U.S. V. Maxwell, 20Cr330 (AJN) [Ms. Maxwell's Rule 16 Disclosures]
Date: Mon, 08 Nov 2021 19:04:22 +0000
Attachments: Maxwell's_Rule_16(b)(1)(C)_Disclosures.zip
Inline-Images: image001.jpg
#3 - Ryan Hall - brief due Monday 11/15
From:
(USANYS)
Sent: Monday, November 1, 2021 10:25 PM
To:
(USANYS)
>;
(USANYS)
Cc:
is
is
)
Subject: FW: U.S. V. Maxwell, 20Cr330 (AJN) [Ms. Maxwell's Rule 16 Disclosures]
From: Nicole Simmons
Sent: Monday, November 1, 2021 10:18 PM
To:
)
is
is
(USANYS)
is
)
Cc: Jeff Pagliuca
>; Laura Menninger
is
Subject: [EXTERNAL] U.S. V. Maxwell, 20Cr330 (AJN) [Ms. Maxwell's Rule 16 Disclosures]
Dear Counsel:
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Rule 16(b)(1)(C) Disclosures.
Thank you,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
DIRECT:
www.hmflaw.com
EFTA00014984


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=== Page 1 ===
From: "postmaster@voip.usa.doj.gov" <postmaster@voip.usa.doj.gov>
To:
Cc: USANYS-EpsteinVictims <USANYS.EpsteinVictims@usa.doj.gov>
Subject: Voice Message Attached from
- name unavailable
Date: Thu, 01 Aug 2019 12:15:27 +0000
Attachments:
wav
Time: Aug 1, 2019 8:15:27 AM
Click attachment to listen to Voice Message
EFTA00015706


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: Jeffrey Epstein
Date: Sun, 07 Jul 2019 20:57:39 +0000
Importance: Normal
thanks man!
From:
(USANYS)
Sent: Sunday, July 07, 2019 16:39
To:
Subject: Fwd: Jeffrey Epstein
Congrats again!
Begin forwarded message:
From:
(USANYS)"
Date: July 7, 2019 at 1:08:19 PM EDT
To:
Cc:
)"
i
)"
)"
i
(USANYS)"
Subject: Jeffrey Epstein
Hey PCU - As you likely may have seen/heard at this point, last evening, we arrested Jeffrey Epstein on sex trafficking
charges. Epstein is in custody and will be presented and arraigned on an Indictment that will be unsealed tomorrow
morning.
The case is an incredibly important one - not only is the conduct extremely serious and deeply disturbing - but our
charges ensure that dozens if not more of Epstein's victims, girls who were as young as 14 at the time they were abused,
will finally have their day in court. It is an extraordinarily worthy prosecution and just the latest example of how this
unit will never shy away from bringing tough cases against powerful people who have committed grievous crimes.
Please join me and
in extending a very well-deserved congratulations to the team,
who have worked tirelessly to make this case happen (and happen so quickly). They have done us all proud, and if you
are free, we hope you join us for the press conference formally announcing the charges, which should happen Monday
morning at 11.
&
EFTA00015598


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=== Page 1 ===
From:
"
)"
To:
"
(USANYS)"
Subject: RE: draft cover letter
Date: Thu, 07 Oct 2021 02:44:09 +0000
Attachments: 2021.10.XX_Maxwell_Cover_Letter_v1.5docx V2.docx
Current draft.
From:
(USANYS)
Sent: Wednesday, October 6, 2021 8:52 PM
To:
Subject: draft cover letter
Here is a draft cover letter. Please feel free to edit. I left a few things highlighted that I wasn't sure about.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00015128


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein
Date: Fri, 07 Dec 2018 16:04:05 +0000
Importance: Normal
On my way
From:
Sent: Friday, December 07, 2018 11:03 AM
To:
is
>;
Cc:
Subject: RE: Epstein
suggests going to
office because his speakerphone is good. Headed there now.
From:
Sent: Friday, December 07, 2018 11:00 AM
To:
is
Cc:
is
Subject: RE: Epstein
Meeting in my office? Or
?
From:
Sent: Thursday, December 06, 2018 9:25 PM
To:
Cc:
is
>;
Subject: Re: Epstein
I can call in at 11:00.
Sent from my iPhone
On Dec 6, 2018, at 9:22 PM,
wrote:
Ok for me.
Sent from my iPhone
On Dec 6, 2018, at 7:12 PM,
wrote:
Good for me.
From:
Sent: Thursday, December 6, 2018 7:08 PM
EFTA00014309

=== Page 2 ===
To:
Cc:
is
>;
Subject: Re: Epstein
How about 11:00?
Sent from my iPhone
On Dec 6, 2018, at 7:04 PM,
wrote:
In case you haven't seen, various lawmakers are now calling on DOJ to explain the Epstein NPA. If you have a few
minutes tomorrow, would be helpful to touch base.
https://www.nbcnews.com/news/us-news/lawmakers-demand-probe-sex-offender-jeffrey-epstein-s-sweetheart-
deal-n944516
EFTA00014310


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=== Page 1 ===
From:
(USANYS)"
To: Christian Everdell
, "Mark S. Cohen"
Bobbi Sternheim
, "Laura
Menninger"
, Jeff Pagliuca
Cc:
)"
)"
,
)"
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Date: Fri, 08 Oct 2021 02:03:20 +0000
Attachments: 2021.10.07_Maxwell_Discovery_Letter.pdf
Counsel,
We have an additional discovery production ready to send to you. Attached please find the accompanying cover letter.
The production will be made via USAfx.
We will send a CD with the new production to the MDC for Ms. Maxwell. If you would prefer that she receive the
production on a drive, we can either request that the MDC send us one of the drives back to load with the production, or
we can load a new drive if you would like to provide us with one.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00015185


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: Re: Epstein FOIA Updates
Date: Tue, 23 Nov 2021 17:16:14 +0000
Those are the addresses I have for him. I would try Stacey, his lawyer. She is usually very responsive. Thanks for
handling this
!
On Nov 23, 2021, at 11:50 AM,
(USANYS)
wrote:
Hi Public Corruption Chiefs,
FYI, since the Times article came out today about Epstein's incarceration and death, BOP has been receiving multiple
new requests for the records released in the FOIA matter (ABC, CNN, MuckRack). BOP plans to respond to those
requests quickly and release the same records.
One minor wrinkle: the FOIA specialist at BOP has tried to contact Mark Epstein a couple times regarding his
communications from about a month ago. But so far he has not responded to her. She has asked if we have contact info
for him. What I have is this phone number
and these emails Mark Epstein
and
STACEY RICHMAN
>. I am going to confirm BOP has these, but please let me know if there is
some other way to contact him.
Thanks,
Assistant United States Attorney
White Plains, NY 10601
Telephone:
EFTA00014714


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=== Page 1 ===
From:
To:
Subject: FW: Follow-up
Date: Thu, 19 Dec 2019 17:14:40 +0000
FYI, below.
From:
Sent: Thursday, December 19, 2019 12:14
To: William Callahan
Subject: RE: Follow-up
Mr. Callahan,
Thank you for your email, and for speaking with me yesterday. As we discussed, we're not able to talk about hypothetical
representations, but to the extent you ultimately represent anyone who may have information in connection with our
ongoing investigation, please feel free to give us a call if/when that happens.
Best regards,
Assistant U.S. Attorney
Southern District of New York
From: William Callahan
Sent: Thursday, December 19, 2019 11:10
To:
Subject: Follow-up
Attn: AUSA
Re: Epstein Matter
Confirming our tel-conference of yesterday and the Subject discussed, I expect it will take 3-4 weeks for me to
engage in discussions with Subject or his representative.
Thank you,
William P. Callahan
Attorney At Law
President, Unitel
New York, NY 10016
https://callahanandrobinson.com/lawyers/
EFTA00016420

=== Page 2 ===
www.unitel.com (click on British Flag)
Formerly U.S. Department of Justice
Member Association of Former Intelligence officers (AFIO)
Member, International Bar Association, London
EFTA00016421


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=== Page 1 ===
From:
To:
Subject: Fwd: our latest on epstein
Date: Mon, 14 Oct 2019 17:57:18 +0000
FYI
Begin forwarded message:
From: "Goldstein, Matthew"
Date: October 14, 2019 at 1:52:47 PM EDT
To:
Subject: our latest on epstein
we now posted the financials online
matt
https://int.nyt.com/data/documenthelper/1882-epstein-financial-
statements/fc7518962c5a9e00805e/optimized/full.pdf#page=1
also did this story with it
https://www.nytimes.com/2019/10/14/business/jeffrey-epstein-estate.html
Matthew Goldstein
The New York Times
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=== Page 1 ===
From:
To:
Subject: Automatic reply: quick trial question
Date: Tue, 27 Aug 2019 13:49:09 +0000
I am currently on trial before the Honorable Ronnie Abrams. I will be checking email at the end of each trial day. If you need immediate
assistance in connection with United States V. Epstein, 19 Cr. 490 (RMB), please contact AUSA
at
For all other matters,
please contact AUSA
at
Thank you.
EFTA00014375


c1: EFTA00017028
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017028.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Epstein search warrant documents
Date: Tue, 12 May 2020 15:43:44 +0000
Okay understood, thanks. Let's see what it looks like and then we can go from there. I assume we prefer to just get the
raw data, rather than having the FBI process it poorly again, it's just a really unfortunate delay - so if farming it out would
ultimately be more efficient, especially with everybody working remotely these days, we are very happy to push for that.
Thanks again.
From:
Sent: Tuesday, May 12, 2020 11:42
To:
Cc:
Subject: RE: Epstein search warrant documents
Right now we have a vendor to process the data as that is how we got the data uploaded to Relativity. I do not know the
data size of anything yet so I did not want to talk to Ed yet about the amount of data that needs to be processed until I got
something from the FBI.
From:
Sent: Tuesday, May 12, 2020 11:37 AM
To:
Cc:
is
Subject: FW: Epstein search warrant documents
should we be asking for permission to retain an outside vendor to deal with this? I just absolutely can't believe that
eight months after the search, the FBI is going to dump terabytes of raw data on us to process, which I assume will take
some process of months to process and upload. Would it be more efficient to have someone like Kroll or BRG do this in
the first instance? I don't think we would have a problem getting the funding for it, if that would be at all helpful.
From:
Sent: Tuesday, May 12, 2020 11:33
To:
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:
Sent: Tuesday, May 12, 2020 11:30
EFTA00017028

=== Page 2 ===
To:
is
Cc:
is
Subject: RE: Epstein search warrant documents
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
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:
Sent: Tuesday, May 12, 2020 11:11
To:
is
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.
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:
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
Subject: RE: Epstein search warrant documents
EFTA00017029

=== Page 3 ===
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data and
where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and send
it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
is
is
i
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:
)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
is
in
>;
(USANYS)
Cc:
in
is
is
is
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.
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.
EFTA00017030

=== Page 4 ===
From:
-
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
is
>;
V.
(USANYS)
Cc:
is
is
>;
is
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.
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:
Sent: Tuesday, April 07, 2020 15:27
To:
is
(USANYS)
i
(USANYS)
Cc:
is
)
is
i
)
is
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
)
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
is
(USANYS)
is
EFTA00017031

=== Page 5 ===
is
(USANYS)
Cc:
is
>;
i
in
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:
From:
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
)
is
is
(USANYS)
Cc:
is
V.
is
is
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
-
is
(USANYS)
is
is
(USANYS)
Cc:
is
is
i
i
EFTA00017032

=== Page 6 ===
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
-
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
-
Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers
and no way to match up anything-that is, even if we were to try to go hunt down every individual large file in the
native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get
a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million
documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
)
Sent: Wednesday, March 04, 2020 16:36
To:
>;
(USANYS)
is
V.
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
EFTA00017033

=== Page 7 ===
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
(office)
(cell)
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
is
(USANYS)
>;
in
(USANYS)
Cc:
is
>;
>;
is
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
is
V.
(USANYS)
Cc:
is
is
>;
is
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
Sent: Monday, February 24, 2020 17:38
To:
is
(USANYS)
is
is
(USANYS)
Cc:
in
is
is
is
EFTA00017034

=== Page 8 ===
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:
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
i
)
is
V.
(USANYS)
Cc:
is
>;
is
is
Subject: RE: Epstein search warrant documents
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
EFTA00017035

=== Page 9 ===
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:
is
Cc:
is
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
EFTA00017036


